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Case 1:19-cv-01570-UNA Document 1 Filed 08/26/19 Page 1 of 10 PageID #: 1

IN THE UNITED STATES DISTRICT COURT


FOR THE DISTRICT OF DELAWARE

LUTRON ELECTRONICS CO., INC., and §


LUTRON TECHNOLOGY COMPANY §
LLC, §
§ Civil Action No. ___________________
Plaintiffs, §
§
v. § JURY TRIAL DEMANDED
§
SAVANT SYSTEMS, LLC, §
§
Defendant. §

COMPLAINT FOR DESIGN PATENT INFRINGEMENT

Plaintiffs Lutron Electronics Co., Inc. and Lutron Technology Company LLC (collectively,

“Lutron”) file this Complaint against Savant Systems, LLC (“Savant” or “Defendant”) because of

Savant’s infringement of U.S. Patent No. D734,277 (the “’277 patent” or “Asserted Patent”),

attached as Exhibit A.

Lutron invests heavily in research and development to create innovative products and,

along with its dealers, expends substantial resources in bringing these innovative products to their

customers. Lutron also makes major investments in intellectual property protecting these

innovations, and in turn protects that IP diligently in order to defend against unfair competition.

Thus, Plaintiffs allege as follows, based on their own knowledge as to themselves and their

own actions and based on information and belief as to all other matters:

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PARTIES

1. Lutron Technology Company LLC (“Lutron Technology”) is a Delaware limited

liability company with its principal place of business located at 7200 Suter Road, Coopersburg,

Pennsylvania 18036.

2. Lutron Electronics Co., Inc. (“Lutron Electronics”) is a Pennsylvania corporation

with its principal place of business located at 7200 Suter Road, Coopersburg, Pennsylvania 18036.

3. Savant Systems, LLC is a limited liability company organized and existing under

the laws of the State of Delaware, with its principal place of business at 45 Perseverance Way,

Hyannis, MA 02601. Savant may be served through its registered agent Corporation Service

Company at 251 Little Falls Drive, Wilmington DE 19808, (302) 636-5401.

JURISDICTION AND VENUE

4. This action arises under the Patent Act, 35 U.S.C. § 1 et seq.

5. Subject matter jurisdiction is proper in this Court under at least 28 U.S.C. §§ 1331

and 1338.

6. Venue is proper in this District pursuant to 28 U.S.C. § 1400(b).

7. Defendant resides in this District and is a limited liability company organized under

the laws of the state of Delaware.

8. Defendant has a regular and established place of business in this District, including

by virtue of its registered agent for service of process in Wilmington, DE.

9. Defendant has transacted business in this District and has committed, by itself or in

concert with others, acts of direct and indirect patent infringement.

10. Defendant sells and/or induces use of its products in this District through numerous

retailers; manufacturers’ representatives; electrical distributors; authorized providers and/or

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authorized dealers – e.g. Integrated Home, LLC and Magnolia Design Center; and lighting

showrooms – e.g. Overture Ultimate Home Electronics.

11. Defendant conducts substantial business in this District, directly and through

intermediaries, including (i) regularly doing or soliciting business, engaging in other persistent

courses of conduct, and deriving substantial revenue from goods and services provided to

individuals in this District, and (ii) using the Savant webpages, “Authorized Dealers”, and other

means to sell goods and services in this District.

BACKGROUND

12. Established in 1961, Lutron is the lighting control industry pioneer,

manufacturing and/or supplying many thousands of products to address the lighting control

requirements of virtually any residential or commercial project. Lutron’s success is the result of

its long history of innovation, beginning with its founder’s successful commercialization of the

solid-state dimmer switch used to dim lamps (a generic term for light bulbs of many varieties).

After more than fifty years, Lutron remains a leading innovator and the world’s industry leader in

controlling natural and artificial light.

13. Lutron’s history of innovation, quality, and success has been widely recognized.

For example, on April 29, 2010, notable products, objects, and papers from Lutron’s 50-year

history were added to the Electricity Collection of the Smithsonian’s National Museum of

American History, joining other notable artifacts such as Thomas Edison’s experimental light

bulbs. Lutron’s products are also utilized in some of the most renowned locations in the world.

For example, Lutron’s lighting control systems are utilized in such locations as the White House,

the Guggenheim Museum, the Metropolitan Museum of Art, the Bank of China headquarters, and

Windsor Castle.

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14. Lutron introduced the world’s first commercially viable solid-state electronic

lighting control device used to dim electric lamps. This device, often referred to as a “dimmer

switch,” replaced bulky rheostats and autotransformers that were inefficient and unattractive.

Lutron remains a leading innovator and manufacturer of dimmer switches and other lighting

control devices worldwide.

15. Lutron is also an industry leader in innovative, ornamental designs of lighting, fan,

HVAC, and shade controls, including keypads, and protects those designs worldwide with design

patents and registrations, including well over 450 active United States design patents.

16. The ’277 patent, for the ornamental design for a control device, is dated July 14,

2015. The named inventors are Elliot G. Jacoby, Jason C. Killo, and Brad Michael Kreschollek.

17. Lutron Electronics and Lutron Technology bring this action as the exclusive

licensee and owner, respectively, of the ’277 patent with all rights to the patent, including the right

to enforce the patent and to recover past, present, and future damages.

18. The ’277 patent helps to protect the substantial investment—including evaluation

of hundreds of prototypes over several years—that Lutron made in its award-winning, clean and

sleek Palladiom® keypads.

THE SAVANT INFRINGING PRODUCTS

ASCEND Keypads - Accused Instrumentality

19. Savant manufactures, imports, uses, sells, and/or offers to sell control devices—

specifically, lighting control keypads—that infringe Lutron’s ’277 patent. See Exhibit A. These

keypads include Savant’s ASCEND keypads (collectively, the “Accused Ascend Keypads”).

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20. One example of the Accused Ascend Keypads is shown below. It includes metal

buttons and faceplate (different finishes are available) and is juxtaposed with a figure from

Lutron’s ’277 patent and the patent-protected Palladiom keypad design:

Accused Ascend Keypad

’277 Patent
Fig. 2

Lutron Palladiom Keypad

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21. Additional views of an Accused Ascend Keypad and the patented design are shown

below:

Accused Ascend Keypad ’277 Patent

22. With the Accused Ascend Keypads, Savant clearly copied Lutron’s patented

design.

23. The aesthetic equivalence of the Accused Ascend Keypads and the design in the

’277 patent is substantial, particularly in relation to the rest of the industry and in comparison to

the stark difference between Lutron’s patented design and all other keypad designs that had come

before.

24. The Accused Ascend Keypads were observed and photographed on or about

May 22, 2019 at the Savant Booth #2025 at the LightFair International 2019 tradeshow at the

Pennsylvania Convention Center, 1101 Arch St., Philadelphia, PA 19107.

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25. The tradeshow dates were May 19-20, 2019 (for the pre-conference) and May 21-

23, 2019 (open to the public).

26. The Accused Ascend Keypads are wall-mounted control devices for lights,

dimmers, and other things such as blinds and drapes.

27. The Accused Ascend Keypads include a cover housing with a flat front surface

faceplate and low profile rectangular outer periphery.

28. There are buttons (typically four) provided at the front surface of the housing that

are substantially flush with the faceplate.

COUNT 1:
INFRINGEMENT OF U.S. PATENT D734,277

29. Lutron incorporates by reference all paragraphs above and re-alleges them as if

stated here.

30. Savant infringes Lutron’s ’277 design patent both directly and indirectly.

31. This patent is based on Lutron Palladiom® keypads.

32. On information and belief, Savant manufactures and/or imports Accused Ascend

Keypads in/into the United States.

33. On information and belief, Savant uses Accused Ascend Keypads in the United

States.

34. On information and belief, Savant offers Accused Ascend Keypads for sale in the

United States.

35. On information and belief, each of Savant’s making, importing, using, offering to

sell, and/or selling Accused Ascend Keypads in/into the United States constitutes direct

infringement.

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36. On information and belief, Savant has applied the patented design to an article of

manufacture for the purpose of using, selling, and/or exposing for sale an article of manufacture

to which the patented design has been applied, without license of Lutron Technology or Lutron

Electronics, the patent owner and exclusive licensee, respectively.

37. On information and belief, through at least the interactive website at

www.savant.com, installation and user guides, and/or through training and instruction, including

at trade shows, Savant has induced others, such as dealers, distributors and end users, to import,

sell, offer to sell, and/or use the Accused Ascend Keypads and otherwise to directly infringe the

’277 patent.

38. As a competitor of Lutron, Savant is well aware of Lutron’s portfolio of active

patents, particularly patented designs related to Palladiom keypads.

39. Savant has had specific knowledge of the ’277 patent since no later than the date of

filing of this Complaint.

40. Moreover, in light of Savant’s copying of Lutron’s Palladiom 4-button keypad, as

well as its history with Lutron’s keypads, to the extent Savant claims no specific knowledge of the

’277 patent prior to the filing of the Complaint, on information and belief Savant made itself

willfully blind to Lutron’s patent rights.

41. Savant has actively induced conduct constituting direct infringement with

knowledge of the ’277 patent and with knowledge that the conduct would constitute infringement.

Savant’s active inducement constitutes indirect infringement and is ongoing.

42. Savant’s actions are at least objectively reckless as to the risk of infringing a valid

Lutron patent, and this objective risk was either known or should have been known by Savant.

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43. Savant has also indirectly infringed by contributing to the infringement of the ’277

patent. This constitutes ongoing indirect infringement.

44. Savant has made, imported, offered to sell, and/or sold Accused Ascend Keypads

in/into the United States with special features that are specially designed to be used in an infringing

manner and that have no substantial uses other than uses that infringe.

45. Savant’s direct and indirect infringement of the ’277 patent is, has been, and

continues to be willful, intentional, deliberate, and in conscious disregard of Lutron’s patent rights.

46. Lutron has been damaged as a result of Defendant’s infringing conduct alleged

above. Thus, Defendant is liable to Lutron in an amount that adequately compensates it for such

infringements, which, by law, cannot be less than a reasonable royalty, together with interest and

costs as fixed by this Court under 35 U.S.C. § 284, and Defendant’s total profit, if any.

JURY DEMAND

Lutron hereby requests a trial by jury on all issues so triable by right.

PRAYER FOR RELIEF

Lutron requests that the Court find in its favor and against Defendant Savant, and that the

Court grant Lutron the following relief:

a. That Defendant be summoned to appear and answer;

b. Judgment in favor of Lutron that the Defendant has infringed the ’277 patent and that

Defendant’s infringement has been willful;

c. Judgment against Defendant for its total profit in accordance with 35 U.S.C. § 289.

d. A permanent injunction entered against Defendant to prevent any further infringement of

the ’277 patent;

e. An order adjudging that this is an exceptional case under 35 U.S.C. § 285;

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f. Judgment against Defendant for all actual, consequential, special, punitive, exemplary,

increased, and/or statutory damages, including if necessary an accounting of all damages,

pre- and post-judgment interest as allowed by law, and reasonable attorneys’ fees, costs,

and expenses incurred in this action; and

g. Such other and further relief to Lutron as the Court may deem just and proper under the

circumstances.

Of Counsel: /s/ Jeffrey L. Moyer


Jeffrey L. Moyer (#3309)
Scott W. Breedlove Christine D. Haynes (#4697)
Carter Arnett, PLLC Tyler E. Cragg (#6398)
8150 N. Central Expressway, Fifth Floor Richards, Layton & Finger, P.A.
Dallas, Texas 75206 920 North King Street
(214) 550-8188 Wilmington, DE 19801
sbreedlove@carterarnett.com (302) 651-7700
moyer@rlf.com
Perry Saidman cragg@rlf.com
Saidman Designlaw Group, LLC
8601 Georgia Ave., Ste. 603,
Silver Spring, MD 20910
(301) 337-3223 Attorneys for Plaintiffs Lutron Electronics
perry.saidman@designlawgroup.com Co., Inc. and Lutron Technology Company
LLC

Dated: August 26, 2019

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EXHIBIT A
Case 1:19-cv-01570-UNA Document 1-1 Filed 08/26/19 Page 2 of 11 PageID #: 12
USOOD734277S

(12) United States Design Patent (10) Patent No.: US D734.277 S


Jacoby et al. (45) Date of Patent: Jul. 14, 2015
(54) CONTROL DEVICE FOREIGN PATENT DOCUMENTS
(71) Applicant: Lutron Electronics Co., Inc., CA 123790 S 6, 2009
Coopersburg, PA (US)
(72) Inventors: Elliot G. Jacoby, Glenside, PA (US); OTHER PUBLICATIONS
Jason C. Killo, Emmaus, PA (US); Brad Lutron Electronics Co., Inc., Stanza Hotel Guestroom Light Control
Michael Krescholek, Bethlehem, PA Brochure, Feb. 20, 2008, 12 pages.
(US) (Continued)
(73) Assignee: Lutron Electronics Co., Inc.,
Coopersburg, PA (US) Primary Examiner — Selina Sikder
(**) Term: 14 Years (74) Attorney, Agent, or Firm — Saidman Design Law
(21) Appl. No. 29/472,772 Group, LLC
(22) Filed: Nov. 15, 2013 (57)
57 CLAM
3. ...) Cl. ................................................ 13-03 We claim the ornamental design for a control device, as
AV e. we h d described.
USPC ......................................... p13/171. D13/164 snown and describe
(58) Field of Classification Search
USPC ................... D13/162, 164, 171, 177; 174/66; DESCRIPTION
200/5 R, 5 A, 1B, 293,296, 329, 406,
200/513,520, 530, 302.1, 302.2, 314, 315, FIG. 1 is a perspective view of a control device showing our
200/341, 344; 338/198–200; 307/112, 115, new design.
307/125, 139,157 FIG. 2 is a front view thereof.
CPC ............. H01H3/12: H01H 9/02; H01H 9/16; FIG. 3 is a left side view thereof.
H01H 9/18: H01H 9/181; H01H 9/182: FIG. 4 is a right side view thereof.
H01H 13/04; H01H 13/14: H01H 2009/187; FIG. 5 is a top view thereof.
H05B33/0803; H05B33/0863; H05B 37/02; FIG. 6 is a bottom view thereof.
H05B 37/0254; H05B 37/0272; H05B 39/02; FIG. 7 is a perspective view of a control device according to
H05B 39/04; H05B 39/085; H05B39/086: a second embodiment of our new design.
HO5B 39,088 FIG. 8 is a front view thereof.
See application file for complete search history. FIG. 9 is a left side view thereof.
FIG. 10 is a right side view thereof.
(56) References Cited FIG. 11 is a top view thereof; and,
FIG. 12 is a bottom view thereof.
U.S. PATENT DOCUMENTS The rear views form no part of the designandare omitted. The
D262,261 S * 12/1981 Schumacher et al. ....... D13, 164 oblique shade lines shown in the drawings indicate a trans
D450,043 S * 1 1/2001 Mosebrook .................. D13,171 parent or translucent Surface. The portions of the drawings
D453,742 S 2/2002 Butler et al. appearing in broken lines are for environment only and do not
D465,460 S 11/2002 Mayo et al. form part of the claimed design.
6,535,202 B1* 3/2003 Amari et al. .................. 345,173
(Continued) 1 Claim, 8 Drawing Sheets
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US D734,277 S
Page 2

(56) References Cited D714,736 S * 10/2014 O’Donnell ................... D13, 164


D720,306 S * 12/2014 Altonen et al. . D13,177
U.S. PATENT DOCUMENTS 2014/0268630 A1* 9, 2014 Samuels .................... 362/23.03
OTHER PUBLICATIONS
7,361,853 4, 2008 Clegg et al. ............. 200/5A
D573,956 T/2008 Hollner et al. Lightolier, Specification Sheet for iGen DALI 4-Button Scene Con
D631,854 2, 2011 Blair et al.
D633,448 3, 2011 Biery et al. ............. D13,171 troller Model No. DA-WS4SS-7, 2007, 2 pages.
D638,375 5, 2011 Clymer et al. Vantage Controls Inc., Vantage Online Binder, 2004, pp. 1, 3-4, 7.
11, 2011 Jacoby et al. 33-34, 113.
D649,123 Dynalite Intelligent Light Pty Ltd., Light News, Aug. 2005, 8 pages,
D649,124 11, 2011 Jacoby et al. issue 2.
D649,520 11, 2011 Jacoby et al. INNCOM, GS-700 Family Glass Series Switches Sell Sheet, Nov.
D666,978 9, 2012 Felegy, Jr. et al. 2008, 2 pages.
8,289,192 10, 2012 O'Donnell .............. . . . . . . . 341 (22
Lutron Electronics Co., Inc., Faceplate for Pico Wireless Controller
D694,196 11, 2013 Felegy, Jr. et al. Installation Sheet, Mar. 31, 2010, 2 sheets.
D694,716 12, 2013 Felegy, Jr. et al. Basalte BVBA, Sentido KNX v3.1 Manual, 2012, pp. 1-3.
D706,731 6, 2014 Altonen et al. Bticino Spa, Matix Brochure, May 2009, 16 pages.
D706,732 6, 2014 Altonen et al. U.S. Appl. No. 29/481,494, filed Feb. 6, 2014, Jacoby et al.
D707,191 6, 2014 Altonen et al.
D714,234 9, 2014 Altonen et al. D13, 177 * cited by examiner
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U.S. Patent Jul. 14, 2015 Sheet 1 of 8 US D734.277 S

Fig. 1
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U.S. Patent Jul. 14, 2015 Sheet 2 of 8 US D734.277 S

Fig. 2
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U.S. Patent Jul. 14, 2015 Sheet 3 of 8 US D734.277 S

|~~~

Fig. 3 Fig. 4
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U.S. Patent Jul. 14, 2015 Sheet 4 of 8 US D734.277 S

a re- or- or- or- or- or re- or- or- or- or- or- or- or

ises o os o os o os o os o os o os o
Case 1:19-cv-01570-UNA Document 1-1 Filed 08/26/19 Page 8 of 11 PageID #: 18

U.S. Patent Jul. 14, 2015 Sheet 5 of 8 US D734.277 S


Case 1:19-cv-01570-UNA Document 1-1 Filed 08/26/19 Page 9 of 11 PageID #: 19

U.S. Patent Jul. 14, 2015 Sheet 6 of 8 US D734.277 S

Fig. 8
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U.S. Patent Jul. 14, 2015 Sheet 7 of 8 US D734.277 S

••?!• •

Fig. 9 Fig. 10
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U.S. Patent Jul. 14, 2015 Sheet 8 of 8 US D734.277 S


Case 1:19-cv-01570-UNA Document 1-2 Filed 08/26/19 Page 1 of 1 PageID #: 22
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