IN 2 Developments LLC v. Globe Electric: LED Bulb Patent Action Dismissed in 91 Days
IN 2 Developments LLC accused Globe Electric’s Vintage LED Bulb — a 60W Edison-style replacement — of infringing two US patents covering LED bulb design and construction. The Central District of California action was voluntarily dismissed without prejudice just 91 days after filing, leaving the door open for future proceedings.
LED Bulb Patent Dispute Exits C.D. Cal. Before Discovery Opens
On 5 September 2024, IN 2 Developments LLC filed suit against Globe Electric in the Central District of California, asserting infringement of US9995436B2 and US9702510B2 — two patents directed at Edison-style LED bulb technology. The accused product was Globe Electric’s Vintage LED Bulb, marketed as a 60W replacement bulb with a traditional filament-style aesthetic powered by LED technology.
On 5 December 2024, just 91 days after filing, IN 2 Developments invoked Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure to voluntarily dismiss the entire action against all parties without prejudice. A dismissal without prejudice under this rule means no merits determination was made, and IN 2 Developments retains the legal right to reassert the same patent claims against Globe Electric or other defendants in a future proceeding.
The sub-100-day resolution is consistent with early settlement negotiations, a licensing agreement reached off the record, or a strategic reassessment of claim strength before Globe Electric filed an answer or motion. Because the dismissal was filed unilaterally under Rule 41(a)(1)(A)(i) — available only before the defendant serves an answer or motion for summary judgment — the public record is silent on whether any financial consideration changed hands or what prompted the withdrawal.
Filing to Voluntary dismissal in 91 days
91 days — notably short; most C.D. Cal. patent cases run 2–3 years to resolution
Voluntarily dismissed: what Rule 41 means for both parties
Rule 41(a)(1)(A)(i): plaintiff’s unilateral exit right
Under Rule 41(a)(1)(A)(i), a plaintiff may dismiss an action without a court order — and without prejudice — before the defendant serves an answer or a motion for summary judgment. This is a procedural right, not a concession on the merits. The case closes immediately upon filing the notice, with no judicial approval required and no finding on infringement or validity.
Procedural dismissal — no merits rulingWithout prejudice confirmed — but the distinction matters
The notice expressly states ‘without prejudice,’ meaning IN 2 Developments LLC retains the right to refile the same claims. A ‘with prejudice’ dismissal would permanently bar refiling. The public record does not disclose whether a confidential settlement or licensing agreement was reached alongside this filing — that distinction is commercially significant but unknowable from the docket alone.
Claims may be refiledGlobe Electric avoids a merits ruling — but risk persists
Globe Electric escapes this particular action without an adverse infringement finding and without a court ruling that its Vintage LED Bulb is non-infringing. That is procedurally neutral, not a vindication. If no license was obtained, Globe Electric’s product line remains potentially exposed to the same patents in any future refiled action — possibly in a different venue.
No invalidity or non-infringement rulingEdison-style LED market: patent risk not resolved
US9995436B2 and US9702510B2 remain in force. Other manufacturers of Edison-style or filament-aesthetic LED bulbs in the consumer lighting market should treat this dismissal as a deferral, not a resolution. The patents have not been tested on validity or claim scope, and IN 2 Developments may pursue enforcement against Globe Electric or similarly situated competitors in the future.
Patents still enforceableFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | IN 2 Developments LLC | Company | LED lighting patent assertion entity — holder of US9995436B2 and US9702510B2Search in Eureka ↗ |
| Defendant | Globe Electric | Individual | Globe Electric — consumer lighting brand, maker of Vintage Edison-style LED bulbsSearch in Eureka ↗ |
| Plaintiff counsel | Chandran B. Iyer | Attorney | Counsel for IN 2 Developments LLCSearch in Eureka ↗ |
| Plaintiff counsel | Peter E. Perkowski | Attorney | Counsel for IN 2 Developments LLCSearch in Eureka ↗ |
| Plaintiff counsel | Ronald M. Daignault | Attorney | Counsel for IN 2 Developments LLCSearch in Eureka ↗ |
| Plaintiff law firm | Daignault Iyer LLP | Law Firm | Representing IN 2 Developments LLCSearch in Eureka ↗ |
| Plaintiff law firm | Perkowski Legal, PC | Law Firm | Representing IN 2 Developments LLCSearch in Eureka ↗ |
| Defendant counsel | Matthew J Levinstein | Attorney | Counsel for Globe ElectricSearch in Eureka ↗ |
| Defendant counsel | Samuel C. Means | Attorney | Counsel for Globe ElectricSearch in Eureka ↗ |
| Defendant law firm | Greenberg Traurig LLP | Law Firm | Representing Globe ElectricSearch in Eureka ↗ |
| Presiding judge | Judge N/A | Judge | California Central District CourtSearch in Eureka ↗ |
Official order — verbatim text
The dismissal notice invokes Rule 41(a)(1)(A)(i) and expressly states ‘without prejudice,’ which is legally significant: it confirms no settlement or adverse merits finding is embedded in the dismissal itself. For Globe Electric, there is no court-endorsed finding of non-infringement. For IN 2 Developments, the patents survive intact. The timing — before an answer was served — means Globe Electric had no opportunity to assert counterclaims or seek attorneys’ fees under 35 U.S.C. § 285.
US9995436B2 & US9702510B2 — Edison-Style LED Bulb Technology
US9995436B2 (App. No. 15/644220) and US9702510B2 (App. No. 14/286586) are both directed at LED bulb technology in the Edison or vintage-filament aesthetic segment — a category that has seen rapid consumer adoption as incandescent bulbs have been phased out. These patents cover structural and design elements of LED bulbs using an Edison-style base, a form factor that commands premium positioning in decorative and residential lighting markets.
The commercial stakes are significant: Edison-style LED bulbs are sold by most major lighting brands and through mass-market retail channels. A patent covering core structural elements of this bulb format could affect a broad range of SKUs across multiple manufacturers. The fact that IN 2 Developments chose to assert both patents against Globe Electric’s Vintage line — rather than a single claim — suggests the patent holder believes the IP portfolio covers multiple aspects of this product architecture, raising the risk profile for competitors in the decorative LED segment.
Should your LED bulb products be cleared against US9995436B2?
Any company manufacturing, importing, or selling Edison-style or vintage filament-aesthetic LED bulbs in the US market should treat US9995436B2 and US9702510B2 as live risks. This case’s voluntary dismissal without prejudice does not extinguish either patent, and no claim construction or invalidity ruling was issued. Product teams developing 60W-equivalent LED replacements with traditional base designs are directly in scope.
PatSnap Eureka’s FTO Search Agent can map your LED bulb product specifications against the claim language of both asserted patents, surface any prosecution history estoppel that may limit claim scope, and identify prior art that could inform an IPR petition strategy at the PTAB. Run an FTO before Globe Electric or a parallel defendant receives a demand letter — not after.
Run a freedom-to-operate analysis on US9995436B2 to assess your product’s exposure
Run FTO in Eureka →Similar LED Bulb & Consumer Lighting Patent Cases in US District Courts
Explore related patent infringement actions involving Edison-style and LED lighting technology filed in California and other US federal district courts.
What this case signals for the consumer LED lighting IP landscape
A sub-100-day voluntary dismissal in a patent case rarely means the issue is resolved — it often signals a pivot, not a retreat.
Rule 41 exits are often preludes to licensing deals or re-filed suits
When a plaintiff invokes Rule 41(a)(1)(A)(i) this early — before the defendant even answers — it typically suggests either a quick confidential settlement or a reassessment of strategy. Neither outcome removes the underlying patent risk for Globe Electric or other Edison-style LED manufacturers. Competitors should not read this dismissal as a signal that these patents are weak.
Both asserted patents remain live enforcement tools
US9995436B2 and US9702510B2 have not been challenged at the PTAB, invalidated, or found non-infringed. Any company selling filament-aesthetic or Edison-style LED bulbs in the US market should assess its exposure to these claims before this docket is reopened or a parallel action is filed elsewhere.
IN v Globe — key questions answered
IN 2 Developments LLC filed a patent infringement suit against Globe Electric in the Central District of California on 5 September 2024, asserting US9995436B2 and US9702510B2 against Globe Electric’s Vintage LED Bulb. The case was voluntarily dismissed without prejudice by the plaintiff on 5 December 2024 — just 91 days after filing — with no merits ruling issued.
Globe Electric avoids an adverse infringement finding, but receives no court ruling that its products are non-infringing or that the asserted patents are invalid. The dismissal without prejudice means IN 2 Developments LLC may refile the same claims in the future. Globe Electric’s legal exposure under US9995436B2 and US9702510B2 is not extinguished by this outcome.
Two patents were asserted: US9995436B2 (Application No. 15/644220) and US9702510B2 (Application No. 14/286586). Both are directed at LED bulb technology with an Edison-style base design. The accused product was Globe Electric’s Vintage LED Bulb, marketed as a 60W incandescent replacement with a filament-aesthetic form factor.
Yes. A dismissal without prejudice under Rule 41(a)(1)(A)(i) does not bar refiling. IN 2 Developments LLC may bring a new action asserting the same patents against Globe Electric — or against other LED bulb manufacturers — in the same or a different venue. However, a second voluntary dismissal against the same defendant would operate as a dismissal with prejudice under Rule 41(a)(1)(B).
The dismissal without prejudice leaves US9995436B2 and US9702510B2 fully enforceable. No invalidity finding, no claim construction, and no non-infringement ruling was issued. Other companies making or selling Edison-style or vintage-filament LED bulbs in the US market should assess their exposure to these patents through a freedom-to-operate analysis before IN 2 Developments files further enforcement actions.
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