DMF v. AMP Plus - Complaint

Case 2:19-cv-04519 Document 1 Filed 05/23/19 Page 1 of 23 Page ID #:1
1 DAVIDSON LAW GROUP, ALC

Ben M. Davidson (State Bar No. 181464)
2 ben@dlgla.com
3 4500 Park Granada Blvd, Suite 202
Calabasas, California 91302
4 Office: (818) 918-4622
Fax: (310) 473-2941
5
6 ERGONIQ LLC
David W. Long
7 longdw@ergoniq.com
8 (pro hac vice to be filed)
8200 Greensboro Dr. Suite 900
9 McLean, VA 22102
10 Office: (202) 847-6853
11 Attorneys for Plaintiff DMF, Inc.

12
IN THE UNITED STATES DISTRICT COURT
13 FOR THE CENTRAL DISTRICT OF CALIFORNIA
14 DMF, Inc., Case No. 2:19-cv-4519
15 Plaintiff,
COMPLAINT FOR PATENT
16 v. INFRINGEMENT
17 AMPS Plus, Inc. d/b/a ELCO Lighting DEMAND FOR JURY TRIAL
and ELCO Lighting Inc.,
18
19 Defendant.
20
21 Complaint For Patent Infringement
22 This is a patent infringement action arising out of the copying of the
23 ornamental design of Plaintiff DMF Inc.’s (“DMF’s) DRD2 LED Module by
24 Defendant AMPS Plus Lighting, Inc. (“ELCO”). DMF seeks damages and injunctive
25 relief based on ELCO’s infringement of DMF’s U.S. Patent No. D847414 (“the
26 D‘414 Patent”) entitled a “Lighting Module” and U.S. Patent No. D847415 (“the
27 D‘415 Patent”) entitled “Unified Casting Lighting Module” (collectively “the
28 patents-in-suit”).
Complaint For Patent Infringement -1-
1 I. Parties
2 1. Plaintiff DMF, Inc. (“DMF” or “Plaintiff”) is headquartered and has
3 manufacturing facilities within this District at 1118 East 223rd Street, Carson,
4 California 90745.
5 2. Defendant AMP Plus, Inc., d/b/a ELCO Lighting and ELCO Lighting
6 Inc. (“ELCO” or “Defendant”) is incorporated in the State of California and has a
7 principal place of business located within this District at 2042 East Vernon Avenue,
8 Vernon, California 90058.
9 II. Jurisdiction and Venue
10 3. This action arises under the patent laws of the United States, Title 35 of
11 the United States Code. Accordingly, this Court has subject matter jurisdiction
12 under 28 U.S.C. §§ 1331 and 1338(a).
13 4. This Court has personal jurisdiction over Defendant ELCO in this
14 action because, among other reasons, ELCO has committed acts within the Central
15 District of California giving rise to this action and have established minimum
16 contacts with the forum state of California, including by establishing a regular and
17 established place of business within this District. ELCO has committed and
18 continues to commit acts of infringement in this District by, among other things,
19 offering for sale or selling products that infringe the patents-in-suit. ELCO has
20 purposefully availed itself of the benefits of doing business in the State of California
21 and the exercise of jurisdiction over ELCO would not offend traditional notions of
22 fair play and substantial justice. ELCO is registered to do business in the State of
23 California and has appointed as its agent for service of process its President at 2042
24 E Vernon Ave, Vernon, CA 90058.
25 5. Venue is proper in this District under 28 U.S.C. § 1400(b) because
26 ELCO resides in and has a regular and established place of business in this District
27 (2042 East Vernon Avenue, Vernon, CA 90058) and has committed acts of patent
28 infringement in this District.

III. The Patents-In-Suit

1
6. On April 30, 2019, the D’414 Patent, entitled “Lighting Module,” was
2
duly and legally issued by the U.S. Patent and Trademark Office (“U.S. Patent
3
Office”) to DMF’s inventors Michael D. Danesh and Dan Hero De Guzman
4
Cajumban. A true and correct copy of the D’414 Patent is attached as Exhibit A.
5
The D’414 Patent is valid, enforceable and in full force and effect.
6
7. DMF is the owner and assignee of all rights, title and interest in the
7
D’414 Patent, including the right to bring this action and enforce the D’414 Patent
8
against infringers, and to collect damages for all relevant times.
9
8. On April 30, 2019, the D’415 Patent, entitled “Unified Casting Lighting
10
Module,” was duly and legally issued by the U.S. Patent Office to DMF’s inventors
11
Danesh and Cajumban. A true and correct copy of the D’415 Patent is attached as
12
Exhibit B. The D’415 Patent is valid, enforceable and in full force and effect.
13
9. DMF is the owner and assignee of all rights, title and interest in the
14
D’415 Patent, including the right to bring this action and enforce the D’415 Patent
15
against infringers, and to collect damages for all relevant times.
16
IV. Factual Background
17
10. DMF is a leading manufacturer of residential and commercial
18
downlighting. DMF’s products stand out for their forward-thinking industrial
19
designs, and are selected by specifiers for prestigious new constructions throughout
20
the United States. DMF’s headquarters and manufacturing facilities in Carson,
21
California include a state-of-the-art research and development laboratory where
22
engineers and product designers work to improve existing products and develop new
23
ones. DMF invests substantially in its continuing efforts to develop leading
24
innovations in the LED lighting industry and has been awarded a number of industry
25
awards as well as United States patents on its innovations.
26
11. DMF developed a rigorous quality control program for its products that
27
has earned and maintained DMF’s reputation as a leading supplier of LED lighting
28

1 products that can be trusted to perform as advertised. All DMF products undergo a
2 rigorous, multi-tiered testing process to ensure that they meet DMF’s stringent
3 performance standards. DMF employs a number of U.S. military veterans in its
4 operation and performs quality-control testing procedures developed by the U.S.
5 military. As a result, DMF’s lighting fixtures have an industry leading success rate.
6 12. DMF makes, sells, and promotes light modules whose ornamental
7 designs are protected by the ‘414 Patent and the ‘415 Patent. These light modules
8 include the DRD2 LED Module, an image of which is shown below:
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

1 13. DMF started marketing and selling its DRD2 LED Module-based
2 lighting system products in 2014. For example, below is an image from a brochure
3 of various sales tools that DMF provided on the DRD2 LED Module by at least
4 December 2014.
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
2014 Sales Tools for DRD2 LED Module Products
28

1 14. By early 2015, the DRD2 LED Module-based lighting system was a
2 prominent part of DMF’s public website.
3 15. DMF showcased its DRD2 LED Module at many industry tradeshows
4 since at least June 2014, including:
5 ● LIGHTFAIR International 2014, Las Vegas, NV (June 3-5, 2014)
6 ● LIGHTFAIR International 2015, New York, NY (May 5-7, 2015)
7 ● LIGHTFAIR International 2016, San Diego, CA (April 26-28, 2016)
8 ● LIGHTFAIR International 2017, Philadelphia, PA (May 7-9, 2017)
9 ● LIGHTFAIR International 2018, Chicago, IL (May 8-10, 2017)
10
11
12
13
14
15
16
17
18
19
DRD2 LED Module Display at LIGHTFAIR International 2014 Tradeshow
20
21 16. DMF has complied with the marking requirements of 35 U.S.C. §
22 287(a) as of April 30, 2019 by marking its products patented and providing a link to
23 a webpage on its website identifying the D’414 Patent and the D’415 Patents.
V. ELCO And Its Infringing LED Module Designs
24
17. On information and belief, ELCO is a commodity-grade supplier of
25
lighting fixtures that owns the website at www.elcolighting.com. On information
26
and belief, after seeing the success of DMF’s DRD2 Module, ELCO decided to
27
make imitation modules and sell them under the name ELL Module. On information
28

1 and belief, after issuance of the D’414 and D’415 Patent, ELCO has been offering
2 for sale and selling ELL Modules.
3 18. Before, on and after May 21, 2019, ELCO has advertised at least one
4 version of the ELL Module (“Version A”) on its website at
5 https://elcolighting.com/sites/default/files/dl-
6 resource/files/ELCO_ElecNewsAd_18_06_web.pdf to promote sales of both the
7 ELL LED Module and “Flexa” Trims that can be attached to the ELL LED Module:
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27 A true and correct copy of an ELCO advertisement for the ELL LED Module and
28 Flexa Trims is attached hereto as Exhibit C.

1 19. Before, on and after May 22, 2019, ELCO has offered the ELL LED
2 Module for sale, and ELCO has advertised ELL LED Modules on its website, such
3 as at https://elcolighting.com/sites/default/files/dl-
4 resource/files/%230243_NoPrice_Color.pdf as the “Commercial Construction E.L.L.
5 System along with housings and trims compatible with the system:
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
A true and correct copy of the advertisement is attached hereto as Exhibit D.
26
20. On, before and after May 22, 2019, ELCO also has advertised its ELL
27
LED Module on its website at www.elcolighting.com/products/commercial-
28

1 construction-ell-led-module#product-sku and identifies it as covered by ELCO’s

2 design patent, U.S. Patent D820494 (the “ELCO D’494 Patent”). A true and correct
3 copy of a printout of this webpage is attached as Exhibit E and an excerpt as it
4 appears on the website is shown below, with ELCO’s D’494 Patent highlighted:
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21. ELCO also offers a second version of the ELL Module (“Version B”),
21
which it also identifies as using the same design shown in the ELCO D’494 Patent
22
on https://elcolighting.com/products/commercial-construction-ell-led-module. A
23
true and correct copy of a printout of this webpage is attached as Exhibit F and an
24
excerpt as it appears on the website is shown below, with ELCO’s ‘D494 Patent
25
highlighted:
26
27
28

1
2
3
4
5
6
7
8
9
10
11
12
22. ELCO also promoted the Version A and Version B ELL Modules at the
13
LightFair trade show starting on Monday May 20, 2019. A photograph of an ELCO
14
display at the trade show promoting these modules is shown below:
15
16
17
18
19
20
21
22
23
24
25
26 23. Attached hereto as Exhibit G is a true and correct copy of the ELCO
27 D’494 Patent showing the design that ELCO considers to be used by both the its
28 ELL Modules. The ELCO D’494 Patent claims the “ornamental design for an
Complaint For Patent Infringement - 10 -

1 integrated lighting module housing, as shown and described.” Figures 1, 2, and 7 of

2 ELCO D’494 Patent are shown below:
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
24. The ELCO D’494 Patent covers ELCO’s Version A ELL Module.
16
25. The ELCO D’494 Patent covers ELCO’s Version B ELL Module.
17
26. The ELCO D’494 Patent was issued on July 12, 2018 based on
18
Application Serial No. 29/594,122 (“the ELCO Design Application”). The
19
application was filed on February 17, 2017 by Brandon Cohen, who on information
20
and belief is Operations Manager of ELCO. Brandon Cohen filed the ELCO Design
21
Application more than two years after DMF started selling the DRD2 Module. On
22
information and belief, Brandon Cohen created the design in the ELCO Design
23
Application by copying DMF’s DRD2 Module, which was already a successful
24
product by the time he filed the ELCO Design Application in February 2017.
25
However, in violation of the duty of good faith and candor owed by all patent
26
applicants to the U.S. Patent Office, Brandon Cohen failed to disclose to the Patent
27
Office that ELCO’s design was based on the DRD2 Module or even cite the DRD2
28

1 Module to the U.S. Patent Office in connection with his patent application. As a
2 result, on May 2, 2018, the Patent Office Examiner who reviewed the ELCO Design
3 Application, Primary Examiner Angela Lee, allowed the ELCO Design Application
4 to issue as the D’494 Patent.
5 27. Because ELCO’s Brandon Cohen and others who had a duty to disclose
6 the DRD2 prior art to the Patent Office did not inform the Patent Office about
7 DMF’s prior art DRD2 Module and applied for a design patent on it, the U.S. Patent
8 Office was misled into believing that ELCO was the original inventor of DMF’s
9 design. On July 24, 2018, during prosecution of DMF’s own design patent
10 applications, Examiner Angela Lee, who issued the ELCO D’494 Patent, rejected
11 DMF’s claim on the design shown in DMF’s related Application Serial No.
12 29/663,040 as anticipated by ELCO’s ‘D494 Patent. Examiner Lee stated that “the
13 claimed invention was patented, described in a printed publication, or in public use,
14 on sale or otherwise available to the public before the effective filing date of the
15 claimed invention.” Examiner Lee explained the U.S. Patent Office determination
16 that DMF’s design was anticipated by ELCO’s design, stating:
17 “The appearance of D820,494 is substantially the same as that of the
18 claimed design. … Both lighting modules have the same overall shape
19 and proportions, including the same shape and number of fins located
20 on a base with the same recessed and protruding edges, and include the
21 same two circular openings surrounded by a curved linear feature.”1
22 To further demonstrate the similarity in the ELCO and DMF designs,
23 Examiner Lee provided the following comparison of the drawings in ELCO’s
24 D’494 Patent and the DMF patent application then under review:
25
26
27 1
Application Ser. No. 29/638,259 (July 24, 2018 Office Action) at 3.
28

1
2
3
4
5
6
7
8
9
10
[ELCO’s U.S. Patent No. D820494 Cited By Patent Office
11
As Anticipating DMF’s Patent Application]
12
13
14
15
16
17
18
19
20
21
22 [DMF’s U.S. Patent Appln. No. 29/663,040]
23
24
25 28. DMF was able to demonstrate to the U.S. Patent Office the chain of
26 continuity of its own patent applications, which have an earlier effective filing date
27 than the ELCO Design Patent Application. Therefore, the Patent Office withdrew
28

1 the rejection in further prosecution of related applications filed by DMF. The U.S.
2 Patent Office later issued the D’414 and D‘415 Patents to DMF on April 30, 2019.
3
4 VI. Claims for Relief
5 COUNT I: INFRINGEMENT OF THE D’414 PATENT
6 29. DMF hereby incorporates paragraphs 1 – 28 as if fully set forth herein.
7 30. The claimed design of the D‘414 Patent is shown in Figures 1 and 2 of
8 the patent and described in the accompanying figure descriptions, which indicate that
9 broken lines do not show the claimed design. See Exhibit A. Images of the claimed
10 design are shown below, including a portion of Figure 1 showing the claimed design,
11 followed by Figure 2 of the D’414 Patent:
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
31. On information and belief, ELCO makes, uses, offers for sale, sells,
18
imports and supplies to the United States infringing ELCO ELL LED Modules.
19
32. ELCO offers the ELL LED Modules for sale, including through its
20
website and, on information and belief, through sales representatives and others
21
acting in concert with ELCO. An image of the Version A ELL LED Module from
22
ELCO’s website, which ELCO marks as using the design of ELCO D’494 Patent, is
23
shown below:
24
25
26
27
28

1
2
3
4
5
6
7
8
9
10
11
12
13
14 33. An image of the Version B ELL LED Module from ELCO’s website,
15 which ELCO also marks using the same ELCO D’494 Patent, is shown in the image
16 below from that website:
17
18
19
20
21
22
23
24
25
26
27
28

1 34. On information and belief, ELCO also offers to sell and sells both the
2 Version A and Version B of the ELL Modules through distributors, including online
3 distributors and, on information and belief, brick and mortar distributors that do not
4 publicly show the products they sell on any website. A representative image of an
5 ELL Module Version A ELL Module offered for sale as of May 21, 2018 by
6 ELCO’s online distributor Bees Lighting is shown below:
7
8
9
10
11
12
13
14
15
16
17
18
35. In the eye of the ordinary observer familiar with the relevant prior art,
19
giving such attention as a purchaser usually gives, the claimed design of the D’414
20
Patent and the design of the Version A and Version B ELL Modules are substantially
21
the same, such that the ordinary observer would be deceived into believing that the
22
design of the ELL Modules is the design claimed in the D’414 Patent.
23
36. DMF did not give ELCO authorization or license to make, use, offer
24
to sell, or sell the infringing products. ELCO has applied the D’414 Patent patented
25
design, or at least a colorable imitation thereof, to the ELL LED Modules for
26
purposes of sale. ELCO sells and exposes for sale the ELL LED Modules to which
27
28

1 the D’414 Patent patented design, or at least colorable imitation thereof, has been
2 applied.
3 37. ELCO has directly infringed, and continues to directly infringe, the
4 D’414 Patent by making, using, offering to sell, selling, and/or importing the ELL
5 Modules having substantially the same ornamental design as the design claimed in
6 the D’414 Patent, in violation of 35 U.S.C. §§ 271(a) and 289. As a result of
7 ELCO’s infringement, DMF is entitled to damages of at least a reasonable royalty
8 for the infringement, lost profits for the infringement, disgorgement of ELCO’s
9 profits and/or at least $250 for each ELL LED Module to which ELCO LED Module
10 for which ELCO has applied the D’414 Patent patented design or colorable imitation
11 thereof.
12 COUNT II: INFRINGEMENT OF THE D’415 PATENT
13 38. DMF hereby incorporates paragraphs 1 - 38 as if fully set forth herein.
14 39. The claimed design of the D‘415 Patent is shown in Figures 1 and 2 of
15 the patent and described in the accompanying figure descriptions, which indicate that
16 broken lines do not show the claimed design. See Exhibit A. Images of the claimed
17 design are shown below:
18
19
20
21
22
23
24
25
26
27
28

1
2
3
4
5
6
7
8
9
40. In the eye of the ordinary observer familiar with the relevant prior art,
10
giving such attention as a purchaser usually gives, the claimed design of the D’415
11
Patent and the design of the ELL Modules shown above are substantially the same,
12
such that the ordinary observer would be deceived into believing that the design of
13
the Version A and Version B ELL Modules is the design claimed in the D’415
14
Patent.
15
41. DMF did not give ELCO authorization or license to make, use, offer
16
to sell, or sell the infringing products. ELCO has applied the D’415 Patent patented
17
design, or at least a colorable imitation thereof, to the ELL LED Modules for
18
purposes of sale. ELCO sells and exposes for sale the ELL LED Modules to which
19
the D’415 Patent patented design, or at least colorable imitation thereof, has been
20
applied.
21
42. ELCO has directly infringed, and continues to directly infringe, the
22
D’415 Patent by making, using, offering to sell, selling and/or importing the ELL
23
Modules having substantially the same ornamental design as the design claimed in
24
the D’415 Patent, in violation of 35 U.S.C. §§ 271(a) and 289. As a result of
25
ELCO’s infringement, DMF is entitled to damages of at least a reasonable royalty
26
for the infringement, lost profits, disgorgement of ELCO’s profits and/or at least
27
28

1 $250 for each ELL LED Module to which the ELCO LED Module for which ELCO
2 has applied the D’415 patent patented design or colorable imitation thereof.
3
4 VII. Prayer For Relief
5 Plaintiff DMF respectfully requests the following relief from the Court:
6 A. A judgment that ELCO has infringed the ‘D414 Patent;
7 B. A judgment that ELCO has infringed the ‘D415 Patent;
8 C. A judgment and order requiring ELCO to pay DMF its damages, costs,
9 expenses, prejudgment interest and post-judgment interest for ELCO’s acts of
10 infringement in accordance with 35 U.S.C. §§ 284 and 289, including at least a
11 reasonable royalty, lost profits, disgorgement of ELCO’s profits and/or $250 per
12 infringing article;
13 D. Injunctive relief; and
14 E. Any and all other relief to which DMF may show itself to be entitled.
15
Dated: May 22, 2019 By: /s/ Ben M. Davidson
17 ben@dlgla.com
4500 Park Granada Blvd, Suite 202
18 Calabasas, California 91302
Office: (818) 918-4622
19 Fax: (310) 473-2941
20 Attorneys for Plaintiff DMF, Inc.
21
22
23
24
25
26
27
28

1 DEMAND FOR JURY TRIAL

2 Pursuant to Rule 38 of the Federal Rules of Civil Procedure, DMF requests a
3 trial by jury of any issues so triable by right.
4
Dated: May 22, 2019 By: /s/ Ben M. Davidson
6 ben@dlgla.com
4500 Park Granada Blvd, Suite 202
7 Calabasas, California 91302
Office: (818) 918-4622
8 Fax: (310) 473-2941
9
Attorneys for Plaintiff DMF, Inc.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

Exhibits
1
 Exhibit A – U.S. Patent No. D847414
2
 Exhibit B - U.S. Patent No. D847415
3  Exhibit C – ELCO Website at https://elcolighting.com/sites/default/files/dl-
4 resource/files/ELCO_ElecNewsAd_18_06_web.pdf
 Exhibit D - ELCO Website at https://elcolighting.com/sites/default/files/dl-
5 resource/files/%230243_NoPrice_Color.pdf
6  Exhibit E - ELCO Website at www.elcolighting.com/products/commercial-
construction-ell-led-module#product-sku
7
 Exhibit F - ELCO Website at https://elcolighting.com/products/commercial-
8 construction-ell-led-module
9  Exhibit G – U.S. Patent No. U.S. Patent No. D820494
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

Case 2:19-cv-04519 Document 1-1 Filed 05/23/19 Page 1 of 9 Page ID #:24
EXHIBIT A
EXHIBIT A - PAGE 24
EXHIBIT A - PAGE 25
EXHIBIT A - PAGE 26
EXHIBIT A - PAGE 27
EXHIBIT A - PAGE 28
EXHIBIT A - PAGE 29
EXHIBIT A - PAGE 30
EXHIBIT A - PAGE 31
EXHIBIT A - PAGE 32
EXHIBIT B
EXHIBIT B - PAGE 33
EXHIBIT B - PAGE 34
EXHIBIT B - PAGE 35
EXHIBIT B - PAGE 36
EXHIBIT B - PAGE 37
EXHIBIT B - PAGE 38
EXHIBIT B - PAGE 39
EXHIBIT B - PAGE 40
EXHIBIT B - PAGE 41
EXHIBIT D
EXHIBIT D - PAGE 44
Systems Resources About Us
Commercial Construction E.L.L. LED Module

11.8/13.7W, 2700K - Sunset K, 850/1100 lm
Overview Resources Catalog Numbers
PRODUCT FEATURES
PRODUCT IMAGE
• Module used with E.L.L Commercial

LINE ART Housing for 0-10V dimming and/or
Emergency battery back-up options
• Smooth lens provides even lighting
illuminations
• Works in 4" and 6" housing with twist-
Dimension &-lock trims
• Excellent color rendering 93+ CRI
• U.S Patent D820494 & Patents
Pending
• Beam angles are 60° standard and 10°,
25°, 36° optional.
Wattage 11.8/13.7W
Lumens 850/1100 lm
EXHIBIT D - PAGE 45
Resources & Downloads Color Temp. 2700K - Sunset K
Lamp Type LED
Specifications Commercial ELL System

Dimmer Compatibility
IES Files
Product SKU
Catalog Number Lamp type Wattage CCT Lumens Spec
ELL2127D LED 11.8/13.7W 2700K 850/1100 lm
ELL2130D LED 11.8/13.7W 3000K 850/1100 lm
ELL2130D LED 11.8/13.7W 3500K 850/1100 lm
ELL2135D LED 11.8/13.7W 3500K 850/1100 lm
ELL2140D LED 11.8/13.7W 4000K 850/1100 lm
ELL21SDD LED 11.8/13.7W Sunset K 850/1100 lm
Product Number Builder
E.L.L. LED Module Lumens Color Temperature Beam Angle
ELL
EXHIBIT D - PAGE 46
21 850/1100 27D 2700K 60° Standard

30D 3000K F 36°
35D 3500K N 25°
40D 4000K S 10°
SDD Sunset
Example: ELL2127D [ E.L.L. LED Module, 850/1100, 2700K, 60° Standard ]
Systems Blog Download spec sheets

Resources Careers Need help? Get in touch with ELCO
About ELCO Contact
TELEPHONE:
Customer Login (323) 231 - 2600
EMAIL:
customerservice@elcolighting.com
© ELCO LIGHTING. 2019
EXHIBIT D - PAGE 47
EXHIBIT E
EXHIBIT E - PAGE 48
EXHIBIT E - PAGE 49
EXHIBIT F
EXHIBIT F - PAGE 50
Commercial Construction E.L.L. LED Module | ELCO Lighting Page 1 of 3
Systems Resources About Us
Commercial Construction E.L.L. LED Module

11.8/13.7W, 2700K - Sunset K, 850/1100 lm
Overview Resources Catalog Numbers
PRODUCT FEATURES
PRODUCT IMAGE
LINE ART
Dimension
• Module used with E.L.L Commercial

Housing for 0-10V dimming and/or
Emergency battery back-up options
• Smooth lens provides even lighting
illuminations
• Works in 4" and 6" housing with twist-
&-lock trims
• Excellent color rendering 93+ CRI
https://elcolighting.com/products/commercial-construction-ell-led-module 5/22/2019
EXHIBIT F - PAGE 51
• U.S Patent D820494 & Patents

Pending
• Beam angles are 60° standard and 10°,
25°, 36° optional.
Wattage 11.8/13.7W
Lumens 850/1100 lm
Color Temp. 2700K - Sunset K
Lamp Type LED
Specifications Commercial ELL System

Dimmer Compatibility
IES Files
Product SKU
Catalog Number Lamp type Wattage CCT Lumens Spec
ELL2127D LED 11.8/13.7W 2700K 850/1100 lm 4
ELL2130D LED 11.8/13.7W 3000K 850/1100 lm 4
ELL2130D LED 11.8/13.7W 3500K 850/1100 lm 4
ELL2135D LED 11.8/13.7W 3500K 850/1100 lm 4
ELL2140D LED 11.8/13.7W 4000K 850/1100 lm 4
ELL21SDD LED 11.8/13.7W Sunset K 850/1100 lm 4
Product Number Builder
EXHIBIT F - PAGE 52
E.L.L. LED Module Lumens Color Temperature Beam Angle
ELL
21 850/1100 27D 2700K 60° Standard

30D 3000K F 36°
35D 3500K N 25°
40D 4000K S 10°
SDD Sunset
Example: ELL2127D [ E.L.L. LED Module, 850/1100, 2700K, 60° Standard ]
Systems Blog Download spec sheets

Resources Careers Need help? Get in touch with ELCO
About ELCO Contact
TELEPHONE:
Customer Login (323) 231 - 2600
EMAIL:
customerservice@elcolighting.com
© ELCO LIGHTING. 2019
EXHIBIT F - PAGE 53
EXHIBIT G
EXHIBIT G - PAGE 54
THE MAINMOTOR ON LA CARTA DA UNITE

USOOD8204945
(12 ) Cohen
United States Design Patent ( 10) Patent No.: US D820 ,494 S
(45) Date of Patent: * * Jun. 12 , 2018
(54 ) INTEGRATED LIGHTING MODULE D682,459 S * 5 /2013 Gordin ..... D26 /74
HOUSING D694 ,456 S * 11/ 2013 Rowlette , Jr. ................ D26 / 74
D708, 381 S * 7 /2014 Rashidi D26 / 74
D714 ,989 S * 10 /2014 Rowlette , Jr. .............. D26 /74
(71) Applicant: Brandon Cohen , Vernon , CA (US ) D726 ,949 S * 4 /2015 Redfern .............. ........... D26 / 74
D734 ,525 S * 7 /2015 Gordin ........................... D26 / 74
(72 ) Inventor : Brandon Cohen , Vernon, CA (US ) D777 , 967 S * 1 /2017 Redfern D26 / 74
D779, 100 S * 2 / 2017 Redfern ............ D26 / 74
(* * ) Term : 15 Years D790 , 102 S * 6 /2017 Guzzini ........ . ....... 126 / 74
* cited by examiner
(21) Appl. No.: 29 /594,122 Primary Examiner — Angela J Lee
(22 ) Filed : Feb . 15 , 2017 (74 ) Attorney, Agent, or Firm — Eric Kelly
(51) LOC (11) CI. 26 -05 (57) CLAIM
( 52 ) U . S . CI. The ornamental design for an integrated lighting module
USPC D26 / 74 housing, as shown and described .
(58 ) Field of Classification Search DESCRIPTION
USPC ........ D26 / 74 , 72 , 75 , 76 , 77 , 78 , 85 , 88 , 89 ,
D26 / 118 , 138 , 141; 362 /364 , 365 , 373 , FIG . 1 illustrates a top front perspective view of a new and
362 /145 , 146 , 147 , 148, 150, 153, 153. 1 , ornamental integrated lighting module housing;
362/ 294 , 296 .01, 296 .07 , 296 . 08 FIG . 2 illustrates a front view thereof;
See application file for complete search history. FIG . 3 illustrates a back view thereof;
FIG . 4 illustrates a left-side view thereof;
(56 ) References Cited FIG . 5 illustrates a right- side view thereof;
FIG . 6 illustrates a top view thereof; and ,
U . S . PATENT DOCUMENTS FIG . 7 illustrates a bottom view thereof.
D606 ,696 S * 12/2009 Chen . ...................... D26 / 74 Broken lines in any of included figures are for illustrative
D640,819 S * 6 / 2011 Pan ........... D26 /74 purposes only and form no part of the claimed design .
D656 ,263 S * 3 /2012 Ogawa .. D26 / 74
D668, 372 S * 10 / 2012 Renshaw . D26 / 74 1 Claim , 5 Drawing Sheets
-
r
EXHIBIT G - PAGE 55
U . S . Patent Jun. 12, 2018 Sheet 1 of 5 US D820 ,494 S
fr i billas
.
FIG
1
L r i i - - - - -- - - - - -
Atoo.
minimninin niin
SSS
--
-
Il 14 . - - - - --
e st
iv ivse
v
L
LLL ocalitate
VVVV
EXHIBIT G - PAGE 56
ivtar +
-
VALS
VIL
?
-
vi
w
www
PW,y y
-
w
STOF
Herrer
FIG . 2
?
-
-
·
w
w
Viv
FIG . 3
EXHIBIT G - PAGE 57
-
'
:
-
-
? VIA
-- - -
FIG . 4
-
-
-
SYNK -
+ -
+
L
at e +
Hein Li
FIG . 5
EXHIBIT G - PAGE 58
. . . . . . . . . . . . . . . . . . . . . . . . . . . . .
-- - - -
--
Hi -
-
?
?
?
?
?
I .
! L . .
FIG . 6
EXHIBIT G - PAGE 59
??????? ??
--- - - - - - - - - -
------------
-- + + + + + + + + + + + + + + + + + + + + + + + + + + + *. *. * . . . . * . * . . *. *. * * * * * ** * * * * * * * ** * * *
+ + + + + + +
FIG . 7
EXHIBIT G - PAGE 60

DMF v. AMP Plus - Complaint

Uploaded by

Document Information

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

DMF v. AMP Plus - Complaint

Uploaded by

Copyright:

Available Formats

Case 2:19-cv-04519 Document 1 Filed 05/23/19 Page 1 of 23 Page ID #:1

1 DAVIDSON LAW GROUP, ALC

11 Attorneys for Plaintiff DMF, Inc.

Complaint For Patent Infringement -2-

III. The Patents-In-Suit

Complaint For Patent Infringement -3-

Complaint For Patent Infringement -4-

Complaint For Patent Infringement -5-

Complaint For Patent Infringement -6-

28 Flexa Trims is attached hereto as Exhibit C.

Complaint For Patent Infringement -7-

Complaint For Patent Infringement -8-

1 construction-ell-led-module#product-sku and identifies it as covered by ELCO’s

Complaint For Patent Infringement -9-

Complaint For Patent Infringement - 10 -

1 integrated lighting module housing, as shown and described.” Figures 1, 2, and 7 of

Complaint For Patent Infringement - 11 -

Complaint For Patent Infringement - 12 -

Complaint For Patent Infringement - 13 -

Complaint For Patent Infringement - 14 -

Complaint For Patent Infringement - 15 -

Complaint For Patent Infringement - 16 -

16 below from that website:

Complaint For Patent Infringement - 17 -

Complaint For Patent Infringement - 18 -

Complaint For Patent Infringement - 19 -

Complaint For Patent Infringement - 20 -

Complaint For Patent Infringement - 21 -

1 DEMAND FOR JURY TRIAL

Complaint For Patent Infringement - 22 -

Complaint For Patent Infringement - 23 -

Systems Resources About Us

Commercial Construction E.L.L. LED Module

Overview Resources Catalog Numbers

• Module used with E.L.L Commercial

Resources & Downloads Color Temp. 2700K - Sunset K

Lamp Type LED

Specifications Commercial ELL System

Catalog Number Lamp type Wattage CCT Lumens Spec

ELL2127D LED 11.8/13.7W 2700K 850/1100 lm

ELL2130D LED 11.8/13.7W 3000K 850/1100 lm

ELL2130D LED 11.8/13.7W 3500K 850/1100 lm

ELL2135D LED 11.8/13.7W 3500K 850/1100 lm

ELL2140D LED 11.8/13.7W 4000K 850/1100 lm

ELL21SDD LED 11.8/13.7W Sunset K 850/1100 lm

Product Number Builder

E.L.L. LED Module Lumens Color Temperature Beam Angle

21 850/1100 27D 2700K 60° Standard

Example: ELL2127D [ E.L.L. LED Module, 850/1100, 2700K, 60° Standard ]

Systems Blog Download spec sheets

© ELCO LIGHTING. 2019

Systems Resources About Us

Commercial Construction E.L.L. LED Module

Overview Resources Catalog Numbers

• Module used with E.L.L Commercial

• U.S Patent D820494 & Patents

Color Temp. 2700K - Sunset K

Lamp Type LED

Specifications Commercial ELL System

Catalog Number Lamp type Wattage CCT Lumens Spec

ELL2127D LED 11.8/13.7W 2700K 850/1100 lm 4

ELL2130D LED 11.8/13.7W 3000K 850/1100 lm 4

ELL2130D LED 11.8/13.7W 3500K 850/1100 lm 4

ELL2135D LED 11.8/13.7W 3500K 850/1100 lm 4