Professional Documents
Culture Documents
10
STETINA BRUNDA GARRED & BRUCKER
12
Attorneys for Plaintiff
(949) 855-1246; FACSIMILE:
13 HGCI, INC.
14 UNITED STATES DISTRICT COURT
15 CENTRAL DISTRICT OF CALIFORNIA
16
HGCI, INC., a Nevada corporation, Case No.
17
PHONE:
Plaintiff, COMPLAINT
18
v. DEMAND FOR JURY TRIAL
19
20 LUXX LIGHTING, INC., a California
corporation,
21
Defendant.
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-1-
COMPLAINT
Case 5:19-cv-00570 Document 1 Filed 03/29/19 Page 2 of 11 Page ID #:2
1 HGCI, Inc. ("HGCI"), for its complaint against Defendant Luxx Lighting, Inc.
2 ("Luxx Lighting"), states as follows:
3 SUMMARY AND NATURE OF THE ACTION
4 1. This is an action for patent infringement. HGCI owns utility patents
5 directed to unique horticulture light fixtures, and HGCI also owns design patents for the
6 ornamental designs of such fixtures. Defendant Luxx Lighting sells light fixtures that
7 are covered by HGCI's patents. HGCI files this lawsuit to put an end to Defendant
8 Luxx Lighting's infringement and to recover damages resulting from Defendant Luxx
9 Lighting's misconduct.
(949) 855-6371
10 PARTIES
STETINA BRUNDA GARRED & BRUCKER
12 business in Las Vegas, NV. HGCI is an affiliate of The Scotts Company, LLC, an Ohio
(949) 855-1246; FACSIMILE:
18 4. This action arises under the patent laws of the United States, Title 35 of the
19 United States Code, 35 U.S.C. § 271 et seq. Subject matter jurisdiction of this Court is
20 conferred by 28 U.S.C. §§ 1331 and 1338.
21 5. Venue in this judicial district is proper under 28 U.S.C. § 1400(b) because
22 Defendant Luxx Lighting is incorporated in California and this judicial district is where
23 Defendant Luxx Lighting has committed acts of infringement and has a regular and
24 established place of business.
25 6. This Court has personal jurisdiction over Defendant Luxx Lighting at least
26 because it is a California corporation.
27 PATENTS-IN-SUIT
28 7. United States Patent No. 7,524,090 ("the '090 patent") is titled
-2-
COMPLAINT
Case 5:19-cv-00570 Document 1 Filed 03/29/19 Page 3 of 11 Page ID #:3
1 "Horticulture Light fixture having integrated lamp and ballast" and issued on April 28,
2 2009. Attached as Exhibit 1 is a copy of the '090 patent.
3 8. United States Patent No. D740,486 ("the D'486 patent") is titled "Light
4 fixture" and issued on October 6, 2015. Attached as Exhibit 2 is a copy of the D'486
5 patent.
6 9. United States Patent No. D771,301 ("the D'301 patent") is titled
7 "Horticulture grow light fixture" and issued on November 8, 2016. Attached as Exhibit
8 3 is a copy of the D'301 patent.
9 10. HGCI is the owner of the '090, D'486, and D'301 patents by assignment.
(949) 855-6371
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-3-
COMPLAINT
Case 5:19-cv-00570 Document 1 Filed 03/29/19 Page 4 of 11 Page ID #:4
10
STETINA BRUNDA GARRED & BRUCKER
11
ALISO VIEJO, CALIFORNIA 92656
75 ENTERPRISE, SUITE 250
12
(949) 855-1246; FACSIMILE:
13
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PHONE:
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COMPLAINT
Case 5:19-cv-00570 Document 1 Filed 03/29/19 Page 5 of 11 Page ID #:5
1 17. A side-by-side comparison of select figures from the D'301 patent and
2 Defendant Luxx Lighting's Infringing Products is likewise shown in the table below:
3 D'301 Patent Luxx Lighting's Infringing Products
4
5
6
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9
(949) 855-6371
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STETINA BRUNDA GARRED & BRUCKER
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ALISO VIEJO, CALIFORNIA 92656
75 ENTERPRISE, SUITE 250
12
(949) 855-1246; FACSIMILE:
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19 18. The design of the Infringing Products and the designs of the D'486 and
20 D'301 patents are so similar that it is highly unlikely that Defendant Luxx Lighting
21 designed the Infringing Products without prior knowledge of the designs set forth in the
22 D'486 and D'301 patents.
23 19. Indeed, customers have noticed the similarity between Defendant Luxx
24 Lighting's Infringing Products and HGCI's products. For example, as shown in the
25 below Instagram post (https://www.instagram.com/p/BfhPfYAnexf/), a user stated:
26 "The [Defendant Luxx Lighting] reflector looks like you got the design from sun
27 systems" ("Sun Systems" is part of HGCI):
28
-5-
COMPLAINT
Case 5:19-cv-00570 Document 1 Filed 03/29/19 Page 6 of 11 Page ID #:6
Case 5:19-cv-00570 Document 1 Filed 03/29/19 Page 7 of 11 Page ID #:7
1 the Internet.
2
FIRST CLAIM FOR RELIEF
3 (Patent Infringement—'090 Patent)
4 25. HGCI repeats and incorporates by reference the allegations set forth in the
5 foregoing paragraphs.
6 26. Defendant Luxx Lighting infringed one or more claims of the '090 patent,
7 including claim 1, in violation of 35 U.S.C. § 271, at least by making, offering to sell,
8 selling, and using within the United States the "Luxx DE 1000" grow light fixture.
9 27. For example, claim 1 of the '090 patent recites:
(949) 855-6371
10 The method for integrating a lamp ballast within a grow light fixture comprising
STETINA BRUNDA GARRED & BRUCKER
-7-
COMPLAINT
Case 5:19-cv-00570 Document 1 Filed 03/29/19 Page 8 of 11 Page ID #:8
Case 5:19-cv-00570 Document 1 Filed 03/29/19 Page 9 of 11 Page ID #:9
10 ornamental features set forth in the D'486 patent such that an ordinary observer, giving
STETINA BRUNDA GARRED & BRUCKER
11 such attention as a purchaser usually gives, would find HGCI's patented design and
ALISO VIEJO, CALIFORNIA 92656
75 ENTERPRISE, SUITE 250
12 Defendant Luxx Lighting's designs to be substantially the same, and the resemblance is
(949) 855-1246; FACSIMILE:
13 such as to deceive such an observer, inducing him to purchase one supposing it be the
14 other.
15 36. By at least the foregoing acts, Defendant Luxx Lighting has infringed the
16 D'486 patent.
17 37. HGCI owned the D'486 patent through the period of the infringing acts of
PHONE:
18 Defendant Luxx Lighting, and HGCI still owns the D'486 patent.
19 38. HGCI has been and continues to be damaged and otherwise harmed by
20 Defendant Luxx Lighting's infringement, and HGCI will be irreparably harmed unless
21 Defendant Luxx Lighting's infringing activities are enjoined.
22
THIRD CLAIM FOR RELIEF
23 (Patent Infringement—D'301 Patent)
24 39. HGCI repeats and incorporates by reference the allegations set forth in the
25 foregoing paragraphs.
26 40. Defendant Luxx Lighting, without authorization from HGCI, has
27 distributed, advertised, promoted, offered for sale, and sold light fixtures, the designs of
28 which are substantially the same as the design set forth in the D'301 patent.
-9-
COMPLAINT
Case 5:19-cv-00570 Document 1 Filed 03/29/19 Page 10 of 11 Page ID #:10
1 41. Defendant Luxx Lighting's infringing light fixtures appropriate the novel
2 ornamental features set forth in the D'301 patent such that an ordinary observer, giving
3 such attention as a purchaser usually gives, would find HGCI's patented design and
4 Defendant Luxx Lighting's designs to be substantially the same, and the resemblance is
5 such as to deceive such an observer, inducing him to purchase one supposing it be the
6 other.
7 42. By at least the foregoing acts, Defendant Luxx Lighting has infringed the
8 D'301 patent.
9 43. HGCI owned the D'301 patent through the period of the infringing acts of
(949) 855-6371
10 Defendant Luxx Lighting, and HGCI still owns the D'301 patent.
STETINA BRUNDA GARRED & BRUCKER
11 44. HGCI has been and continues to be damaged and otherwise harmed by
ALISO VIEJO, CALIFORNIA 92656
75 ENTERPRISE, SUITE 250
12 Defendant Luxx Lighting's infringement, and HGCI will be irreparably harmed unless
(949) 855-1246; FACSIMILE:
-10-
COMPLAINT
Case 5:19-cv-00570 Document 1 Filed 03/29/19 Page 11 of 11 Page ID #:11
10 William J. Brucker
STETINA BRUNDA GARRED & BRUCKER
HGCI, INC.
75 ENTERPRISE, SUITE 250
12
(949) 855-1246; FACSIMILE:
13
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-11-
COMPLAINT
Case 5:19-cv-00570 Document 1-1 Filed 03/29/19 Page 1 of 16 Page ID #:12
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US 7,524,090 B2
1. 2
HORTICULTURELIGHT FIXTURE HAVING grow lamp is sold separately from the lamp ballast assembly
INTEGRATED LAMP AND BALLAST and the end-user connects the two via a power cord.
Previously integrating the lamp ballast into the horticulture
CROSS REFERENCES TO RELATED light fixture was not feasible due to the high temperatures
APPLICATIONS generated by the grow lamp and the relatively low tempera
ture failure rates of the ballast. If installed too close to the
None grow lamp, the lamp ballast will fail prematurely due to the
heat produced by the lamp and absorbed by the ballast.
STATEMENT REGARDING FEDERALLY U.S. Pat. No. 6,595,662 to Wardenburg (2003) teaches a
SPONSORED RESEARCH ORDEVELOPMENT 10 horticulture light fixture benefiting from a sealed forced air or
passive cooling system. The passive or active cooling of the
This invention is not the product of any Federally Spon grow lamp prolongs the life of the lamp while isolating the
sored Research or Development. growing environment from the excessive heat generated by
the grow lamp. The Wardenburg horticulture light fixture
REFERENCE TO MICROFICHEAPPENDIX 15 requires a remote lamp ballast to ignite and power the grow
lamp.
Not Applicable An ideal horticulture light system would be constructed
and arranged having the lamp, lamp ballast, and reflector
BACKGROUND OF THE INVENTION integrated as a single structure that, preferably, is thermally
isolated from the growing environment. Prior attempts to
1. Technical Field integrate the lamp ballast into the horticulture light fixture
The present device relates generally to horticultural and have failed because excessive heat produced by the grow
agricultural lighting systems used in developing and growing lamp was absorbed by the lamp ballast, causing premature
plants in controlled environments. failure of the lamp ballast. Lamp ballasts are sensitive to heat;
2. Discussion of Related Art
25 and, as the operating temperature increases, performance and
longevity decrease.
Indoor gardens, green houses, hydroponics systems, and 3. Objects and Advantages
isolated carbon dioxide growing chambers demand careful There are several objects and advantages of the present
regulation of temperature, light, hydration, nutrients, and device:
humidity. In these controlled environments the grower must 30 a) to provide a horticulture light system that integrates the
provide adequate light intensity, which is usually accom grow lamp and lamp ballast into a single easy-to-install
plished using an HID grow lamp in cooperation with a remote fixture;
HID lamp ballast that is located within a couple feet of the b) to provide an integrated horticulture light system
HID grow lamp.
The most common HID grow lamps are high pressure 35
wherein the lamp ballast does not suffer from premature
failure due to absorption of heat generated by the grow
sodium and metal halide. Metal halide lamps work well to lamp;
generate the “blue” spectrum, but also produce well in the c) to provide an integrated horticulture light system
"orange-red' spectrum. Metal halides are best suited as a wherein the lamp ballast is thermally isolated from the
primary light source (if little or no natural Sunlight is avail grow lamp enclosure by an air gap.
able) and are excellent for plant growth. High pressure 40
Sodium lamps produce primarily in the "orange-red' spec Still further objects and advantages will become apparent
trum. The high pressure sodiums are the best available lamps from consideration of the following description and draw
for secondary or Supplemental lighting (used in conjunction ings.
with natural sunlight). The “orange-red' type of light pro
motes flowering/budding/fruiting in plants. High pressure 45 SUMMARY
Sodium lamps are ideal for greenhouse or commercial grow
ing applications. However, one significant drawback is the In accordance with the present device, a horticulture light
heat generated by these grow lamps. Without cooling, the system constructed and arranged to integrate a lamp ballast
lamps will prematurely fail. Due to the extreme heat, any into the same fixture as the grow lamp without the lamp
electronics located in close proximity to the grow lamp will 50 ballast suffering from premature failure.
also prematurely fail.
Both the metal halide lamps and the high pressure sodium DESCRIPTION OF THE DRAWINGS
lamps require high Voltage power to ignite the lamps and
maintain lumen output. Commonly, the high Voltage power FIG. 1 is a perspective view of one embodiment of the
Supply is referred to as a lamp ballast. These lamp ballasts 55 horticulture light fixture having integrated lamp and ballast;
convert the standard 110 volt or 220 volt electrical service FIG. 2 is a first side view of the embodiment of the horti
power to high Voltage electrical power that meets the require culture light fixture having integrated lamp and ballast as
ments of the metal halide and high pressure Sodium lamps. shown in FIG. 1;
The lamp ballasts are often housed a safe distance from the FIG. 3 is a second side view of the embodiment of the
grow lamp in separate aluminum extruded cases, with a 60 horticulture light fixture having integrated lamp and ballast as
power cord connecting the grow lamp to the lamp ballast. shown in FIG. 1;
Lamp ballasts suffer from temperature sensitivity in that FIG. 4 is a rear side view of the embodiment of the horti
excessive temperatures cause premature failure of the elec culture light fixture having integrated lamp and ballast as
tronic components, leading to decreased performance. shown in FIG. 1;
Because of the heat generated by the grow lamp, the lamp 65 FIG. 5 is a front side view of the embodiment of the horti
ballast must be thermally isolated in order to prevent prema culture light fixture having integrated lamp and ballast as
ture failure. Generally, the horticulture light fixture with the shown in FIG. 1;
Case 5:19-cv-00570 Document 1-1 Filed 03/29/19 Page 13 of 16 Page ID #:24
US 7,524,090 B2
3 4
FIG. 6 is a top side view of the embodiment of the horti development. A “fixator can be any device, apparatus, or
culture light fixture having integrated lamp and ballast as adhesive capable of holding a “transparent portion' securely
shown in FIG. 1; to the fixture.
FIG. 7 is a bottom view of the embodiment of the horticul
ture light fixture having integrated lamp and ballast as shown 5
Description FIG. 1:
in FIG. 1; FIG. 1 illustrates one preferred embodiment of the device
FIG. 8 is a perspective view of the horticulture light fixture and is not representative of all possible embodiments. The
with the ballast enclosure removed showing greater detail of exterior structure 130 generally consists of the lower exterior
structure 120 and the ballast enclosure 118. The lower exte
the lamp ballast, ballast plate, and the air gap between the rior structure 120 has a lower flat front side 110; a lower flat
ballast plate and the mid top flat side; 10
rear side 111; a first inclined lower side portion 112: a second
FIG. 9 is a bottom view of the embodiment with a grow inclined lower side portion 113; and a rectangular bottom side
lamp installed in proper position for use; 128. Said lower flat front side 110 having a cool atmosphere
FIG. 10 is a side view of the embodiment having part of the inlet 124 and said flat rear side 111 having a heated atmo
ballast enclosure removed and showing the lamp ballast sphere exhaust 122. The secure mounting tabs 138 for hang
mounted to the ballast plate, stand-offs between the ballast 15
ing the device are located generally along the centerline of the
plate and the mid top flat side, further demonstrating the air flat top side 117.
gap between the mid top flat side and the ballast plate of the The ballast enclosure 118 consists of a front inclined upper
horticulture light fixture having integrated lamp and ballast. side portion 115; a rear inclined upper side portion 116; a first
DESCRIPTION OF THE PREFERRED inclined upper side portion 119; a second inclined upper side
EMBODIMENT portion 114; and a flat top side 117. Louvered vents 126 can
be integrated into the front inclined upper side portion 115;
Referring now to the drawings, and particularly to FIGS. the rear inclined upper side portion 116; the first inclined
1-10, a preferred embodiment of the present device is shown, upper side portion 119; and the second inclined upper side
illustrating the horticultural and agricultural lighting systems 25 portion 114. Cut out of the front inclined upper side portion
used in developing plants in controlled growing environ 115 there is a power inlet hole 134 having a power cord 140
ments. The exemplary embodiments according to the present extending out to connect to electrical service.
device are illustrated with those components necessary to Fixators 121 fasten into the lower flat front side 110 for the
demonstrate the inventive design. Many of the necessary purpose of holding a transparent portion 710 shown in FIG. 7.
electrical and mechanical elements for attaching, powering, 30 Description FIG. 2:
and implementing are not present. For example, the electrical FIG. 2 illustrates a left side view of one preferred embodi
service connection of 110 Volts or 220 volts is known by one ment of the device. The lower exterior structure 120, having a
of normal skill in the art but not specifically mentioned. The first inclined lower side portion 112 with a lower flat front side
horticulture lamp types most commonly used are high pres 110 and a lower flat rear side 111. Said lower flat front side
Sure sodium and metal halide—both high intensity discharge 35 110 having a cool atmosphere inlet 124 and said lower flat
and requiring specific power that is well known by one of rear side 111 having a heated atmosphere exhaust 122. The
ordinary skill in the art. Elements not present or described rectangular bottom side 128 is open towards the plants.
below may take on any known form consistent with forms Fixators 121 fasten into the lower flat front side 110 for the
readily realized by one of ordinary skill in the art, having purpose of holding a transparent portion 710 shown in FIG. 7.
knowledge of the mode of operation of a horticulture light 40
The fixators 121 may be placed anywhere along the bottom of
system. the lower exterior structure 120.
As used herein, “grow light’ is the desired radiation having The ballast enclosure 118 consists of a first inclined upper
a wavelength within the spectrum of light that promotes pho side portion 119 having louvered vents 126. A front inclined
tosynthesis in plants. A 'grow lamp' can mean any presently upper side portion 115 with integrated louvered vents 126; a
available lamp or combination of lamps capable of generating 45
rear inclined upper side portion 116 with louvered vents 126;
radiation within the “grow light' spectrum. “Lamp ballast’ is and a flat top side 117. The louvered vents 126 are cut in the
the electrical component that converts service power (i.e. 110 sheet metal and open downwardly. The louvered vents 126
volt or 220 volt) to the requisite “grow lamp' power require provide a pathway for either the exhausting of heated air from
ments (i.e. 1200 volt). The “growing environment' is the the ballast enclosure or a pathway for taking in cooling air
confined gas around the plants that may be as simple as air, or 50
from the growing environment. The flat top side 117 may also
could be a complex combination of carbon dioxide and intro be vented, depending on the application, to facilitate further
duced moisture for a balanced humidity. “Plants’ refers to cooling of the ballast enclosure 118. The louvered vents 126
growing, developing, and living plants maintained in potted may also be simple hole punched vents of any shape or size
soil, hydroponics, or other growing medium, generally par depending upon application, size of the grow lamp, and size
allel to the earth's surface. A “reflector hood' is an internal 55 of the ballast.
hood made of reflective material and constructed with folds The cool atmosphere inlet 124 provides an opening for
and bends to reflect light towards the plants. A “transparent cooling air to be forced over the grow lamp and through the
portion' is a transparent plate that can be made of any trans lower exterior structure 120 and out the heated atmosphere
parent substance that will be impervious to air but allow light exhaust 122. This forced cooling air lowers the temperature of
to pass through. A “reflector chamber is the space bounded 60
the lower exterior structure 120 increasing the longevity of
by the “reflector hood” and “transparent portion.” A “cooling the grow lamp and the lamp ballast.
atmosphere' is gas moved into the “reflector chamber to The flat top side 117 having secure mounting tabs 138 for
cool the lamp, Surrounding area, and “reflector chamber. A hanging the device over the plants.
“heated atmosphere' is gas moved out of the “reflector cham
ber and away from the surrounding area. "Gas' can be nor 65 Description FIG.3:
mal air, Co2-enhanced air, or some other gaseous combina FIG. 3 illustrates right side view of one preferred embodi
tion effective at either cooling or advantageous to plant ment of the device illustrated in FIG. 2. The lower exterior
Case 5:19-cv-00570 Document 1-1 Filed 03/29/19 Page 14 of 16 Page ID #:25
US 7,524,090 B2
5 6
structure 120 has a second inclined lower side portion 113: 126 may be punched out vents or any other vents depending
with a lower flat front side 110 and a lower flat rear side 111. on application, heat generated by the grow lamp, and specific
Said lower flat front side 110 having a cool atmosphere inlet ballast requirements.
124 and said lower flat rear side 111 having a heated atmo Description FIG. 6:
sphere exhaust 122. The rectangular bottom side 128 is open 5
FIG. 6 illustrates a top view of one preferred embodiment
to the plants. Fixators 121 fasten into the lower flat front side of the device. The lower exterior structure 120 having a first
110 for the purpose of holding a transparent portion 710 inclined lower side portion 112: a second inclined lower side
shown in FIG. 7. The fixators 121 may be placed anywhere portion 113: a lower flat front side 110 and a lower flat rear
along the bottom of the lower exterior structure 120. 10 side 111. Said flat front side 110 having a cool atmosphere
The ballast enclosure 118 consists of a second inclined inlet 124 and said lower flat rear side 111 having a heated
upper side portion 114 having louvered vents 126. A front atmosphere exhaust 122. The heated atmosphere exhaust 122
inclined upper side portion 115 with integrated louvered and cool atmosphere inlet 124 are interchangeable in that
vents 126; a rear inclined upper side portion 116; and a flat top cooling atmosphere can be pushed through in either direction.
side 117. The louvered vents 126 are cut in the sheet metal and 15 The rectangular bottom side 128 is open to the plants. Fix
open downwardly. The louvered vents 126 provide a pathway ators 121 fasten into the lower flat front side 110 for the
for either the exhausting of heated air from the ballast enclo purpose of holding a transparent portion 710 shown in FIG. 7.
Sure 118 or a pathway for taking in cool air from the growing The fixators 121 may be placed anywhere along the bottom of
environment. the lower exterior structure 120.
The flat top side 117 having secure mounting tabs 138 for The ballast enclosure 118 consists of a front inclined upper
hanging the device over the plants. side portion 115; a rear inclined upper side portion 116; a first
inclined upper side portion 119; a second inclined upper side
Description FIG. 4: portion 114; and a flat top side 117. The front inclined upper
FIG. 4 illustrates a front view of one preferred embodiment side portion 115 has a power inlet hole 134 for this embodi
of the device. The open cool atmosphere inlet 124 provides a 25 ment, but the power can be brought in anywhere on the
through view to the other side where the socket mount 132 fixture. The power cord 140 extends out of the power inlet
attached to thej-box 136 provides the screw in location for the hole 134.
grow lamp. The cool atmosphere inlet 124 is approximately The louvered vents 126 provide a pathway for either the
centered in the lower flat front side 110 of the lower exterior exhausting of heated air from the ballast enclosure, or a path
structure 120. On either side of the lower flat front side 110 is 30 way for taking in cooling air from the growing environment.
the first inclined lower side portion 112 and the second If it is desirable that the entire device be sealed from the
inclined lower side portion 113. The rectangular bottom side growing environment, no louvered vents 126 are cut.
128 is open to the plants. The cool atmosphere inlet 124 may Description FIG. 7:
be located anywhere on the lower flat front side 110. Fixators FIG. 7 illustrates a bottom side view of one preferred
121 fasten into the lower flat front side 110 for the purpose of 35 embodiment of the device. The lower exterior structure 120
holding a transparent portion 710 shown in FIG. 7. The fix
ators 121 may be placed anywhere along the bottom of the has a first inclined lower side portion 112; a second inclined
lower exterior structure 120. lower side portion 113; a lower flat front side 110; and a lower
The ballast enclosure 118 consists of a first inclined upper flat rear side 111. Said flat front side 110 having a cool
side portion 119 and a second inclined upper side portion 114, 40
atmosphere inlet 124 and said lower flat rear side 111 having
a heated atmosphere exhaust 122.
both having louvered vents 126; and front inclined upper side The rectangular bottom side 128 is sealed by the transpar
portion 115. The ballast enclosure 118 is capped by the flat ent portion 710. The transparent portion 710 is held in place
top side 117. A power inlet hole 134 is located on the front by fixators 121. Looking through the transparent portion 710
inclined upper side portion 115, said power inlet hole 134 the reflector hood 712 can be seen with a plurality of longi
having a power cord 140 extending out for electrical service. 45
tudinal fold lines. The reflector hood 712 may be in any
The ballast enclosure 118 sits atop the lower exterior structure configuration that effectively reflects light towards the plants.
120. The flat top side 117 having a secure mounting tab 138 The socket mount 132 is placed on the inboard side of the flat
for hanging the device over the plants. rear side 111 being attached by the j-box 136, centered in the
Description FIG. 5: 50
heated atmosphere exhaust 122. The reflector hood 712 has
FIG. 5 illustrates a rear view of one preferred embodiment matching openings to the cool atmosphere inlet 124 and the
of the device. The open heated atmosphere exhaust 122 pro heated atmosphere exhaust 122 allowing for forced cooling
vides a view of the back of the j-box 136 wherein the grow atmosphere to pass through freely.
lamp can screw into the other side. The heated atmosphere Description FIG. 8:
exhaust 122 is approximately centered in the lower flat rear 55 FIG. 8 illustrates a perspective view centering on the
side 111 of the lower exterior structure 120 but the location exposed lamp ballast 512 having the ballast enclosure 118
can be anywhere on the lower flat rear side 111. On either side removed. The lower exterior structure 120 has a first inclined
of the lower flat rear side 111 is the first inclined lower side lower side portion 112; a second inclined lower side portion
portion 112 and the second inclined lower side portion 113. 113; a lower flat front side 110; and a lower flat rear side 111.
The rectangular bottom side 128 is open downward towards 60 Said flat front side 110having a cool atmosphere inlet 124 and
the plants. said lower flat rear side 111 having a heated atmosphere
The ballast enclosure 118 consists of a rear inclined upper exhaust 122.
side portion 116, a first inclined upper side portion 119, and a The mid top flat side 1060 is the mounting surface for the
second inclined upper side portion 114, all having louvered ballast plate 1050. Said ballast plate 1050 provides the
vents 126. The ballast enclosure 118 is capped by the flat top 65 mounting surface for the lamp ballast 512. The lamp ballast
side 117. The flat top side 117 having secure mounting tabs 512 and ballast plate 1050 are located above the lower exte
138 for hanging the device over the plants. The louvered vents rior structure 120. The ballast plate 1050 is distanced from the
Case 5:19-cv-00570 Document 1-1 Filed 03/29/19 Page 15 of 16 Page ID #:26
US 7,524,090 B2
7 8
mid top flat side 1060 creating an air gap 1030 between the that have both been removed for this FIG.10; a front inclined
ballast plate 1050 and the mid top flat side 1060. The air gap upper side portion 115; a rear inclined upper side portion 116;
1030 width is set by size of the stand offs 1040. The preferred and, a flat top side 117 that has also been removed for this
embodiment utilizes stand offs 1040, but any spacing device FIG. 10. The cool atmosphere inlet 124 provides an opening
can be used to keep the ballast plate 1050 and the mid top flat for cooling air to be forced through the lower exterior struc
side 1060 separated. The ballast plate 1050 can be of a size ture 120, over the grow lamp, and out the heated atmosphere
and dimension larger than the bottom Surface area of lamp exhaust 122. This forced cooling air lowers the temperature of
ballast 512 and may be of different dimensions, depending the exterior structure 120 and increases the longevity of the
upon application. The air gap 1030 provides athermal barrier grow lamp 910 and the lamp ballast 512.
between the ballast plate 1050 and midtop flat side 1060. The 10 The grow lamp 910 creates significant heat that is trans
mid top flat side 1060 is exposed to a higher temperature due ferred to the mid top flat side 1060 creating a high surface
to the grow lamp 910 (shown installed in FIG.9). The heated temperature that would cause the lamp ballast 512 to prema
gas in the air gap 1030 rises up and around the ballast plate turely fail if mounted directly to the mid top flat side 1060.
1050, avoiding the lamp ballast 512; and, thus decreasing the The high surface temperature of the mid top flat side 1060
gas temperatures directly surrounding the lamp ballast 512. 15 heats the gas in the air gap 1030 between the mid top flat side
Mounting the lamp ballast 512 directly to the mid top flat side 1060 and the ballast plate 1050. The heated atmosphere rises
1060 causes heat to soak into the lamp ballast 512, causing up from the mid top flat side 1060 and is deflected by the
premature failure even with cooling atmosphere moving ballast plate 1050 around and away from the lamp ballast 512.
between the cool atmosphere inlet 124 and the heated atmo The dimensions of the ballast plate 1050 can vary depending
sphere exhaust 122. The preferred embodiment demonstrates on the surface temperature of the mid top flat side 1060 and
the ballast plate 1050 and the air gap 1030 working in concert the desired operating environment of the selectedlamp ballast
when, in some applications, only the ballast plate 1050 or the 512. When a larger grow lamp 910 is installed, a larger ballast
air gap 1030 are alone required, depending on the size of the plate 1050 may be required to adequately shield the lamp
grow lamp 910 and heat sensitivity of the lamp ballast 512. ballast 512 from the heated gas rising off the mid top flat side
The lamp ballast 512 connects to electrical service via the 25 1060. The distance between the ballast plate 1050 and the mid
power cord 140, converting to the requisite power for the top flat side 1060 may be increased to create a larger air gap
selected grow lamp 910 (shown in FIG. 9), and connecting to 1030, further thermally isolating the lamp ballast 512 from
the grow lamp via the lamp cord 1020. The lamp cord 1020 the heat generated from the grow lamp 910. The size of the air
connects to the lamp ballast 512 at the ballast power connec gap 1030 can be set by using stand off 1040 spacers.
tor 1010. 30 The ballast enclosure 118 may be used to cover the lamp
Description FIG.9: ballast 512, but is not necessary to the integration of the lamp
FIG. 9 illustrates a bottom side view of one preferred ballast 512 and the grow lamp 910 into a single horticulture
fixture.
embodiment of the device having a grow lamp 910 installed.
The lower exterior structure 120 has a first inclined lower side
35
portion 112; a second inclined lower side portion 113; a lower
flat frontside 110; and a lower flat rear side 111. Said flat front REFERENCENUMBERS:
side 110 having a cool atmosphere inlet 124 and said lower
flat rear side 111 having a heated atmosphere exhaust 122. 110 lower flat front side 124 cool atmosphere inlet
111 lower flat rear side 126 louvered vents
The rectangular bottom side 128 is open towards the plants 40 112 first inclined lower side portion 128 rectangular bottom
and the grow lamp 910 and the reflectorhood 712 can be seen side
through the transparent portion 710, said transparent portion 113 second inclined lower side portion 130 exterior structure
710 sealing off the growing environment from the heated 114 second inclined upper side portion 132 socket mount
115 front inclined upper side portion 134 power inlet hole
atmosphere moving through the fixture. The Socket mount 116 rear inclined upper side portion 136 j-box
132 is placed on the inboard side of the flat rear side 111, 45 117 flat top side 138 secure mounting tabs
centered in the heated atmosphere exhaust 122. The reflector 118 ballast enclosure
119 first inclined upper side portion
140 power cord
512 lamp ballast
hood 712 has matching openings to the cool atmosphere inlet 120 lower exterior structure 710 transparent portion
124 and the heated atmosphere exhaust 122. 121 fixators 712 reflector hood
Description FIG. 10: 122 heated atmosphere exhaust 910 grow lamp
1010 ballast power connector 1020 lamp cord
FIG. 10 illustrates a side view of one preferred embodi 50 1030 air gap 1040 stand off
ment of the device having the first inclined upper side portion 1050 ballast plate 1060 mid top flat side
119, second inclined upper side portion 114, and the flat top
side 117 removed to further demonstrate the relative configu
ration between the lamp ballast 512, ballast plate 1050, air What is claimed:
gap 1030, and the mid top flat side 1060. 55 1. The method for integrating a lamp ballast within a grow
The lower exterior structure 120, having a first inclined light fixture comprising the steps of:
lower side portion 112 with a lower flat front side 110 and a a) enclosing the grow lamp in a lower exterior structure;
lower flat rear side 111. Said lower flat front side 110 having b) securing the lamp ballast to a ballast plate;
a cool atmosphere inlet 124 and said lower flat rear side 111 c) mounting said ballast plate to the top side of the lower
having a heated atmosphere exhaust 122. The rectangular 60 exterior structure using at least one stand off spacer
bottom side 128 is open towards the plants. between the ballast plate and the lower exterior struc
Fixators 121 fasten into the lower flat front side 110 for the ture; and,
purpose of holding a transparent portion 710 shown in FIG. 7. d) said stand off spacer being the size of the desired air gap
The fixators 121 may be placed anywhere along the bottom of between the ballast plate and the lower exterior struc
the lower exterior structure 120. 65 ture.
The ballast enclosure 118 consists of a first inclined upper 2. A horticultural light system having an integrated lamp
side portion 119 and second inclined upper side portion 114 and ballast comprising:
Case 5:19-cv-00570 Document 1-1 Filed 03/29/19 Page 16 of 16 Page ID #:27
US 7,524,090 B2
9 10
an exterior structure having a lower exterior structure and a a transparent portion between the light reflector hood and
ballast enclosure; the plants, fittingly attached to said lower exterior struc
said lower exterior structure having a lower flat front side, ture sealing the atmosphere within the light reflector
a lower flat rear side, a midtop flat side, and a rectangular chamber from the growing environment of the plants;
bottom side being open towards the plants, including a 5 a lamp ballast integrated above said lower exterior struc
cool atmosphere inlet on the flat front side, and a heated ture and within said ballast enclosure, mounted to a
atmosphere exhaust outlet on the rear flat side; ballast plate, said ballast plate fixedly attached to the mid
said ballast enclosure having a front inclined upper portion, top flat side of the lower exterior structure, leaving an air
a rear inclined upper portion, a first inclined upper side
portion, a second inclined upper side portion, and a flat 10 at gap
least
between said ballast plate and the mid top flat side;
one Support Socket bracket for mounting a lamp
top side, the bottom bounded by the mid top flat side of within the lower exterior structure.
the lower exterior structure;
at least one vent cut through the ballast enclosure; 3. The horticultural light apparatus of claim 2, wherein the
a light reflector hood within said lower exterior structure, ballast plate is separated from the mid top flat side by a
constructed and arranged to reflect light towards plants, 15 plurality of standoffspacers, Said standoffspacers setting the
further having a first opening at the cool atmosphere air gap size between the ballast plate and mid top flat side.
inlet, and a second opening at the heated atmosphere
exhaust outlet; k . . . .
Case 5:19-cv-00570 Document 1-2 Filed 03/29/19 Page 1 of 10 Page ID #:28
USOOD740486S
US D740.486 S
Page 2
US D771,301S
Page 2
US D771,301S
Page 3
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Case 5:19-cv-00570 Document 1-3 Filed 03/29/19 Page 4 of 5 Page ID #:41
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