DCT
2:22-cv-08575
Chauvet Sons LLC v. Jmaz Group Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Chauvet & Sons, LLC (Delaware)
- Defendant: JMAZ Group, Inc. (California)
- Plaintiff’s Counsel: Akerman LLP
- Case Identification: 2:22-cv-08575, C.D. Cal., 11/23/2022
- Venue Allegations: Venue is alleged to be proper because the Defendant is a California corporation that resides in the Central District of California.
- Core Dispute: Plaintiff alleges that Defendant’s "Versa Flex Bar" portable lighting system infringes a patent related to configurable, multi-function lighting systems.
- Technical Context: The technology relates to the professional and consumer lighting market for events, such as those managed by mobile DJs, where integrated, portable, and customizable lighting solutions are commercially valuable.
- Key Procedural History: The complaint alleges that Plaintiff notified Defendant of the patent-in-suit on or before August 2, 2022, a fact that may be used to support allegations of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2015-02-02 | U.S. Patent No. 10,094,542 Priority Date |
| 2018-10-09 | U.S. Patent No. 10,094,542 Issued |
| 2022-08-02 | Alleged pre-suit notice to Defendant |
| 2022-11-23 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,094,542 - "Portable Multi-Function Lighting System"
The Invention Explained
- Problem Addressed: The patent describes the difficulty, cost, and time associated with transporting, setting up, and programming many different types of lights for events at remote locations or venues without permanent lighting installations (’542 Patent, col. 1:39-48).
- The Patented Solution: The invention is a modular lighting apparatus built around a central "mounting light bar." This bar contains its own integrated light sources (e.g., strobes) within a hollow cavity and also functions as a power and data bus for additional, externally mounted light fixtures. This design allows a user to easily transport, assemble, and customize a variety of lighting effects from a single, reconfigurable unit (’542 Patent, Abstract; col. 3:40-55).
- Technical Importance: This integrated approach addresses a need in the event production market for portable, all-in-one lighting systems that offer flexibility and reduce setup complexity (’542 Patent, col. 2:1-11).
Key Claims at a Glance
- The complaint asserts infringement of at least independent Claim 1 (’542 Patent, col. 8:14-40; Compl. ¶19).
- The essential elements of independent Claim 1 are:
- A mounting light bar with an internal cavity and an opening on its face.
- At least one light source mounted inside the cavity, providing a first lighting effect through the opening.
- At least one light fixture removably secured to the bar outside the cavity, providing a second, different lighting effect.
- At least a second light fixture removably secured to the bar outside the cavity, providing a third lighting effect different from the first and second effects.
- A power source within the internal cavity that provides power to the internal light source(s) and the external light fixture(s).
- The complaint also references numerous dependent claims and implicitly reserves the right to assert them (Compl. ¶¶25-28).
III. The Accused Instrumentality
Product Identification
The accused instrumentality is the "Versa Flex Bar" and associated JMAZ products (Compl. ¶18).
Functionality and Market Context
The complaint describes the Versa Flex Bar as a "portable, multi-function lighting apparatus" and an "all in one lighting solution" (Compl. ¶20). It is alleged to feature a central mounting bar with built-in lights, as well as the capability to have external, removable light fixtures attached (Compl. ¶21, ¶23). The complaint includes a product image showing a horizontal bar with integrated lights and two larger, externally mounted fixtures (Compl. ¶21, p. 4). A second image shows the product's control panel, illustrating its user-programmable features (Compl. ¶27, p. 6). The complaint alleges that the Versa Flex Bar is a direct competitor to Plaintiff's own "DJ GigBar line of products" (Compl. ¶15).
IV. Analysis of Infringement Allegations
'542 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a mounting light bar extending longitudinally and having an internal cavity and at least one opening formed in an outer surface of a longitudinally extending face... | The Versa Flex Bar is alleged to comprise a mounting light bar with an internal cavity and multiple openings on its face through which light projects. | ¶21 | ’542 Patent, col. 3:56-62 |
| at least one light source providing a first lighting effect mounted within the internal cavity in alignment with said at least one opening... | The product allegedly includes multiple light sources, such as "twelve white lights," mounted within the internal cavity to provide a first lighting effect. | ¶22 | ’542 Patent, col. 3:62-65 |
| at least one light fixture removably secured to the mounting light bar outside said internal cavity and providing a second lighting effect different from the first... | The product's "basic" configuration is alleged to include at least two moving light fixtures that are removably secured to the bar outside the internal cavity. | ¶23 | ’542 Patent, col. 8:26-30 |
| at least a second light fixture removably secured to the mounting light bar outside said internal cavity and providing a third lighting effect different from the first and second... | The complaint alleges the "basic" configuration includes at least two external fixtures and that additional, optional fixtures are offered for a third lighting effect. | ¶23-24 | ’542 Patent, col. 8:31-35 |
| a power source mounted within the internal cavity providing power to at least one of said at least one light source, said at least one light fixture or...a second light fixture. | The product allegedly has a power source inside the bar's cavity that powers both the internal light sources and the external, removable fixtures. | ¶25 | ’542 Patent, col. 8:36-40 |
Identified Points of Contention
- Scope Questions: Claim 1 requires a "third lighting effect different from the first and second lighting effects," which is provided by a "second light fixture." The complaint alleges the base product includes "at least two moving light fixtures" (Compl. ¶23) and that other optional fixtures are available (Compl. ¶24). This raises the question of whether the base product itself meets this limitation, or if infringement requires the combination of the base product with separately sold optional fixtures.
- Technical Questions: What evidence will be presented to establish that the "second lighting effect" and "third lighting effect" are, in fact, "different" from each other and from the "first lighting effect" as required by the claim? The analysis may depend on the technical definitions of lighting effects (e.g., strobe, wash, spot, laser).
V. Key Claim Terms for Construction
"different from the first and second lighting effects"
- Context and Importance: The construction of this phrase is central to the dispute. Infringement of Claim 1 hinges on the accused product providing three distinct lighting effects from its combination of internal and external lights. Practitioners may focus on this term because the complaint's allegations could be interpreted to mean the two external fixtures in the base product are identical, which raises the question of how they could produce two "different" effects (a second and a third).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification distinguishes between multiple types of lights, such as "strobe lights," "tri-color LED wash light fixtures," "LED derby light fixtures," and a "laser light device" (’542 Patent, col. 3:62-63, col. 4:41-43, col. 4:56-58). This could support an interpretation where different categories of fixtures inherently produce "different" effects.
- Evidence for a Narrower Interpretation: A party could argue that "different" requires a fundamental distinction in the type of illumination (e.g., wash vs. spot) or technology (e.g., LED vs. laser), and not merely different colors or patterns produced by fixtures of the same underlying type.
"removably secured"
- Context and Importance: The modular and reconfigurable nature of the claimed invention depends on the external fixtures being "removably secured." The definition will determine what kind of attachment mechanism qualifies.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests multiple attachment methods beyond the preferred embodiment, stating fixtures "may snap into holes... or may slide to discrete locations in a track" (’542 Patent, col. 4:13-16). This language could support a construction that is not limited to a specific type of fastener.
- Evidence for a Narrower Interpretation: The preferred embodiment consistently describes the use of "threaded knob screws" for securing fixtures, which implies tool-less or simple user-level removal (’542 Patent, col. 4:12, 4:24, 4:26). This could be used to argue for a narrower construction that requires easy, user-level removability.
VI. Other Allegations
Indirect Infringement
The complaint alleges both induced and contributory infringement (Compl. ¶29). Inducement is based on allegations that JMAZ provides instructions and videos that encourage customers to use the Versa Flex Bar in an infringing manner (Compl. ¶30). Contributory infringement is alleged on the basis that the Versa Flex Bar is a material part of the invention, is not a staple article of commerce, and is sold with knowledge of its infringing use (Compl. ¶31).
Willful Infringement
The complaint alleges willful infringement based on Defendant's alleged continued infringement after receiving notice of the ’542 Patent via correspondence on or before August 2, 2022 (Compl. ¶13, ¶16, ¶32).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim scope and product configuration: Does the "Versa Flex Bar" in its standard, "out-of-the-box" configuration meet all limitations of Claim 1, specifically the requirement for three "different" lighting effects? Or does Plaintiff's infringement case depend on a theory of indirect infringement, where an end-user must purchase additional, optional fixtures to create the claimed combination?
- A key evidentiary question will be one of technical definition: How will the parties and the court define a "lighting effect," and what technical evidence will be required to prove that the effects produced by the accused product are "different" from one another in the manner required by the patent's claims?