Denovo Lighting, LLC v. Norman Lamps, Inc.

Northern District of Illinois, ilnd-1:2016-cv-05965

Exhibit B

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Case: 1:16-cv-05965 Document #: 1-2 Filed: 06/07/16 Page 1 of 5 PageID #:33 Exhibit B To The Complaint Case: 1:16-cv-05965 Document #: 1-2 Filed: 06/07/16 Page 2 of 5 PageID #:34 DeNovo Lighting, LLC v. Norman Lamps Inc. Claim Chart Claim Language Infringement by Norman Claim 1 1 An LED lamp device for use with multiple power The Accused Products contain sources comprising: Dual Mode Internal Drivers for Bypass lnstallation to operate with AC 120-347v and work with Electronic & Magnetic ballast for Plug & Play Direct installation. 2 first and second inputs for receiving power from a first The Accused Products have first power source; Nl and second Ll inputs for receiving power from AC 120- 347v or an Electronic & Magnetic ballast; 3 third and fourth inputs for receiving power from a The Accused Products have third second power source; L2 (ACl) and fourth N2 (AC2) inputs for receiving power from AC 120-347v or an Electronic & Magnetic ballast; 4 a first voltage reducing device connected between said The Accused Products use a first first and second inputs for electrical communication voltage reducing device with said first power source; capacitor C1B between said first input N1 and second input L1 for electrical communication with said AC 120-347v or an Electronic & Magnetic ballast; 5 a second voltage reducing device between said second The Accused Products use a and third inputs; second voltage reducing device capacitor C1C between said second input L1 and third input L2 (AC1); 6 a third voltage reducing device between said first and The Accused Products use a fourth inputs; third voltage reducing device capacitor C1A between said first input N1 and fourth input N2 1 Case: 1:16-cv-05965 Document #: 1-2 Filed: 06/07/16 Page 3 of 5 PageID #:35 Claim Language Infringement by Norman (AC2); 7 at least one voltage regulating circuit connected to said The Accused Products use at first and second inputs for providing linear current, least one voltage regulating which is not dependent on a voltage or circuit that is connected to said electromagnetic induction power; first input Nl and second input Ll to DC outputs B+ and B-for providing linear current, which is not dependent on a voltage or electromagnetic induction power; 8 and at least two LEDs connected in series across the at The Accused Products use at least one voltage regulating circuit. least two LEDs connected in series across the at least one voltage regulating circuit. There is a total of 100 LEDs that are connected as an array of 25 series strings of 4 LEDs each connected in parallel between V+ and B-. Claim 2 9 An LED lamp device as defined in claim 1, wherein The Accused Products are said LED lamp device is capable of use with more capable of use with a ballast or than one type of said power sources, said types of mains alternating current power sources are a ballast, mains alternating current voltage. voltage, direct current voltage and electromagnetic induction power. Claim 5 10 An LED lamp device as defined in claim 1, wherein The Accused Products use said a first voltage reducing device is a first capacitor. capacitors as voltage reducing devices. Claim 7 11 An LED lamp device as defined in claim 1, wherein The Accused Products use said voltage regulating circuit includes at least one discrete diodes D1-D8 to voltage converting device connected across said first represent at least one voltage voltage reducing device and at least one voltage converting device connected to regulating device; wherein said at least one voltage voltage reducing capacitors C1, regulating device is on a DC output side of said at C1A, C1B, and C1C and 2 Case: 1:16-cv-05965 Document #: 1-2 Filed: 06/07/16 Page 4 of 5 PageID #:36 Claim Language Infringement by Norman least one voltage converting device. providing DC outputs B+ and B- from the outputs of D1-D8 and providing power to voltage regulating device ICl. Claim 8 12 An LED lamp device as defined in claim 7, wherein The Accused Products use said at least one voltage converting device is at least discrete diodes D1-D8 to one AC-to-DC converter. represent at least one voltage converting device that is at least one AC-to-DC converter. Claim 9 13 An LED lamp device as defined in claim 7, wherein The Accused Products use said at least one voltage converting device is at least discrete diodes D1-D8 to one rectifier. represent at least one voltage converting device that is at least one rectifier. Claim 10 14 An LED lamp device as defined in claim 9, wherein The Accused Products use said at least one rectifier is at least one full-wave diode discrete diode rectifiers D1-D8 bridge rectifier. to represent at least one full- wave diode bridge rectifier. Claim 19 15 An LED lamp device as defined in claim 1, wherein The Accused Products use the said at least one voltage regulating circuit is at least RT8487 voltage regulator one voltage regulator. manufactured by Richtek Technology Corporation. Claim 22 16 An LED lamp device as defined in claim 19, wherein The Accused Products use the said at least one voltage regulator is at least one buck RT8487 buck converter voltage converter. regulator manufactured by Richtek Technology Corporation. Claim 23 3 Case: 1:16-cv-05965 Document #: 1-2 Filed: 06/07/16 Page 5 of 5 PageID #:37 Claim Language Infringement by Norman 17 An LED lamp device as defined in claim 1, wherein The Accused Products each use said at least two LEDs are at least two high brightness at least two high brightness LEDs. LEDs. Claim 24 18 An LED lamp device as defined in claim 1, wherein The Accused Products each use said at least two LEDs are at least two surface mount at least two surface mount LEDs. LEDs. 4