January 2, 2025
Signify vs. Keystone Lawsuit Transferred to Pennsylvania
Bishop & Brogdon’s "Sales Agency" status and Atlanta inventory failed to establish Georgia venue
The legal dispute between Signify and Keystone Technologies over alleged patent infringement has been transferred from the U.S. District Court for the Northern District of Georgia to the Eastern District of Pennsylvania. The transfer, finalized on December 19, 2024, follows a detailed court examination of venue propriety under the patent-specific venue statute, 28 U.S.C. § 1400(b).
Signify, the world’s largest lighting maker, initially filed its lawsuit against Keystone on May 31, 2024, in Georgia, alleging that Keystone infringed upon eight patents related to LED technology. The patents cover innovations in driver circuits, configurable lighting systems, downlights, and lamps. Keystone products cited in the complaint include the XFIT Area Light, Aviva Retrofit Downlights, and SmartDrive LED Lamps. Signify also claims willful and deliberate infringement dating back to 2020.
In its initial filing, Signify pointed to its subsidiary Cooper Lighting, headquartered in Peachtree City, Georgia, and noted its involvement in lighting projects like the University of Georgia's Sanford Stadium as evidence of its strong ties to the region. The company also cited Keystone’s sales activities through Grainger’s Marietta, Georgia location to establish venue.
Above: Court order excerpt as written by U.S. District Judge, Leigh Martin May
Keystone's Argument for Transfer
Keystone countered that it neither resides in Georgia nor maintains a "regular and established place of business" there. As the case evolved, Signify’s primary contention focused on Bishop & Brogdon, an independent manufacturers' representative based in Atlanta, which represents Keystone in the region. Keystone argued that Bishop & Brogdon operates independently, with no lease or direct control by Keystone over its facility, employees, or business practices. According to Keystone, its relationship with Bishop & Brogdon is limited to a standard commercial agreement for warehousing and sales support.
The court agreed, finding that Bishop & Brogdon's operations could not be deemed a “regular and established place of business” for Keystone. The court cited lack of control, absence of an agency relationship, and Bishop & Brogdon’s representation of multiple manufacturers, including Keystone’s competitors, as factors negating the venue argument.
Signify's Counterarguments
Signify maintained that Keystone’s activities through Bishop & Brogdon, including training sessions and inventory storage occupying approximately 5,000 square feet at Bishop & Brogdon’s Atlanta facility, constituted a regular business presence. The company also highlighted Bishop & Brogdon’s designation as Keystone’s "Sales Agency" in their agreement, arguing this implied agency under U.S. law that dictates court venue locations.
However, the court dismissed these claims, emphasizing that Keystone’s contractual rights did not equate to the control or permanence required to establish venue. The court noted that Bishop & Brogdon’s handling of multiple manufacturers’ products further diluted Signify’s argument.
Judge's Rationale
The court ruled that Keystone resides in Pennsylvania, where its headquarters and primary operations are located, making the Eastern District of Pennsylvania a proper and more convenient venue. Keystone’s argument that relevant evidence and witnesses are concentrated in Pennsylvania, coupled with the lack of venue propriety in Georgia, led to the transfer.
This decision shifts the focus of the case to Pennsylvania, where Keystone is headquartered. The outcome of this patent litigation could have broader implications for intellectual property enforcement in the lighting industry.
