DCT

2:24-cv-04379

Chengdu Ruihan Yongtai Trading Co Ltd v. Aaron Chien

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Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:24-cv-04379, C.D. Cal., 11/07/2024
  • Venue Allegations: Venue is based on the individual defendants’ residence within the Central District of California and Defendant Jasco’s alleged purposeful direction of business activities into the district, including sales, licensing, and enforcement of the patent-in-suit.
  • Core Dispute: Plaintiffs, sellers of decorative lighting products, seek a declaratory judgment that their "Astronaut" themed LED light projectors do not infringe U.S. Patent No. 9,719,654, and that the patent is invalid and unenforceable.
  • Technical Context: The dispute involves the field of decorative light projectors, which use LEDs and/or lasers in combination with optics to project images such as stars, nebulas, and other patterns onto surfaces like walls and ceilings.
  • Key Procedural History: The complaint alleges that this declaratory judgment action was filed after Defendants reported Plaintiffs’ products to Amazon.com for patent infringement, initiating Amazon’s Patent Evaluation Express (APEX) procedure. The complaint also includes a count for unenforceability based on alleged inequitable conduct, asserting that the inventor intentionally failed to disclose his own material prior art to the U.S. Patent and Trademark Office during prosecution.

Case Timeline

Date Event
2013-09-11 ’654 Patent Priority Date
2017-08-01 ’654 Patent Issue Date
2024-03-27 Approximate date of Amazon.com infringement notice emails to Plaintiffs
2024-05-20 Defendants allegedly submitted infringement arguments in APEX proceeding
2024-11-07 Complaint Filing Date

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 9,719,654 - "LED AND/OR LASER LIGHT HAS MORE THAN ONE OPTICS MEANS TO CREATE WIDER OR BIG AREAS IMAGE"

The Invention Explained

  • Problem Addressed: The patent’s background section describes prior art image projectors as often being bulky, high-cost, and noisy due to the inclusion of motors. It also notes that wired devices can present a tripping hazard, while battery-powered units require frequent battery changes. (’654 Patent, col. 1:7-41).
  • The Patented Solution: The invention is a compact light projection device that uses at least one light source (LED or laser) and "more than one optical element" to create a large-area image projection. (’654 Patent, Abstract). As described in the specification and illustrated in figures, light beams from the source first interact with a "first optical element" (e.g., an inner lens or reflector) and are then processed by a "second optical element" (e.g., an outer cover or dome) before being projected onto an external surface, with the goal of creating a "wider range or bigger size of image." (’654 Patent, Abstract; Fig. 1; col. 7:39-48).
  • Technical Importance: This multi-element optical design purports to enable the creation of complex and wide-angle visual effects from a simple, low-cost, plug-in device without requiring the complex mechanics of traditional projectors. (’654 Patent, col. 1:12-20).

Key Claims at a Glance

  • The complaint seeks a declaration of non-infringement and invalidity of all claims, with specific non-infringement arguments directed at language found in independent claims 1, 9, and 10. (Compl. ¶¶27-30).
  • Independent Claim 1 recites the core elements of the invention:
    • An LED and/or laser light device comprising at least one LED and/or laser light;
    • More than one optical element with reflective and/or refractive properties;
    • Wherein the optical elements include at least one first optical element and at least one second optical element;
    • And wherein light beams are reflected and/or refracted by the first optical element before passing through the second optical element to create a wider or bigger image for projection. (’654 Patent, col. 11:60–col. 12:15).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies the "Mooyran Astronaut LED" and the "SFOUR Astronaut LED" as the Accused Products. (Compl. ¶¶12-14). These are named “Star Projector Galaxy Night Light - Astronaut Space Projector, Starry Nebula Ceiling LED Lamp with Timer and Remote.” (Compl. ¶¶12-13).

Functionality and Market Context

  • The Accused Products are described as "LED light projector[s] in the shape of an astronaut" sold by Plaintiffs on Amazon.com. (Compl. ¶¶11-13).
  • The complaint does not provide a technical description of the internal components or optical workings of the Accused Products.
  • It is alleged that the Accused Products are commercially successful and that California represents the Plaintiffs’ largest market. (Compl. ¶¶11, 21).

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

This is a declaratory judgment action for non-infringement. The analysis below summarizes Plaintiffs’ asserted grounds for why their products do not infringe. The complaint does not provide a detailed claim chart but instead makes narrative arguments against specific claim limitations.

’654 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Non-Infringing Functionality Complaint Citation Patent Citation
more than one optical element... includes at least one first optical element arranged to reflect, refract, enlarge shape, and/or diffuse light beams... and at least one second optical element arranged to reflect, refract, enlarge, shape, and/or diffuse an image formed by the light beams from the first optical element The complaint alleges that the Accused Products do not satisfy this limitation, among others in claims 1-8. It does not specify the structure of the Accused Products. ¶27 col. 12:1-8
wherein light beams emitted by the at least one LED and/or laser light are reflected and/or refracted by the at least one first optical element before traveling or passing through the at least one second optical element to create a wider range or bigger size of image for projection... The complaint alleges that the Accused Products do not satisfy this limitation. ¶27 col. 12:9-15

Identified Points of Contention

  • Structural Questions: The central point of contention is structural: do the Accused Products, in fact, contain "more than one optical element" that functions sequentially as claimed? The complaint asserts they do not but provides no technical evidence, such as a product teardown or optical diagram, to support this assertion. This raises the question of what the actual optical architecture of the Accused Products is.
  • Scope Questions: The dispute will likely involve the scope of "first optical element" and "second optical element." A key question is whether these terms require two physically distinct and separate components, as depicted in certain patent figures, or if they could be read more broadly to cover different functional surfaces on a single, integrated optical component.

V. Key Claim Terms for Construction

  • The Term: "first optical element" / "second optical element"
  • Context and Importance: These terms define the fundamental two-stage architecture of the claimed invention. The Plaintiffs' non-infringement position appears to hinge on a finding that their products lack this specific structure. (Compl. ¶27). The construction of these terms will therefore be critical to determining whether there is a literal correspondence between the claim language and the accused devices.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claims define the elements functionally (e.g., an element "arranged to reflect, refract, enlarge, shape, and/or diffuse..."). (’654 Patent, col. 12:1-8). Parties arguing for a broader scope may contend that any two distinct optical surfaces performing these functions in the specified sequence meet the limitation, regardless of whether they are part of a single physical component.
    • Evidence for a Narrower Interpretation: The patent’s detailed description and figures repeatedly illustrate the "first" and "second" optical elements as physically separate parts. For example, Figure 1 depicts an "inner optics means" (3) and a distinct "top cover" (7). (’654 Patent, col. 7:39-43). Parties arguing for a narrower scope may point to these embodiments as defining the terms to mean physically separate and non-integral components.

VI. Other Allegations

  • Invalidity and Unenforceability: In addition to non-infringement, Plaintiffs seek a declaration that the ’654 Patent is invalid for failing to meet the conditions of patentability under 35 U.S.C. §§ 101, 102, 103, and/or 112. (Compl. ¶32). The complaint further alleges that the patent is unenforceable due to inequitable conduct. (Compl. ¶35). The basis for this allegation is the inventor’s and/or prosecution counsel’s alleged intentional failure to disclose material prior art to the patent office, specifically identifying the inventor’s own earlier U.S. Patent No. 7,832,917 and two of his own prior patent applications. (Compl. ¶36).

VII. Analyst’s Conclusion: Key Questions for the Case

  • A central issue will be one of structural correspondence: Do the Accused Products employ the two-stage optical pathway recited in the claims? Resolution will depend on factual evidence regarding the internal construction of the "Astronaut" projectors, which is not detailed in the complaint.
  • The case presents a significant question of patent unenforceability: Did the inventor's failure to disclose his own, potentially material, prior art during prosecution rise to the level of inequitable conduct? This will turn on judicial findings regarding both the materiality of the undisclosed references and the applicant's specific intent to deceive the USPTO.
  • A key legal question will be one of claim construction: Can the terms "first optical element" and "second optical element" be construed to cover different functional regions of a single component, or are they limited to the physically separate components illustrated in the patent’s preferred embodiments?