Jiaxing Super Lighting Elec. Appliance, Co., v. CH Lighting Tech. Co
Authored by: Jeremy J. Justrowsky
In a significant patent dispute over LED tube lamp technology, the Federal Circuit has sent the case of Jiaxing Super Lighting Electric Appliance Co., Ltd. v. CH Lighting Technology Co., Ltd. back for a new trial on the validity of two patents and the calculation of damages. The case centers on three patents: U.S. Patent Nos. 10,295,125 and 10,352,540 (the “tube patents”), which cover structural improvements in LED tube lamps, and U.S. Patent No. 9,939,140, which relates to a shock-prevention system for such lamps.
CH Lighting had conceded infringement of the tube patents but challenged their validity, arguing that similar products were on sale before the patents’ effective filing dates—a legal hurdle known as the “on-sale bar.” However, the district court blocked CH Lighting from presenting certain evidence, including documents and testimony that could have proven these prior sales. The Federal Circuit found this exclusion to be an abuse of discretion, noting that there was no rule requiring advance identification of witnesses to authenticate documents, and that the excluded evidence was directly relevant to the on-sale bar defense.
While the court upheld the jury’s verdict that the ‘140 patent was valid and infringed, it found that the damages award—nearly $14 million—could not stand because it was based on all three patents without separating the amounts attributable to each. The court also instructed the district court to more closely scrutinize the reliability of the damages expert’s testimony, especially regarding how damages should be apportioned among multiple patents.
As a result, the Federal Circuit affirmed the finding of infringement and validity for the ‘140 patent, but reversed the lower court’s ruling on the tube patents’ validity and vacated the damages award. The case is now headed back to the district court for a new trial on whether the tube patents are invalid and for a new assessment of damages.