August 2nd, 2015 by Eric Lane No comments »

 

 

Green Patent Blog is on vacation.



 

 

 

Proposed Eco-mark Succumbs to Genericness as SUSTAINABLE WATER Proves Unsustainable

July 27th, 2015 by Eric Lane No comments »

I’ve regularly reported on the struggles faced by clean tech manufacturers and service providers seeking to protect and enforce descriptive eco-marks (including my own marks).

One can’t register or otherwise protect a mark that is merely descriptive (i.e., it immediately conveys to consumers the nature of the goods or services) because that would restrict competitors from conveying information about their goods or services.

Mere descriptiveness has killed many eco-marks over the last several years, such as ECODIESEL, MOTIONPOWER, SOLARWINDOW, and HYBRID GREEN.

However, a descriptive mark can be protected if the applicant demonstrates that the mark has acquired distinctiveness, or secondary meaning, i.e., the mark has become sufficiently distinctive through use so consumers have come to recognize it as a source identifier for the goods or services.  Such a mark is not merely descriptive.

Generic terms, on the other hand, can never be protected.  There is no such thing as a generic mark; a generic term cannot function as a trademark.

A recent decision of the Trademark Trial and Appeal Board (Board) of the U.S. Patent and Trademark Office (USPTO) highlights the genericness analysis in the context of green technology.

In re Aquei Technologies LLC involves Aquei’s application to register the proposed mark SUSTAINABLE WATER for “sustainable on-site water recycling and wastewater treatment services.”  The trademark examining attorney in the USPTO refused registration on the ground that the mark is generic.

Aquei appealed, and the Board affirmed.  To determine whether a term is generic requires a two-step inquiry:  first, the Board looks at what is the genus of goods or services at issue; second, the Board asks whether the term sought to be registered is understood by the relevant public to refer to that genus of goods and services.

The Board found the genus of services at issue was accurately stated by Aquei’s recitation of services, i.e., “sustainable on-site water recycling and wastewater treatment services.”

Based on Aquei’s web site describing its business as “water reclamation and reuse” to make “water” supplies “sustainable,” articles such as one about “The Science of Sustainable Water,” and other players’ in Aquei’s field use of the term “Sustainable Water” in their trade names including an industry alliance called the Sustainable Water Infrastructure Coalition, the Board found the term names the central focus or key aspect of Aquei’s services:

The evidence reveals that the term “Sustainable Water” directly names the most important or central aspect or purpose of Applicant’s services, which are treating, recycling and reusing water.

The Board went on to find that the components “SUSTAINABLE” and “WATER” are independently generic and remain generic when combined:

 “Sustainable Water” is nothing more than the sum of its two generic parts and “the entire formulation does not add any meaning to the otherwise generic mark.”  The generic components produce a generic composite and signify nothing more than services focused ultimately on the production of “sustainable water” as that term is ordinarily and commonly used by the public and others in the industry.

Accordingly, the Board held SUSTAINABLE WATER to be generic and unprotectable:

Hence, the term sought to be registered is understood by the relevant public primarily to refer to that genus of services, the term is generic, and should be freely available for use by competitors.

Clean Tech in Court: Green Patent Complaint Update

July 21st, 2015 by Eric Lane No comments »

Several new green patent complaints were filed in May and June in the areas of LEDs, smart grid, and solar power including solar mounting systems and solar powered lanterns.

 

LEDs

Koninklijke Philips N.V. v. iGuzzini Lighting USA, Ltd. et al.

On May 22, 2015, Philips sued iGuzzini for infringement of five patents relating to LEDs and LED lighting devices.  The complaint was filed in the U.S. District Court for the District of New York.  The patents-in-suit are:

U.S. Patent No. 6,094,014, entitled “Circuit arrangement, and signaling light provided with the circuit arrangement”

U.S. Patent No. 6,250,774, entitled “Luminaire”

U.S. Patent No. 6,577,512, entitled “Power supply for LEDs”

U.S. Patent No. 6,586,890, entitled “LED driver circuit with PWM output”

U.S. Patent No. 7,802,902, entitled “LED lighting fixtures”

The accused products are iGuzzini’s Laser Blade, Primopiano-LED, Woody LED, and Palco LED lines.

 

Lynk Labs, Inc. v. Juno Lighting LLC et al.

Illinois-based Lynk Labs recently sued Juno Lighting for patent infringement, correction of inventorship, and breach of contract.

Filed in U.S. District Court for the Northern District of Illinois, the complaint alleges infringement of U.S. Patent Nos. 8,531,118, entitled “AC light emitting diode and AC LED drive methods and apparatus”(‘118 Patent) and 8,841,855, entitled “LED circuits and assemblies” (‘855 Patent).

Lynk Labs also has requested that the court correct the inventorship of Juno’s U.S. Patent No. 7,909,499, entitled “LED track lighting module” and U.S. Design Patent No. D579,144, entitled “L.E.D. light source cover” to include one or more officers or employees of Lynk Labs as co-inventors.

Finally, Lynk Labs alleges that Juno breached a 2006 Non-disclosure Agreement between the parties.

 

Smart Grid

Endeavor MeshTech, Inc. v. Nexgrid, LLC

Endeavor MeshTech, Inc. v. Freewave Technologies, Inc.

Endeavor MeshTech, Inc. v. Zenner Performance Meters, Inc.

Endeavor MeshTech (a wholly-owned subsidiary of patent monetization firm Endeavor IP) continued its patent enforcement campaign, filing three more lawsuits in May and June.

The first was filed against Nexgrid in federal court in Richmond, Virginia on May 5, 2015 (Endeavor Meshtech v. Nexgrid), the second against Freewave Technologies in the U.S. District Court for the District of Colorado on June 16, 2015 (Endeavor Meshtech v. Freewave), and the third against Zenner Performance Meters in federal court in Marshall, Texas on June 23, 2015 (Endeavor Meshtech v. Zenner).

The first two complaints accuse each Nexgrid and Freewave, respectively, of infringing three patents in a family – U.S. Patent Nos. 7,379,981 (‘981 Patent),  8,700,749 (‘749 Patent), and 8,855,019 (‘019 Patent), each entitled “Wireless communication enabled meter and network.”  The complaint against Zenner asserts only the ‘749 and ‘019 Patents.

The patents-in-suit relate to a self-configuring wireless network including a number of vnodes and VGATES.

The accused products and services are Nexgrid products sold under the Nexgrid Technology Solutions brand name, Freewave’s Comprehensive High-Speed Wireless M2M Communications Solution sold under the WavePoint brand name, and Zenner’s Stealth and MeshPlus branded products and services.

 

Solar Power

D Three Enterprises, LLC v. Sunmodo Corporation

D Three Enterprises, LLC v. Rillito River Solar LLC

On June 2, 2015 D Three filed two patent infringement suits in the U.S. District Court for the District of Colorado.

In the first (D Three Enterprises v. Sunmodo), D Three accuses Sunmodo of infringing U.S. Patent Nos. 8,689,517 (‘517 Patent) and 8,707,655 (‘655 Patent), both relating to involving sealing assemblies for roof-mounted solar panels.

The ‘517 and ‘655 Patents are related patents, each entitled “Roof mount sealing assembly” and directed to roof mount sealing assemblies that allow a user to mount rails for solar panels, signs, satellite dish or any other desired item on the roof and have the mounting location sealed against water.

The accused Sunmodo products are the EZ Mount assembly with Standoff for Shingle Roofs and the EZ Mount L-Foot Kit for Shingle Roofs.

The D Three complaint against Rillito asserts only the ‘517 Patent and alleges that Rillito’s (dba EcoFasten Solar) QuikFoot Roof Mount System with P-3-CSK Compression Post infringes the patent.

 

Allsop, Inc. v. Jetmax Ltd.

Allsop, a manufacturer of various consumer products including collapsible solar power lanterns, sued Hong Kong-based Jetmax for infringement of U.S. Patent No. 8,657,461 (‘461 Patent).

The ‘461 Patent is entitled “Solar-powered collapsible lighting apparatus” and directed to a solar-powered lighting apparatus having a light transmissible spherical shade coupled to a housing that receives a solar cell, a battery and at least a portion of a lighting element assembly.

Filed May 29, 2015 in federal court in Seattle, Washington, the complaint alleges that Jetmax’s Nylon Solar Hanging Lantern infringes the ‘461 Patent.

 

Defendant Pleads Guilty in RIN Fraud Greenwashing Case

July 13th, 2015 by Eric Lane No comments »

A previous post discussed a federal indictment of an individual for allegedly selling fraudulent renewable identification numbers (RINs).

The indictment alleged that an individual using the name Philip Joseph Rivkin controlled and operated Green Diesel LLC and claimed that the company produced millions of gallons of biodiesel at its Houston facility then generated and sold about 45 million RINs based on the claim.

However, according to the indictment, Green Diesel did not actually produce any biodiesel at its facility, and the defendant allegedly made millions of dollars selling the fraudulent RINs.

Recently, Rivkin, a.k.a. Felipe Poitan Arriaga, pleaded guilty to making a false statement under the Clean Air Act and to mail fraud for his role in the scheme, which included attempts to defraud the U.S. Environmental Protection Agency.

In the plea agreement, he admitted that he falsely generated renewable fuel credits between July 2010 and July 2011 and sold them to oil companies and brokers, generating over $29 million.

Under the plea deal, Rivkin faces more than 10 years in prison and will be responsible for $51 million in restitution to reimburse victims of the scheme.

Because the fraudulent activity in this case did not involve individual green consumers and consumer products such as water bottles, cleaning supplies, or hybrid vehicles, this would not typically be thought of as a greenwashing case.  But the fraudulent activity does represent a serious instance of greenwashing.

The fraud and resulting damage are recognizable when we view the putative RIN purchasers as green consumers, albeit commercial consumers instead of individuals, falling victim to false representations about the validity of renewable energy-based financial products.

You can read more about the guilty plea at Biofuels Digest here and at Biodiesel Magazine here.

Vinson Conlan’s LED Patent Report: What’s at Stake in Cree v. Feit?

July 7th, 2015 by Vinson Conlan No comments »

A previous post reported on the LED patent lawsuit between North Carolina LED manufacturer Cree and Feit Electric Company in which Cree has alleged infringement of a number of utility and design patents.

There are several patents involved with this case but none as far reaching as U.S. Patent No. 8,596,819 (‘819 Patent). Let’s look at the first claim:

1.  A lighting device comprising at least one light emitting diode, said lighting device, when supplied with electricity of a first wattage, emitting output light with a wall plug efficiency of at least 60 lumens per watt of said electricity.

This claim covers all LED devices with an efficacy over 60 lumens per watt with at least one LED.

The latest Energy Star luminaire requirements (taking effect in 2016) for all luminaire categories, but track need to meet or exceed 60 LPW. Most large retailers have relied upon Energy Star to help qualify products for sale to residential customers. In some cases, products without Energy Star will not be considered for sale in retail outlets.

Energy Star is required to qualify for many utility rebate programs. Energy Star is a Department of Energy program and has been made aware of the ‘819 Patent. They were made aware of this patent issue before the latest luminaire requirements were finalized.

Those who honor the ‘819 Patent would be denied rebate dollars and the potential to sell into some large volume accounts because meeting Energy Star requirements would force them to infringe the patent.

Energy Star has the best interest of the country in mind, but one has to question their decisions when their policies will clearly steer rebates dollars and retail business directly towards a single patent holder.

This case is about more than one company against another, it is the test of a patent that could be used successfully to deny businesses the opportunity to get an Energy Star listing and qualify for rebate dollars.

For those looking to sell into the commercial channel and get added to the Design Lights Consortium (DLC) qualified product list, they will only qualify for display case lighting and directional interior categories. All lamps would infringe as well. Like Energy Star, DLC qualified products are eligible for rebates.

Another Cree patent in this lawsuit is U.S. Patent No. 8,628,214 (‘214 Patent).  This patent is very similar to the ‘819 Patent. The first claim of the ‘214 Patent reads:

 1.  A lighting device comprising:a first string of solid state light emitters in series, the first string comprising at least two solid state light emitters,

a second string of solid state light emitters in series, the second string comprising at least two solid state light emitters,

a third string of solid state light emitters in series, the third string comprising at least two solid state light emitters,

the lighting device, when supplied with electricity of a first wattage, emitting output light with a wall plug efficiency of at least 60 lumens per watt of the electricity.”

Perhaps it is time for those who support Energy Star and DLC to consider a revised set of efficacy standards that promote free trade and offer their customers a wider range of options. The following organizations have influence, and as objective third parties can help all interested parties find solutions that will help save energy without infringing these patents.

DSIRE Database of State Incentives for Renewables and Efficiency:  http://www.dsireusa.org/

ACEEE (American Council for an Energy Efficient Economy):  http://aceee.org/

AESP Association of Energy Service Professionals:  http://www.aesp.org/

CEE (Consortium for Energy Efficiency):  http://www.cee1.org/

ESource:  http://www.esource.com

 

Vinson Conlan has been developing light fixtures for nearly 30 years and has spent the last 9 years specializing in LED products. He has 8 US patents and has a broad range of experience working for family owned businesses as well as Fortune 100 companies. Vinson currently heads up product development for a leading company in the solid state lighting industry.

Inside An Eco-mark Application: Saving GREEN PATENT LAW from the Depths of Descriptiveness

July 1st, 2015 by Eric Lane No comments »

In a series of posts published several years ago (see, e.g., here and here), I documented all the gory details of my attempt to register the GREEN PATENT BLOG service mark.

Despite two rejections (see here and here) on the ground that the mark was merely descriptive of the blogging services, it was ultimately registered (thanks to many of my readers) (see here) based on an evidentiary showing of acquired distinctiveness.

Now that I run my own practice under the GREEN PATENT LAW service mark, it’s de ja vu all over again.

In June 2014, I filed an application with the U.S. Patent and Trademark Office (USPTO) to register the GREEN PATENT LAW mark for “legal services.”

As expected, the application was rejected for being merely descriptive (a mark that immediately conveys to consumers the nature of the goods or services is merely descriptive and can’t be registered because that would restrict competitors from conveying information about their goods or services).

To support the rejection, the Examining Attorney cited my web site, which says Green Patent Law is a “law firm” providing “patent” and trademark law services to businesses in various technology areas, including “green technologies.”

When facing a rejection for mere descriptiveness, there are two basic response strategies.  If there is room to argue that consumers would not immediately perceive some characteristic of the goods or services from the mark, but instead would need to think about it to link the mark and the goods/services, then the applicant can argue the mark is suggestive.

If there is no credible suggestiveness argument, the applicant has to show, through one or more avenues, that the mark has acquired distinctiveness, or secondary meaning.  Acquired distinctiveness is a trademark law concept which means that the mark, though it may not be inherently distinctive enough for trademark protection, has become sufficiently distinctive through use so that consumers have come to recognize it as a source identifier for the goods or services.

The first tactic, if the mark has been in use for at least five years, is to rely on a trademark law presumption of acquired distinctiveness.

A second possibility is the applicant can marshal evidence to demonstrate acquired distinctiveness.  This can take the form of direct evidence consisting of statements from consumers saying they identify the applicant as the source of the goods or services and/or indirect evidence such as advertising and media mentions linking the mark with the goods or services.

A third approach, available in limited circumstances, is to argue acquired distinctiveness in whole or in part based on a prior registered trademark already found to have acquired distinctiveness, essentially piggy-backing on the prior registration.  This was how I responded to the Office Action making the initial rejection for GREEN PATENT LAW.

In my response, I argued acquired distinctiveness in part based on the prior registration for GREEN PATENT BLOG.  In other words, my response contended that the GREEN PATENT portion of the GREEN PATENT LAW mark has secondary meaning because GREEN PATENT BLOG has secondary meaning, they share common words, and the services – legal services and legal blogging – are related.

That response was unsuccessful.  In a second Office Action, the Examining Attorney said the legal services and blogging services were not sufficiently similar and required additional evidence of acquired distinctiveness.

So I’m now left with gathering evidence of acquired distinctiveness.  Stay tuned.

Class Action Alleges Ford Fusion Fuel Figure Fudge

June 23rd, 2015 by Eric Lane No comments »

In a recent lawsuit, a Ford Fusion owner has accused the automaker of misrepresenting the fuel efficiency of the hybrid vehicle and distributing a software update that displays false mileage figures.

In the proposed class action complaint filed in California Superior Court in Los Angeles, named plaintiff Dave DeLuca says that, not long after purchasing the vehicle, he realized its actual performance didn’t match the advertised performance.

Mr. DeLuca tested the car under “optimal conditions” as described by a Ford technician.  More particularly, he tested the car with the windows up, the air conditioner and stereo turned off, and driving at a speed of 62 miles per hour or less, and the car allegedly underperformed.

When Mr. DeLuca took the car into the dealership, the Ford technician tested the car under the same conditions, got the same results, but told Mr. DeLuca nothing could be done to fix the car because it wasn’t broken.

Up to this point, the allegations are pretty common for this type of lawsuit.  Most greenwashing cases against automakers include claims that the hybrid or electric vehicles fail to achieve the advertised fuel efficiency (see, e.g., previous posts here and here).

What’s new here is the software piece.  The DeLuca complaint also alleges that Ford issued a software update for the Fusion Hybrid, claiming the update would increase performance and mileage.  After the dealer installed the update in his car, Mr. DeLuca tested its performance again.

On a road trip to Sin City (Viva Las Vegas!), he drove the car under optimal conditions again and observed that the car’s monitor was indeed displaying better mileage and less gas usage.  But Mr DeLuca alleges, that was just smoke and mirrors:

[W]hen Mr. DeLuca filled his gas tank at a gas station, he realized the vehicle’s software relayed inaccurate mileage and use of gasoline.

The mileage had not really increased, according the complaint:

[A]lthough Ford’s software update displays a higher mileage, the vehicle’s mileage has not increased.

Mr. DeLuca performed one final test, doing comparative driving runs with gas-only Ford Fusion.  He found that the gas-only Fusion displayed accurate numbers while Fusion Hybrid displayed inaccurate figures.

It will be interesting to watch this case and see what, if anything, we learn about the alleged software greenwash.

Ford EV Patents Open, Not Free; You Can License For a Fee

June 16th, 2015 by Eric Lane No comments »

Once is an isolated incident, twice could be a coincidence, but three times – that may make a trend.  Following Tesla’s big patent giveaway about a year ago and Toyota’s fuel cell vehicle patent limited license offer a few months ago, Ford recently announced that it has “opened” its electric vehicle patent portfolio.

Don’t get too excited, though.  This one is fundamentally different from the prior patent pledges.  Ford is not donating its patents or even offering limited-time royalty-free licenses to the patents.

Rather, Ford is offering the patents for license “for a fee” as the company’s press release explains.  In view of the other automakers’ EV freebies, Ford issued a brief statement in defense of it’s for-profit licensing scheme (reproduced here from a Financial Times article):

Defending the decision to charge for the patents, the company said “We’re proud of the work that we do.”  It added: “From the research we’ve conducted already, we feel that licensing is appropriate.”

Not that there’s anything wrong with that.  To the contrary, companies should generate revenue from their R&D, their innovation, and their patents.

But the headline of the announcement obscures the fact that it’s a for-profit licensing venture (“Ford Opens Portfolio of Patented Technologies to Competitors to Accelerate Industry-Wide Electrified Vehicle Development”).

In intellectual property, the word “open” signals free use or public domain (e.g., open source), and the headline is particularly misleading in view of the recent Tesla and Toyota royalty-free patent license moves in this field.  Note Toyota’s press release also used “open” (“Toyota Opens the Door and Invites the Industry to the Hydrogen Future”).

Of course, reasonable people can differ in opinion as to whether the developing EV industry is better served by truly open patent portfolios or revenue generating licensing opportunities.  But either way, the patent holders should not mislead and should get the messaging right.

By the way, this trend of pledging patents appears to be a hot topic:  it’s the subject of a recent article by Professor Jorge Contreras called Patent Pledges and a conference held just yesterday at American University.

 

Automakers Make Eco-mark Progress

June 9th, 2015 by Eric Lane No comments »

Two major automakers have made progress recently in protecting their present and future brands.

In previous posts (here and here), I reported on GM’s U.S. Trademark Application Nos. 86357513 and 86357523 for BOLT and CHEVROLET BOLT, respectively, for “motor land vehicles, namely, automobiles” (BOLT Applications).

The applications ran into some hitches when the U.S. Patent and Trademark Office (USPTO) initially refused registration based on U.S. Trademark Registration No. 4,429,759, owned by Yamaha, for the mark BOLT for “Motorcycles and structural parts therefor, excluding wheels.”  According to the trademark examining attorney, there was a likelihood of consumer confusion because the marks are the same and goods are similar.

GM overcame this rejection by arguing differences between the goods and channels of trade (e.g., motorcycles and automobiles are typically sold in different dealerships).  GM also entered into and submitted to the USPTO a Consent Agreement whereby both parties consented to registration by the other of the BOLT mark for their respective goods.

However, the trademark examining attorney also suspended GM’s BOLT Applications based on provisional refusals to register the marks based on prior filed U.S. Trademark Application Serial Nos. 86108379 and 86108374 for the BOLT CUSTOM TRUCKS AND MANUFACTURING word and design marks for “truck parts, namely, a premium-outfitted truck cab.

GM was able to overcome these provisional rejections by agreeing to amend the identification of goods in their BOLT Applications to motor land vehicles, namely, automobiles in the nature of cars.”

Now both applications are moving forward toward publication and registration, assuming no third parties oppose registration.

 

Toyota recently prevailed in an opposition proceeding against HongKong WillRaise Integrated Circuit Company (HWICC), which had filed U.S. Application No. 86/357,165 for PRIUS for chemical flavorings for tobacco and various smoking paraphernalia (‘165 Application).

Toyota filed a Notice of Opposition in December of 2014 before the USPTO Trademark Trial and Appeal Board (Board) opposing registration of the ‘165 Application.  Recently, HWICC withdrew the ‘165 Application (HWICC Withdrawal), and because the withdrawal did not include the consent of all the parties, the Board subsequently entered judgment against HWICC.

Guest Post: Vinson Conlan’s LED Patent Update

June 2nd, 2015 by Vinson Conlan No comments »

Lighting Science Group expanded their intellectual property for their LED Disc Light (Glimpse) with three recent patents.

The trio of patents cover LED light fixtures that are low profile and designed to cover recessed light fixtures and junction boxes. Most of these fixtures look like recessed trims with a lamp or a recessed light fixture trim with a lens.

Their latest patent is written to cover fixtures that are designed to cover a recessed light fixture housing and a junction box with a driver located between the light fixture and the junction box or recessed housing. The ratio of height to diameter is not included in the first claim as it was on the original patent, U.S. Patent No. 8,201,968 (‘968 Patent).

The combination of patents covers many fixture types currently manufactured in North America. Examples of their products can be found here.

The second patent, U.S. Patent No. 8,672,518, entitled “Low profile light and accessory kit for the same”, issued March 18, 2014.

U.S. Patent No. 8,967,844, entitled “Low profile light and accessory kit for the same” (‘844 Patent), issued on March 3, 2015. This is the third of the patents issued that provides coverage for their disc light LED product.

All of the patents claim the benefit of U.S. Provisional Application Ser. No. 61/248,665, filed Oct. 5, 2009.

The following description from the ‘968 Patent has been separated into two claims in the ‘844 Patent:

wherein the heat spreader, the heat sink and the outer optic, in combination, have an overall height H and an overall outside dimension D such that the ratio of H/D is equal to or less than 0.25; wherein the combination defined by the heat spreader, the heat sink and the outer optic, is so dimensioned as to: cover an opening defined by a nominally sized four-inch can light fixture; and, cover an opening defined by a nominally sized four-inch electrical junction box.

In place of the above, claim 1 in the ‘844 Patent adds the following:

…and a power conditioner disposed and configured to receive AC voltage from an electrical supply and to provide DC voltage for the plurality of LEDs; wherein the power conditioner is disposed, configured and sized to fit at least partially within an interior space of: a nominally sized can light fixture; and, a nominally sized electrical junction box.

 

Another recent patent of interest

Copper Technologies (see Halo brand products) was granted U.S. Patent No. 9,010,956,entitled “LED module with on-board reflector-baffle-trim ring” (‘956 Patent). Claim 1 reads as follows:

A light module, comprising:

a heat sink comprising an internal surface surrounding a heat sink cavity formed therein, the internal surface comprising:

a mounting region; and

a reflector region extending from the perimeter of the mounting region to a distal end;

one or more light sources coupled to the mounting region within the heat sink cavity; and

a plurality of mounting pads disposed circumferentially around a portion of the heat sink to separably couple the light module to a housing having a five inch diameter cavity or a housing having a six inch diameter cavity, each mounting pad comprising:

a first receiving hole; and

a second receiving hole,

wherein either the first receiving hole or the second receiving hole is coupled to a torsion spring,

wherein when the torsion spring is coupled to the first receiving hole, the light module is coupled to the housing having the five inch diameter cavity, and

wherein when the torsion spring is coupled to the second receiving hole, the light module is coupled to the housing having the six inch diameter cavity.

One of the embodiments, which is on the shelf at a popular retail DIY chain, can be seen here.

The ‘956 Patent protects their current low cost LED trim; many low cost trims use a similar construction.

 

Vinson Conlan has been developing light fixtures for nearly 30 years and has spent the last 9 years specializing in LED products. He has 8 US patents and has a broad range of experience working for family owned businesses as well as Fortune 100 companies. Vinson currently heads up product development for a leading company in the solid state lighting industry.