Case 5:21-cv-10617-JEL-DRG ECF No. 1, PageID.

1 Filed 03/19/21 Page 1 of 13

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF MICHIGAN

GENERAL SCIENTIFIC
CORPORATION d/b/a SURGITEL, Case No. ______________

Plaintiff, JURY TRIAL DEMANDED

v.

DEN-MAT HOLDINGS, LLC

Defendant.

COMPLAINT FOR PATENT INFRINGEMENT

Plaintiff General Scientific Corporation d/b/a SurgiTel (“SurgiTel”), for its

complaint against Den-Mat Holdings, LLC (“Den-Mat”), hereby alleges as follows:

NATURE OF THE ACTION

1. This is an action for patent infringement arising under the Patent Laws

of the United States, 35 U.S.C. § 1 et seq., including specifically, 35 U.S.C. § 271,

based on Den-Mat’s willful infringement of U.S. Patent No. 8,047,684 (“the ’684

Patent”) (Exhibit A) and U.S. Patent No. 8,662,709 (“the ’709 Patent”) (Exhibit B)

(collectively, “the Patents-in-Suit”)

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THE PARTIES

2. SurgiTel is a corporation organized and existing under the laws of the

State of Michigan with a principal place of business at 77 Enterprise Drive, Ann

Arbor, Michigan 48103.

3. On information and belief, Den-Mat is a corporation organized and

existing under the laws of the State of Delaware with a principal place of business

at 1017 W. Central Ave., Lompoc, CA 93436-2701.

JURISDICTION AND VENUE

4. This action arises under the Patent Laws of the United States, Title 35,

United States Code. This Court has subject matter jurisdiction over this action

pursuant to 28 U.S.C. §§ 1331 and 1338.

5. This Court has personal jurisdiction over Den-Mat at least because

Den-Mat transacts and solicits business in the State of Michigan, including with

respect to illuminators that infringe the Patents-in-Suit, and because Den-Mat is

committing and has committed acts of patent infringement in the State of Michigan,

at least by selling and offering to sell illuminators that infringe the Patents-in-Suit in

Michigan.

6. Venue is proper in this judicial district under 28 U.S.C. §§ 1391 and

1400 at least because Den-Mat has committed acts of infringement in this district,

including with respect to illuminators that infringe the Patents-in-Suit, and has a

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regular and established place of business in this district through the presence of a

dentist partner and product trainer who is physically located in the district.

COMMON ALLEGATIONS

7. Since 1932, SurgiTel and its predecessor in interest have been a leading

provider of loupes, headlights, and other optical accessories for medical and dental

practitioners.

8. SurgiTel sells a range of illuminator devices, including light emitting

diode (“LED”) headlights, designed to be worn by medical and dental professionals.

9. SurgiTel’s illuminator devices advantageously allow for an adjustable

beam pattern, improving light uniformity and decreasing color separation at the edge

of the beam.

10. Specifically, SurgiTel’s illuminator devices provide for an adjustable

beam pattern by virtue of a flexible arrangement of singlet and doublet lenses. The

distance between the singlet lens and the doublet lens may be adjusted, and/or the

distance between the LED and the singlet lens may be adjusted, through, for

example, a threaded connection.

11. Additionally, SurgiTel’s illuminator devices may be easily attached to

headware, such as optical loupes or a headband. A representative photograph of a

SurgiTel illuminator device is shown below in photograph A.

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A: SurgiTel Illuminator Device For Medical and Dental Professionals Attached to

Loupes by Way of Attachment Mechanism

12. SurgiTel has taken steps to protect its innovative designs, including its

illuminator devices. In particular, SurgiTel owns various United States utility

patents relating to its illuminator devices. Relevant to this dispute, SurgiTel owns

all right, title and interest in, and has the right to sue and recover for past, present,

and future infringement of, the Patents-in-Suit.

13. On information and belief, without SurgiTel’s authorization, Den-Mat

made, used, offered for sale, sold, and/or imported into the United States illuminator

devices that violate the Patents-in-Suit (the “Infringing Illuminator Devices”). The

Infringing Illuminator Devices include at least products identified by the model

name PeriOptix’s LumiPro LED light, as well as illuminator devices bearing the

same or substantially similar infringing designs, regardless of model name.

14. On information and belief, Dr. Timothy Kosinski is a partner for Den-

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Mat residing in Oakland County, Michigan.

15. On information and belief, Dr. Kosinski practices dentistry at

Smilecreator of Bingham Farms located at 31000 Telegraph Rd #170, Bingham

Farms, MI 48025.

16. A screenshot from Den-Mat’s website (located at

https://www.denmat.com/blog/every-dental-practice-needs-secret-recipe-for-

success.html) reflecting Dr. Kosinski’s affiliation with Den-Mat is shown below in

photograph B.

B: Den-Mat’s Website Promoting Partnership with Dr. Kosinski

17. Dr. Kosinski teaches courses on the use of Den-Mat’s products,

including an upcoming course scheduled for July 16, 2021 in Lansing, Michigan. A

screenshot from Den-Mat’s website (located at

https://www.denmat.com/education/hands-on-

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courses/?event_type=0&event_date=0&state=0) advertising for a hands-on course

taught by Dr. Kosinski is shown below in photograph C.

C: Den-Mat’s Website Advertising Course Taught by Dr. Kosinski

18. On information and belief, Dr. Kosinski is a dentist who has promoted

and used, and currently promotes and uses, illuminator devices from Den-Mat that

infringe the Patents-in-Suit.

19. On information and belief, Den-Mat sells and offers to sell its products,

including the Infringing Illuminator Devices, to third-party retailers through its

wholesale distribution channel.

20. On information and belief, Den-Mat sells and offers to sell the

Infringing Illuminator Devices in the United States, including in Michigan.

21. On information and belief, Den-Mat intended to copy the features

covered by the Patents-in-Suit.

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COUNT I
(Infringement of the ’684 Patent)

22. SurgiTel incorporates by reference and realleges each and every

allegation of Paragraphs 1 through 21 as if set forth herein.

23. The ’684 Patent is entitled “LED Illuminator with Improved Beam

Quality,” and issued November 1, 2011. The application leading to the ’684 Patent

was filed November 23, 2009. A true and correct copy of the ’684 Patent is attached

hereto as Exhibit A and incorporated herein by reference.

24. SurgiTel owns all substantial rights, interest, and title in and to the ’684

Patent, including the sole and exclusive right to prosecute this action and enforce the

’684 Patent against infringers, and to collect damages for all relevant times.

25. The ’684 Patent is valid and enforceable.

26. Direct Infringement. Den-Mat has been and continues to directly

infringe one or more claims of the ’684 Patent in at least this District, either literally

or by the doctrine of equivalents, by making, using, offering to sell, selling and/or

importing, without limitation, at least the Infringing Illuminator Devices, which

infringe at least claim 1 of the ’684 Patent as set forth in the claim chart included as

Exhibit C to this Complaint, which is incorporated herein by reference.

27. Den-Mat also has and continues to directly infringe, either literally or

by the doctrine of equivalents, at least claim 1 of the ’684 Patent by having its

employees internally test and use the Infringing Illuminating Devices.

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28. Actual Knowledge of Infringement. On information and belief, Den-

Mat had actual knowledge of the ’684 Patent at least by January 13, 2021, which is

the date counsel for SurgiTel, Mr. John G. Posa, sent a letter to Mr. Dave Casper,

Chief Executive Officer of Den-Mat, notifying Mr. Casper of Den-Mat’s

infringement of the ’684 Patent. Despite such actual knowledge, Den-Mat continued

to make, use, test, sell, offer for sale, market, and/or import in the United States,

products that infringe the ’684 Patent.

29. On information and belief, Den-Mat has also continued to sell the

Infringing Illuminating Devices and distribute product literature inducing end users

and others to use its products in the customary and intended manner that infringes

the ’684 Patent.

30. Induced Infringement. Den-Mat therefore actively, knowingly, and

intentionally has been and continues to induce infringement of the ’684 Patent, either

literally or by the doctrine of equivalents, by selling the Infringing Illuminating

Devices to its customers for use in a manner that infringes at least claim 1 of the

’684 Patent.

COUNT II
(Infringement of the ’709 Patent)

31. SurgiTel incorporates by reference and realleges each and every

allegation of Paragraphs 1 through 30 as if set forth herein.

32. The ’709 Patent is entitled “LED Illuminator with Improved Beam

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Quality,” and issued March 4, 2014. The application leading to the ’709 Patent was

filed August 24, 2011, and claims priority to, and is a continuation-in-part of, U.S.

Patent Application No. 12/623,470, now the ’684 Patent. A true and correct copy of

the ’709 Patent is attached hereto as Exhibit B and incorporated herein by reference.

33. SurgiTel owns all substantial rights, interest, and title in and to the ’709

Patent, including the sole and exclusive right to prosecute this action and enforce the

’709 Patent against infringers, and to collect damages for all relevant times.

34. The ’709 Patent is valid and enforceable.

35. Direct Infringement. Den-Mat has been and continues to directly

infringe one or more claims of the ’709 Patent in at least this District, either literally

or by the doctrine of equivalents, by making, using, offering to sell, selling and/or

importing, without limitation, at least the Infringing Illuminator Devices, which

infringe at least claim 1 of the ’709 Patent as set forth in the claim chart included as

Exhibit D to this Complaint, which is incorporated herein by reference.

36. Den-Mat also has and continues to directly infringe, either literally or

by the doctrine of equivalents, at least claim 1 of the ’709 Patent by having its

employees internally test and use the Infringing Illuminating Devices.

37. Actual Knowledge of Infringement. On information and belief, Den-

Mat had actual knowledge of the ’709 Patent at least by January 13, 2021, which is

the date counsel for SurgiTel, Mr. John G. Posa, sent a letter to Mr. Dave Casper,

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Chief Executive Officer of Den-Mat, notifying Mr. Casper of Den-Mat’s

infringement of the ’709 Patent. Despite such actual knowledge, Den-Mat continued

to make, use, test, sell, offer for sale, market, and/or import in the United States,

products that infringe the ’709 Patent.

38. On information and belief, Den-Mat has also continued to sell the

Infringing Illuminating Devices and distribute product literature inducing end users

and others to use its products in the customary and intended manner that infringes

the ’709 Patent.

39. Induced Infringement. Den-Mat therefore actively, knowingly, and

intentionally has been and continues to induce infringement of the ’709 Patent, either

literally or by the doctrine of equivalents, by selling the Infringing Illuminating

Devices to its customers for use in a manner that infringes at least claim 1 of the

’709 Patent.

CLAIM FOR RELIEF

(Infringement Under 35 U.S.C. § 271 of the Patents-in-Suit)

40. SurgiTel re-alleges and incorporates by reference the allegations set

forth in paragraphs 1–39 of this Complaint.

41. Den-Mat, without authorization from SurgiTel, has made, used, offered

for sale, sold, and/or imported in or into the United States, and continues to make,

use, offer for sale, sell, and/or import in or into the United States, illuminator devices

that infringe the Patents-in-Suit.

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42. SurgiTel has been and will continue to be irreparably harmed by Den-

Mat’s infringement of the Patents-in-Suit.

WHEREFORE, SurgiTel respectfully requests that the Court grant the

following relief:

1. A judgment that Den-Mat infringed the Patents-in-Suit;

2. A permanent injunction enjoining Den-Mat, and all persons in concert

with Den-Mat, from infringing the Patents-in-Suit;

3. A judgment and order requiring Den-Mat to pay SurgiTel all damages

caused by Den-Mat’s infringement of the Patents-in-Suit (but in no event less than

a reasonable royalty) pursuant to 35 U.S.C. § 284, or the total profit made by Den-

Mat from its infringement of the Patents-in-Suit pursuant to 35 U.S.C. § 289;

4. A judgment and order requiring Den-Mat to pay SurgiTel supplemental

damages or profits for any continuing post-verdict infringement up until entry of the

final judgment, with an accounting, as needed;

5. A judgment and order requiring Den-Mat to pay SurgiTel increased

damages up to three times the amount found or assessed pursuant to 35 U.S.C. §

284;

6. A judgment and order requiring Den-Mat to pay SurgiTel pre-judgment

and post-judgment interest on any damages or profits awarded;

7. A determination that this action is an exceptional case pursuant to 35

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U.S.C. § 285;

8. An award of SurgiTel’s attorneys’ fees for bringing and prosecuting

this action;

9. An award of SurgiTel’s costs and expenses incurred in bringing and

prosecuting this action; and

10. Such further and additional relief as this Court deems just and proper.

DEMAND FOR JURY TRIAL

SurgiTel hereby demands a jury for all issues so triable.

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Date: March 19, 2021 Respectfully submitted,

HONIGMAN LLP

By: /s/ J. Michael Huget

J. Michael Huget (P39150)
315 East Eisenhower Parkway
Suite 100
Ann Arbor, MI 48108-3330
(734) 418-4200
mhuget@honigman.com

Scott Barnett (P82673)

39400 Woodward Ave.
Suite 101
Bloomfield Hills, MI 48304
(248) 566-8416
sbarnett@honigman.com

Of Counsel:

LAW OFFICES OF JOHN G. POSA

John G. Posa (P49445)
2075 W. Stadium Blvd. #1109
Ann Arbor, MI 48106
(734) 355-2005
john@posa.law

Attorneys for Plaintiff

38353221.1
Case 5:21-cv-10617-JEL-DRG ECF No. 1-1, PageID.14 Filed 03/19/21 Page 1 of 1

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF MICHIGAN

GENERAL SCIENTIFIC
CORPORATION d/b/a SURGITEL, Case No. ______________

Plaintiff, JURY TRIAL DEMANDED

v.

DEN-MAT HOLDINGS, LLC

Defendant.

INDEX OF EXHIBITS

EXHIBIT DESCRIPTION
A. U.S. Patent Number 8,047,684

B. U.S. Patent Number 8,662,709

C. Claim Chart ‘684 Patent

D. Claim Chart ‘709 Patent

Case 5:21-cv-10617-JEL-DRG ECF No. 1-2, PageID.15 Filed 03/19/21 Page 1 of 7

EXHIBIT A
Case 5:21-cv-10617-JEL-DRG ECF No. 1-2, PageID.16 Filed 03/19/21 Page 2 of 7

USOO8047684B2

(12) United States Patent (10) Patent No.: US 8,047,684 B2

Chang (45) Date of Patent: Nov. 1, 2011
(54) LED ILLUMINATOR WITH IMPROVED (56) References Cited
BEAM QUALITY
U.S. PATENT DOCUMENTS
(75) Inventor: Byung J. Chang, Ann Arbor, MI (US) 3,745,993 A 7, 1973 Feinbloom
5,042,048 A * 8/1991 Meyer ........................... 372/108
(73) Assignee: General Scientific Corporation, Ann 5,924,234. A * 7/1999 Bindon et al. .................. 42.123
2007/0217198 A1* 9, 2007 Alessio .......... ... 362,268
Arbor, MI (US) 2008/0019011 A1 1/2008 Krineta et al. .. ... 359,641
2009,0059.095 A1* 3, 2009 Hall et al. ..................... 348,744
(*) Notice: Subject to any disclaimer, the term of this * cited by examiner
patent is extended or adjusted under 35
U.S.C. 154(b) by 0 days. Primary Examiner — Laura Tso
(74) Attorney, Agent, or Firm — Gifford, Krass, Sprinkle,
(21) Appl. No.: 12/623,470 Anderson & Citkowski, P.C.
(22) Filed: Nov. 23, 2009 (57) ABSTRACT
An improved illuminator with an adjustable beam pattern to
(65) Prior Publication Data be worn by medical and dental professionals includes a hous
ing, a light-emitting diode (LED) disposed in the housing
US 2011 FO122598 A1 May 26, 2011 outputting light through a distal opening in the housing, an
achromatic doublet lens mounted in the opening in the hous
(51) Int. Cl. ing, and a singlet lens disposed between the LED and the
F2IV5/00 (2006.01) achromatic lens. The distance between the singlet lens and the
(52) U.S. Cl. ......... 362/268; 362/271; 362/273; 362/331 doublet lens may be adjustable, and/or distance between the
LED and the singlet lens may be adjustable, through a
(58) Field of Classification Search .................. 362/268, threaded connections, for example.
362/270, 271, 273, 277, 331, 335,336
See application file for complete search history. 18 Claims, 3 Drawing Sheets

ff O
31 O

322 --

32O
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U.S. Patent Nov. 1, 2011 Sheet 1 of 3 US 8,047,684 B2

108
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U.S. Patent Nov. 1, 2011 Sheet 2 of 3 US 8,047,684 B2

Case 5:21-cv-10617-JEL-DRG ECF No. 1-2, PageID.19 Filed 03/19/21 Page 5 of 7

U.S. Patent Nov. 1, 2011 Sheet 3 of 3 US 8,047,684 B2

...
23.2%
.

ff O
31 O

322

32
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US 8,047,684 B2
1.
LED LLUMINATOR WITH IMPROVED
BEAM QUALITY
FIELD OF THE INVENTION
This invention relates generally to illuminators of the type
worn by medical and dental professionals and, in particular,
to an LED illuminator with multiple optical elements to
improve beam quality
BACKGROUND OF THE INVENTION
The light generated by existing light-emitting diode (LED)
illuminators is quite poor. Current illuminators of this kind
use reflecting optical elements or singlet or multiple lenses
with reflecting optical elements. An example is shown in U.S.
Pat. No. 3,745,993 entitled “Surgical Headlight.” Although
this design discloses anachromatic lens, the light delivered to
it from an optical fiberis reflected off of a mirror. As such, this
and other existing configurations exhibit poor light unifor
mity and/or unacceptable color separation at the edge of
beam.
SUMMARY OF INVENTION
This invention improves upon existing designs by provid
ing an illuminator with an adjustable beam pattern to be worn
by medical and dental professionals, comprising:
The preferred embodiment includes a housing, a light
emitting diode (LED) disposed in the housing outputting light
through a distal opening in the housing, an achromatic dou
blet lens mounted in the opening in the housing, and a singlet
lens disposed between the LED and the achromatic lens.
The distance between the singlet lens and the doublet lens
may be adjustable, and/or distance between the LED and the
singlet lens may be adjustable, through a threaded connec
tions, for example.
BRIEF DESCRIPTION OF THE DRAWINGS
FIG. 1 is a cross section of a preferred embodiment of the
invention;
FIG. 2 is a ray-tracing diagram of the preferred embodi
ment; and
FIG. 3 is a drawing of a housing applicable to the present
invention.
DETAILED DESCRIPTION OF THE INVENTION
This invention resides in an LED illuminator with multiple
optical elements to improve beam quality. As shown in FIG.
1, the preferred embodiment uses one singlet lens 104 and one
achromatic doublet lens 106 (made with one positive and one
negative lens 108, 110). The system is based upon a high
intensity white-emitting LED 100 including an integral lens
102, which may be spherical.
One or both distances A, B can be either fixed or adjustable
for beam pattern or different applications. For typical head
lamp applications. A may be on the order of 6 mm, adjustable
between 4 to 11 mm, while B may be on the order of 4 mm,
adjustable between 2 to 6 mm orthereabouts. The diameter of
the singlet 104 may be in the range of 7 to 10 mm, whereas the
achromatic doublet lens 106 will be on the order of 17 to 20
mm, again for typical headlamp applications. The radius of
the LED lens may be 2.5 mm--/-0.5 mm.
FIG. 3 shows a suitable housing for the preferred optical
assembly. Doublet 108, 110, is disposed in a housing 302;
2
singlet 104 is disposed in housing 304, and LED 102 is
mounted within housing 306. The housings are coupled via
threaded connections 330, 340, with set screws 332, 342
and/or an adhesive being used to fix the relative positions. If
one or both distances are permanently fixed, one or both of the
threaded connections 330, 340 may be eliminated, simplify
ing the housing overall.
The base housing 306 is preferably coupled to a clip-on
type connector 320 through hinge 310. The invention is not
10 limited in this regardinsofar as other attachment mechanisms
may be used. Any materials such as plastic, metal (i.e., alu
minum) may be used for the housing pieces. Heat vents or
sinks (not shown) may also be provided. The cord for the LED
is depicted at 322.
15
I claim:
1. An illuminator of the type worn by medical and dental
professionals, comprising:
a housing:
a light-emitting diode (LED) disposed in the housing out
putting light through a distal opening in the housing:
an achromatic doublet lens mounted in the opening in the
housing:
a singlet lens disposed between the LED and the achro
25 matic lens; and
an attachment mechanism coupled to the housing enabling
the illuminator to be worn as a headlamp.
2. The illuminator of claim 1, wherein the distance between
the singlet lens and the doublet lens is adjustable through a
30 threaded connection.
3. The illuminator of claim 1, wherein the distance between
the LED and the singlet lens is adjustable through a threaded
connection.
4. The illuminator of claim 1, wherein:
35 the distance between the singlet lens and the doublet lens is
adjustable through a threaded connection; and
the distance between the LED and the singlet lens is adjust
able through a different threaded connection.
5. The illuminator of claim 1, wherein the attachment
40 mechanism is a clip-on connector.
6. The illuminator of claim 1, wherein the LED is a white
LED.
7. The illuminator of claim 1, wherein the LED includes an
integral lens.
45 8. The illuminator of claim 1, wherein the LED includes an
integral spherical lens.
9. The illuminator of claim 1, wherein the output light has
a non-collimated, divergent beam pattern.
10. The illuminator of claim 1, wherein:
50 the output light has a non-collimated, divergent beam pat
tern; and
the beam pattern is adjustable through movement of one or
both of the lenses.
11. An illuminator of the type worn by medical and dental
55 professionals, comprising:
a housing having a distal opening:
a light-emitting diode (LED) disposed in the housing:
anachromatic doublet lens mounted in the distal opening;
a singlet lens disposed in the housing between the LED and
60 the achromatic lens;
wherein the lenses output a non-collimated, divergent
beam pattern; and
an attachment mechanism coupled to the housing enabling
the illuminator to be worn as a headlamp.
65 12. The illuminator of claim 11, wherein the distance
between the singlet lens and the doublet lens is adjustable
through a threaded connection.
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US 8,047,684 B2
3 4
13. The illuminator of claim 11, wherein the distance 15. The illuminator of claim 11, wherein the attachment
between the LED and the singlet lens is adjustable through a mechanism is a clip-on connector.
threaded connection. 16. The illuminator of claim 11, wherein the LED is a white
LED.
14. The illuminator of claim 11, wherein: 17. The illuminator of claim 11, wherein the LED includes
the distance between the singlet lens and the doublet lens is an integral lens.
adjustable through a threaded connection; and 18. The illuminator of claim 11, wherein the LED includes
the distance between the LED and the singlet lens is adjust an integral spherical lens.
able through a different threaded connection. k k k k k
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EXHIBIT B
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USOO8662709B2

(12) United States Patent (10) Patent No.: US 8,662,709 B2

Chang (45) Date of Patent: Mar. 4, 2014

(54) LED LLUMINATOR WITH IMPROVED (56) References Cited

BEAM QUALITY U.S. PATENT DOCUMENTS
(75) Inventor: Byung J. Chang, Ann Arbor, MI (US) 3,745,993 A * 7/1973 Feinbloom .................... 600,249
5,042,048 A 8/1991 Meyer
(73) Assignee: General Scientific Corporation, Ann 5,331.357 A * 7/1994 Cooley et al. ................. 351,158
Arbor, MI (US) 5,924,234 A 7/1999 Bindon et al.
6,290,368 B1* 9/2001 Lehrer .......................... 362,187
(*) Notice: Subject to any disclaimer, the term of this 2007/0217198 A1 9, 2007 Alessio
2008, OO19011 A1 1/2008 Krineta et al.
patent is extended or adjusted under 35 2009/0059095 A1 3/2009 Hall, Jr. et al.
U.S.C. 154(b) by 330 days. 2009/0161348 A1* 6/2009 Spartano et al. .............. 362/105
2011/0122598 A1* 5/2011 Chang ............................. 362/33
(21) Appl. No.: 13/216,866
* cited by examiner
(22) Filed: Aug. 24, 2011
Primary Examiner — Laura Tso
(65) Prior Publication Data (74) Attorney, Agent, or Firm — Gifford, Krass, Sprinkle,
Anderson & Citkowski, P.C.
US 2011/0305OO7 A1 Dec. 15, 2011
(57) ABSTRACT
An improved illuminator with an adjustable beam pattern to
Related U.S. Application Data be worn by medical and dental professionals includes a hous
(63) Continuation-in-part of application No. 12/623,470, ing, a light-emitting diode (LED) disposed in the housing
filed on Nov. 23, 2009, now Pat. No. 8,047,684. outputting light through a distal opening in the housing, an
achromatic doublet lens mounted in the opening in the hous
(51) Int. C. ing, and a singlet lens disposed between the LED and the
F2IV5/00 (2006.01) achromatic lens. The distance between the singlet lens and the
(52) U.S. C. doublet lens may be adjustable, and/or distance between the
USPC ............ 362/268; 362/271; 362/273; 362/331
LED and the singlet lens may be adjustable, through a
threaded connections, for example. In the preferred embodi
(58) Field of Classification Search ment, the achromatic doublet lens, the singlet lens, or both the
USPC ............ 362/311.02, 103, 105,106, 268, 331, singlet and the doublet lens have a planar Surface.
362/332, 277,281,319, 449, 455
See application file for complete search history. 18 Claims, 5 Drawing Sheets

f 10

322 --
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US 8,662,709 B2
1.
LED LLUMINATOR WITH IMPROVED
BEAM QUALITY
REFERENCE TO RELATED APPLICATIONS
This patent application is a Continuation-in-Part of U.S.
patent application Ser. No. 12/623,470, filed Nov. 23, 2009,
the entire content of which is incorporated herein by refer
CCC.
FIELD OF THE INVENTION
This invention relates generally to illuminators of the type
worn by medical and dental professionals and, in particular,
to an LED illuminator with multiple optical elements to
improve beam quality
BACKGROUND OF THE INVENTION
The light generated by existing light-emitting diode (LED)
illuminators is quite poor. Current illuminators of this kind
use reflecting optical elements or singlet or multiple lenses
with reflecting optical elements. An example is shown in U.S.
Pat. No. 3,745,993 entitled “Surgical Headlight.” Although
this design discloses anachromatic lens, the light delivered to
it from an optical fiberis reflected off of a mirror. As such, this
and other existing configurations exhibit poor light unifor
mity and/or unacceptable color separation at the edge of
beam.
SUMMARY OF INVENTION
This invention improves upon existing designs by provid
ing an illuminator with an adjustable beam pattern to be worn
by medical and dental professionals. The preferred embodi
ments include a housing, a light-emitting diode (LED) dis
posed in the housing outputting light through a distal opening
in the housing, an achromatic doublet lens mounted in the
opening in the housing, and a singlet lens disposed between
the LED and the achromatic lens.
The distance between the singlet lens and the doublet lens
may be adjustable, and/or distance between the LED and the
singlet lens may be adjustable, through a threaded connec
tions, for example. In the preferred embodiment, the achro
matic doublet lens, the singlet lens, or both the singlet and the
doublet lens have a planar Surface.
BRIEF DESCRIPTION OF THE DRAWINGS
FIG. 1 is a cross section of an embodiment of the invention;
FIG. 2 is a ray-tracing diagram of the embodiment of FIG.
1;
FIG. 3 is a drawing of a housing applicable to the present
invention;
FIG. 4 is a cross section of a preferred embodiment of the
invention; and
FIG. 5 is a ray-tracing diagram of the embodiment of FIG.
4.
DETAILED DESCRIPTION OF THE INVENTION
This invention resides in an LED illuminator with multiple
optical elements to improve beam quality. All embodiments
include a housing with an LED source, a singlet lens Sup
ported in front of the LED, and anachromatic doublet lens in
2
position where the light exits the housing. An attachment
mechanism is coupled to the housing, enabling the illumina
tor to be worn as a headlamp.
One embodiment, shown in FIG. 1, uses a singlet lens 104
and an achromatic doublet lens 106 made with one positive
and one negative lens elements 108, 110. This and the other
embodiments disclosed herein are based upon a high-inten
sity white-emitting LED 100 including an integral lens 102.
which may be spherical.
10 One or both distances A, B in FIG. 1 can be either fixed or
adjustable for beam pattern or different applications. For
typical headlamp applications. A may be on the order of 6
mm, adjustable between 4 to 11 mm, while B may be on the
order of 4 mm, adjustable between 2 to 6 mm or thereabouts.
15 The diameter of the singlet 104 may be in the range of 7 to 10
mm, whereas the achromatic doublet lens 106 will be on the
order of 17 to 20 mm, again for typical headlamp applica
tions. The radius of the LED lens may be 2.5 mm +/- 0.5 mm.
FIG. 3 shows a suitable housing for the preferred optical
assembly. Doublet 108, 110, is disposed in a housing 302;
singlet 104 is disposed in housing 304, and LED 102 is
mounted within housing 306. The housings are coupled via
threaded connections 330, 340, with set screws 332, 342
and/or an adhesive being used to fix the relative positions. If
25 one or both distances are permanently fixed, one or both of the
threaded connections 330, 340 may be eliminated, simplify
ing the housing overall.
The base housing 306 is preferably coupled to a clip-on
type connector 320 through hinge 310. The invention is not
30 limited in this regardinsofar as other attachment mechanisms
may be used. Any materials such as plastic, metal (i.e., alu
minum) may be used for the housing pieces. Heat vents or
sinks (not shown) may also be provided. The cord for the LED
is depicted at 322.
35 FIG. 4 is a cross section of a preferred embodiment of the
invention, and FIG. 5 is a ray-tracing diagram of the embodi
ment of FIG. 4. In this configuration, one or both of the singlet
lens 402 and doublet lens 404 includes a planar surface (i.e.,
surfaces 403, 405), resulting in a configuration which is more
40 compact that the embodiment of FIGS. 1, 2. FIG. 4 provides
typical lens diameters, dimensions and weights for a medical/
dental illuminator with the understanding that these values
represent one combination of many. The optical elements of
FIGS. 4, 5 would be mounted in a housing comparable to that
45 shown in FIG. 3. An aperture stop is optionally provided to
beam pattern with a desired shape Such as round.
I claim:
1. An illuminator of the type worn by medical and dental
professionals, comprising:
50 a housing:
a light-emitting diode (LED) disposed in the housing out
putting light through a distal opening in the housing:
an achromatic doublet lens mounted in the opening in the
housing:
55 a singlet lens disposed between the LED and the achro
matic lens;
an attachment mechanism coupled to the housing enabling
the illuminator to be worn as a headlamp; and
wherein the achromatic doublet lens, the singlet lens, or
60 both the singlet and the doublet lens have a planar sur
face.
2. The illuminator of claim 1, wherein the distance between
the singlet lens and the doublet lens is adjustable through a
threaded connection.
65 3. The illuminator of claim 1, wherein the distance between
the LED and the singlet lens is adjustable through a threaded
connection.
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US 8,662,709 B2
3 4
4. The illuminator of claim 1, wherein:
the distance between the singlet lens and the doublet lens is
adjustable through a threaded connection; and
the distance between the LED and the singlet lens is adjust
able through a different threaded connection.
5. The illuminator of claim 1, wherein the attachment
mechanism is a clip-on connector.
6. The illuminator of claim 1, wherein the LED is a white
LED.
7. The illuminator of claim 1, wherein the LED includes an
integral lens.
8. The illuminator of claim 1, wherein the LED includes an
integral spherical lens.
9. The illuminator of claim 1, wherein the output light has
a non-collimated, divergent beam pattern.
10. The illuminator of claim 1, wherein:
the output light has a non-collimated, divergent beam pat
tern; and
the beam pattern is adjustable through movement of one or
both of the lenses.
11. An illuminator of the type worn by medical and dental
professionals, comprising:
a housing having a distal opening:
a light-emitting diode (LED) disposed in the housing:
an achromatic doublet lens mounted in the distal opening:
a singlet lens disposed in the housing between the LED and
the achromatic lens;
wherein the achromatic doublet lens, the singlet lens, or
both the singlet and the doublet lens have a planar sur
face;
wherein the lenses output a non-collimated, divergent
beam pattern; and
an attachment mechanism coupled to the housing enabling
the illuminator to be worn as a headlamp.
12. The illuminator of claim 11, wherein the distance
between the singlet lens and the doublet lens is adjustable
10 through a threaded connection.
13. The illuminator of claim 11, wherein the distance
between the LED and the singlet lens is adjustable through a
threaded connection.
14. The illuminator of claim 11, wherein:
15 the distance between the singlet lens and the doublet lens is
adjustable through a threaded connection; and
the distance between the LED and the singlet lens is adjust
able through a different threaded connection.
15. The illuminator of claim 11, wherein the attachment
mechanism is a clip-on connector.
16. The illuminator of claim 11, wherein the LED is a white
LED.
17. The illuminator of claim 11, wherein the LED includes
an integral lens.
25 18. The illuminator of claim 11, wherein the LED includes
an integral spherical lens.
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EXHIBIT C
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Claim 1 of PeriOptix’s LumiPro LED light (“Accused Product”)

U.S. Patent No. 8,047,684

1. An illuminator of the The Accused Product is an illuminator of the type worn by

type worn by medical and medical and dental professionals:
dental professionals,
comprising:

a housing; The Accused Product includes a housing:

a light-emitting diode The Accused Product includes an LED disposed in the

(LED) disposed in the housing outputting light through a distal opening in the
housing outputting light housing:
through a distal opening in
the housing;
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an achromatic doublet The Accused Product includes an achromatic doublet lens

lens mounted in the mounted in the opening in the housing:
opening in the housing;

a singlet lens disposed In the Accused Product, a singlet lens is disposed between
between the LED and the the LED and the achromatic lens (not visible in this view
achromatic lens; and but present in the Accused Product):

an attachment mechanism The Accused Product includes an attachment mechanism

coupled to the housing coupled to the housing enabling the illuminator to be worn
enabling the illuminator to as a headlamp:
be worn as a headlamp.
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EXHIBIT D
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Claim 1 of PeriOptix’s LumiPro LED light (“Accused Product”)

U.S. Patent No. 8,662,709

1. An illuminator of the The Accused Product is an illuminator of the type worn by

type worn by medical and medical and dental professionals:
dental professionals,
comprising:

a housing; The Accused Product includes a housing:

a light-emitting diode The Accused Product includes an LED disposed in the

(LED) disposed in the housing outputting light through a distal opening in the
housing outputting light housing:
through a distal opening in
the housing;
Case 5:21-cv-10617-JEL-DRG ECF No. 1-5, PageID.37 Filed 03/19/21 Page 3 of 4

an achromatic doublet The Accused Product includes an achromatic doublet lens

lens mounted in the mounted in the opening in the housing:
opening in the housing;

a singlet lens disposed In the Accused Product, a singlet lens is disposed between
between the LED and the the LED and the achromatic lens (not visible in this view
achromatic lens; but present in the Accused Product):

an attachment mechanism The Accused Product includes an attachment mechanism

coupled to the housing coupled to the housing enabling the illuminator to be worn
enabling the illuminator to as a headlamp:
be worn as a headlamp;
and
Case 5:21-cv-10617-JEL-DRG ECF No. 1-5, PageID.38 Filed 03/19/21 Page 4 of 4

wherein the achromatic In the Accused Product, the achromatic doublet lens, the
doublet lens, the singlet singlet lens, or both the singlet and the doublet lens have a
lens, or both the singlet planar surface:
and the doublet lens have
a planar surface.