DCT
2:17-cv-05648
Snap Light LLC v. Kimsaprincess Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Snap Light, LLC (d.b.a., Snaplight) (California)
- Defendant: Kimsaprincess Inc. (California); Urban Outfitters, Inc. (Pennsylvania)
- Plaintiff’s Counsel: San Diego IP Law Group LLP
- Case Identification: 2:17-cv-05648, C.D. Cal., 07/31/2017
- Venue Allegations: Venue is alleged based on Kimsaprincess residing in the district and both defendants allegedly conducting continuous business, committing acts of patent infringement, and purposefully directing activities at residents within the Central District of California. For Urban Outfitters, venue is additionally based on its operation of retail stores constituting a regular and established place of business in the district.
- Core Dispute: Plaintiff alleges that Defendants’ sale and endorsement of LuMee brand smartphone cases infringes a patent related to an integrated lighting accessory and case for a mobile phone device.
- Technical Context: The technology concerns accessories for mobile phones, specifically protective cases that incorporate an independent, diffused lighting system to improve the quality of photographs and videos, particularly self-portraits ("selfies").
- Key Procedural History: The complaint states that Plaintiff Snaplight has exclusive rights to the patent-in-suit via a license agreement with the inventor, Hooshmand Harooni, who is named as an involuntary plaintiff due to an unwillingness to participate in the litigation. The existence of an involuntary plaintiff who owns the patent may raise questions for the court regarding Snaplight's standing to sue independently.
Case Timeline
| Date | Event |
|---|---|
| 2012-01-20 | '644 Patent Priority Date (Filing Date) |
| 2013-04-23 | '644 Patent Issue Date |
| During 2015 | Accused Product promotions allegedly begin on social media |
| Early 2016 | Official partnership between LuMee and Ms. West allegedly begins |
| 2017-01-31 | Effective date of exclusive license agreement between Harooni and Snaplight |
| 2017-07-31 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,428,644 - "Integrated Lighting Accessory and Case for a Mobile Phone Device" (Issued April 23, 2013)
The Invention Explained
- Problem Addressed: The patent's background section notes that the built-in lights on many mobile phones provide illumination that is not "diffused sufficiently or not dispersed enough to be an appropriate lighting source for professional photography/videography purposes" (’644 Patent, col. 1:28-34).
- The Patented Solution: The invention is a protective mobile phone case with an integrated "ring of Light Emitting Diode (LED) lights" that is independently powered by a portable source within the case (’644 Patent, Claim 1). To solve the problem of harsh lighting, each individual LED light is "covered by a frosted or softening lens" to create a "significantly enhanced light source" suitable for photography by providing diffused illumination (’644 Patent, col. 1:33-37; Claim 1).
- Technical Importance: The invention aims to provide users with a portable, integrated tool for creating professional-quality, evenly-lit photographs and videos using a mobile device, overcoming the lighting limitations of the phone itself (’644 Patent, col. 1:28-37).
Key Claims at a Glance
- The complaint asserts independent Claim 1 (Compl. ¶27).
- The essential elements of Claim 1 include:
- An "Integrated Lighting Accessory and Case for a mobile phone device."
- An "integrated ring of Light Emitting Diode (LED) lights" to provide illumination.
- "embedded electronic circuitry" and a "portable power source" to power the LEDs.
- The ring of LED lights is "mounted in a recessed manner" and each light is "covered by a lens to provide for diffusion of the illumination."
- A "separate docking port" or an extended native port, with an "additional port" for power and programmability of the lights.
- The light ring provides a "diffused light source to be used in conjunction with professional photography and/or videography."
- The complaint reserves the right to assert other claims upon completion of discovery and claim construction (Compl. ¶28).
III. The Accused Instrumentality
Product Identification
The accused products are "LuMee branded cases such as the LuMee Duo and LuMee Two" (Compl. ¶16).
Functionality and Market Context
The complaint describes the accused products as "smartphone cases that provide bright, even lighting for capturing photos or video" (Compl. ¶3). The complaint includes a photograph from a social media post showing a smartphone case with two vertical strips of lights integrated into its front face, which is being used to take a selfie (Compl. p. 2). This visual depicts the accused case providing frontal illumination for the user (Compl. p. 2). The complaint alleges that the products have gained significant market traction due to endorsements by celebrity Kim Kardashian West, who is described as an "official' partner with LuMee" (Compl. ¶¶ 2, 5, 29).
IV. Analysis of Infringement Allegations
’644 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an Integrated Lighting Accessory and Case for a mobile phone device | The Accused Products are identified as LuMee branded smartphone cases, including the LuMee Duo and LuMee Two. | ¶16 | col. 4:41-43 |
| an integrated ring of Light Emitting Diode (LED) lights in the case...to provide an illumination to be used in conjunction with functionality native to the phone device | The Accused Products are described as cases that "provide bright, even lighting for capturing photos or video" and are used to take "selfies." | ¶3, ¶22 | col. 4:44-49 |
| the base part embedded electronic circuitry in the case with a portable power source that provides the ability to illuminate the LEDs simultaneously or selectively | The complaint's description of the cases providing "bright, even lighting" implies the existence of an internal power source and control circuitry. | ¶3 | col. 4:50-53 |
| the ring of LED lights are mounted in a recessed manner in the case, with each LED light being covered by a lens to provide for diffusion of the illumination | The allegation that the Accused Products provide "even lighting" suggests the light is diffused, which the patent teaches is achieved with a lens. | ¶3 | col. 4:54-57 |
| the protective case house a separate docking port and/or extend the docking port native to the mobile phone device...wherein an additional port used to provide power and programmability to the LED lights | The complaint does not provide sufficient detail for analysis of the Accused Products' docking or charging port configuration. | N/A | col. 4:58-65 |
| further, the LED light ring illuminated to provide a diffused light source to be used in conjunction with professional photography and/or videography | The complaint alleges the Accused Products provide "bright, even lighting for capturing photos or video" and improve selfies, directly linking the light source to photography. | ¶3, ¶25 | col. 4:65-68 |
Identified Points of Contention
- Scope Questions: A primary question will be whether the term "ring of...lights," which the patent figures depict as a continuous rectangular loop, can be interpreted to read on the accused LuMee cases, which appear to feature two separate vertical strips of lights on the case's face.
- Technical Questions: The complaint alleges "even lighting," but provides no specific evidence that the accused products achieve this through a "lens to provide for diffusion" or that the lights are "mounted in a recessed manner" as required by the claim. The actual physical construction of the accused products will be a central factual issue. The complaint is also silent on whether the accused products meet the specific limitations related to a "separate docking port" and an "additional port" for programmability.
V. Key Claim Terms for Construction
"ring of Light Emitting Diode (LED) lights"
- Context and Importance: The construction of this term appears dispositive for literal infringement. If "ring" is construed narrowly to require a continuous, enclosing loop of lights, the accused products with their two parallel light strips may not infringe. Practitioners may focus on this term because the visual evidence in the complaint suggests a potential mismatch with the patent's embodiments.
- Intrinsic Evidence for a Broader Interpretation: A party could argue that the specification does not explicitly define "ring" and that the term should be given its plain meaning in the context of the invention, which is to surround a subject (the user's face) with light, a function arguably performed by two parallel strips.
- Intrinsic Evidence for a Narrower Interpretation: The patent figures, such as Figure 5, consistently depict the lights (502) arranged in a complete, unbroken rectangular formation (501) (’644 Patent, Fig. 5). A party could argue that these consistent depictions limit the term "ring" to such an enclosing configuration.
"covered by a lens to provide for diffusion"
- Context and Importance: This limitation defines a key technical feature that allegedly solves the problem of harsh, non-professional lighting from standard phone flashes. Infringement will depend on whether the material covering the LEDs on the accused products qualifies as a "lens" and performs "diffusion."
- Intrinsic Evidence for a Broader Interpretation: The specification provides an example of a "frosted or softening lens," which could suggest that "lens" is not limited to a traditional optical element but can include any translucent material that scatters light to achieve the stated purpose of diffusion (’644 Patent, col. 1:33-34).
- Intrinsic Evidence for a Narrower Interpretation: A party may argue that the term "lens" implies a component with specific optical properties designed to refract or redirect light, not merely a protective plastic cover. The claim's specific functional requirement—"to provide for diffusion"—may require a particular degree or quality of light scattering that must be proven.
VI. Other Allegations
Indirect Infringement
The complaint alleges inducement of infringement, stating that Defendant Kimsaprincess, through Ms. West, "has encouraged her followers, family, and friends to purchase and/or use the Accused Products" through promotions on television and social media (Compl. ¶¶ 21, 23).
Willful Infringement
The complaint alleges that "Defendants are aware of the ‘644 patent" and that this awareness existed "prior to the filing of this lawsuit" (Compl. ¶17). The complaint does not specify the basis or timing of this alleged pre-suit knowledge.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the claim term "ring of...lights," which is depicted in the patent as a continuous rectangular loop, be construed to cover the two parallel light strips of the accused LuMee cases?
- A key evidentiary question will be one of technical implementation: what evidence will demonstrate that the accused products' lighting system includes a "lens to provide for diffusion" and is mounted in a "recessed manner" as specifically required by Claim 1, details not explicitly described in the complaint?
- A threshold procedural question may concern plaintiff's standing: given that the patent owner is an "involuntary plaintiff," the court may need to scrutinize the exclusive license agreement to determine if it transferred sufficient rights for Snaplight to bring this infringement suit independently.