DCT
2:24-cv-06364
Infinity X1 LLC v. Alliance Sports Group LP
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Infinity X1, LLC (Nevada)
- Defendant: Alliance Sports Group, L.P. (Texas)
- Plaintiff’s Counsel: Jeffer Mangels Butler & Mitchell LLP
- Case Identification: 2:24-cv-06364, C.D. Cal., 07/29/2024
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is subject to personal jurisdiction in the district, based on Defendant’s sales of products in California retailers and online, and its sending of pre-suit communications regarding the alleged infringement to Plaintiff, which operates in the district.
- Core Dispute: Plaintiff seeks a declaratory judgment that its X1 Flashlight product does not infringe Defendant's patent related to adjustable focal length LED lighting systems.
- Technical Context: The technology concerns high-performance flashlights that use chip-on-board (COB) LED assemblies with multiple types of LEDs and specially configured adjustable lenses to optimize light output and beam focus.
- Key Procedural History: The complaint states that this declaratory judgment action was initiated in response to a letter from Defendant’s counsel, dated July 10, 2024, which accused Plaintiff’s X1 Flashlight of infringement and demanded that Plaintiff cease and desist from selling the product.
Case Timeline
| Date | Event |
|---|---|
| 2019-09-13 | ’924 Patent Priority Date |
| 2021-10-19 | ’924 Patent Issue Date |
| 2024-07-10 | Defendant's counsel sends infringement accusation letter to Plaintiff |
| 2024-07-29 | Complaint for Declaratory Judgment filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,149,924 - "System, apparatus, and methods for adjustable focal length light," issued October 19, 2021 (’924 Patent)
The Invention Explained
- Problem Addressed: The patent addresses the technical challenges of high-power Light Emitting Diodes (LEDs), including managing heat dissipation and overcoming the inefficiencies of conventional lenses that can lead to "lost lumen output or creates an unwanted glare" (’924 Patent, col. 9:22-24). Standard designs struggle to efficiently collimate light from the entire surface of an LED emitter (’924 Patent, col. 1:15-35).
- The Patented Solution: The invention proposes a lighting apparatus that combines different types of LEDs (e.g., high-power and mid-power) on a single substrate, often in distinct zones ('924 Patent, col. 6:7-10). This LED assembly is paired with an adjustable lens that has different geometries or focal lengths corresponding to the different LED zones. For instance, a convex portion of the lens might focus light from high-power LEDs in the center, while a flat portion corresponds to lower-power LEDs on the periphery, allowing for a more optimized and controllable beam ('924 Patent, col. 6:45-56).
- Technical Importance: This approach seeks to maximize usable light output by tailoring both the light source (mixing LED types) and the optics (a multi-geometry lens) to work in concert, rather than using a brute-force, single high-power LED with a simple lens (’924 Patent, col. 5:1-9).
Key Claims at a Glance
- The complaint seeks a declaratory judgment of non-infringement for claims 1-21 (Compl. ¶25). Independent claims 1, 8, 14, and 18 are identified (Compl. ¶19). The complaint reproduces and focuses its arguments on independent claim 18.
- Independent Claim 18 recites a portable lighting apparatus with the following essential elements:
- An elongate housing with a distal end, a proximal end, and an axial direction.
- A "chip-on-board LED assembly" with a "fixed planar substrate" and "a plurality of coplanar LEDs," positioned to project light parallel to the housing's axis.
- A power source coupled to the LED assembly and a "control module," which is "configured to provide power to the LEDs."
- A lens at the distal end of the housing that is in an "axially adjustable position" relative to the LED assembly.
- The complaint expressly reserves the right to assert non-infringement of dependent claims (Compl. ¶29).
III. The Accused Instrumentality
Product Identification
Plaintiff’s "X1 5000 Lumen product," also referred to as the "X1 Flashlight" (Compl. ¶¶4, 10).
Functionality and Market Context
The complaint describes the product as a flashlight but provides limited detail on its specific technical operation (Compl. ¶13). The core of the complaint’s technical position is based on features the X1 Flashlight allegedly lacks. Specifically, Plaintiff alleges its product does not contain a "control module" as recited in the claims, nor does it have "a first plurality of LEDs having a first power rating" and "a second plurality of LEDs having a second power rating," which are limitations found in other independent claims of the ’924 patent (Compl. ¶28). The complaint does not provide detail on the product's commercial importance beyond Plaintiff's general goal of creating advanced lighting products (Compl. ¶3).
No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement. The following table summarizes Plaintiff's primary arguments for why its X1 Flashlight does not meet the limitations of independent claim 18 of the ’924 Patent.
’924 Patent Infringement Allegations
| Claim Element (from Independent Claim 18) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a chip-on-board LED assembly comprising a fixed planar substrate and a plurality of coplanar LEDs... | Plaintiff's allegations of non-infringement are not specific to this element, but focus on the "control module" and, for other claims, the types of LEDs used. | ¶28 | col. 17:29-35 |
| a power source disposed within the housing, the power source coupled to the LED assembly and a control module, the control module configured to provide power to the LEDs | Plaintiff alleges its product lacks the claimed "control module." The complaint argues this term should be construed under 35 U.S.C. § 112(f) and limited to the corresponding structure described in the specification, which Plaintiff's product allegedly does not contain. | ¶¶20-22, 28 | col. 17:36-39 |
| a lens disposed about a distal end of the elongate housing, the lens disposed in an axially adjustable position with respect to the LED assembly | Plaintiff does not specifically contest this element in the complaint. | - | col. 17:40-43 |
Identified Points of Contention
- Scope Questions: The central dispute articulated in the complaint concerns the proper legal construction of the term "control module." The complaint asserts this is a "nonce term" that fails to recite a specific structure and must be construed as a means-plus-function element under 35 U.S.C. § 112(f) (Compl. ¶¶20-21). This raises the question of whether "module" provides sufficient structural connotation to one of ordinary skill in the art to avoid § 112(f) treatment.
- Technical Questions: Assuming the court construes "control module" under § 112(f), the complaint suggests the corresponding structure is a "control circuit for controlling differently-rated LED configurations or zones" (Compl. ¶22; ’924 Patent, col. 10:23-24, col. 11:11-14). A key factual question will be whether the circuitry inside the accused X1 Flashlight performs this specific function and is structurally equivalent to the disclosed circuit. The complaint also raises a factual dispute over whether the accused product contains the multiple, differently-rated pluralities of LEDs required by other independent claims (Compl. ¶28).
V. Key Claim Terms for Construction
- The Term: "control module"
- Context and Importance: This term is central to Plaintiff's non-infringement argument for at least Claim 18. Practitioners may focus on this term because its construction—specifically, whether it is governed by 35 U.S.C. § 112(f)—could significantly narrow its scope. If construed as a means-plus-function term, it would be limited to the corresponding structures disclosed in the patent's specification and their equivalents, which Plaintiff alleges its product lacks (Compl. ¶¶21-22).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party arguing for a broader construction may point out that "module" is a well-understood term in the electrical arts that connotes a structural unit of components. The claims list the "control module" as a distinct component alongside the "power source" and "LED assembly," which may suggest it has a generally understood structural meaning to an artisan and is not merely a "black box" recitation of a function (’924 Patent, cl. 18).
- Evidence for a Narrower Interpretation: Plaintiff argues that the patent does not define "control module" and that the term itself is a generic placeholder for a function, thus invoking § 112(f) (Compl. ¶21). The complaint points to specific language in the specification describing a "logic control circuit" or "printed circuit board" used to control "different zones" of LEDs as the only disclosed structure for the recited function (’924 Patent, col. 10:19-27, col. 11:11-14). A party could argue this specific structure for controlling different LED types is the required structure for infringement.
VI. Other Allegations
- Indirect Infringement: In its prayer for relief, Plaintiff seeks a declaration that it has not infringed "either directly or indirectly" any claims of the ’924 patent (Compl. Prayer for Relief ¶A). However, as a declaratory judgment complaint for non-infringement, the pleading does not contain specific factual allegations regarding inducement or contributory infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction: will the term "control module" be found to be a means-plus-function limitation under 35 U.S.C. § 112(f), limiting its scope to the specific "control circuit" for managing different LED zones as described in the specification? Or will it be given a broader, plain and ordinary meaning?
- A second central question will be factual infringement: depending on the outcome of claim construction, an evidentiary analysis will be required to determine if the internal circuitry of the accused X1 Flashlight is structurally and functionally equivalent to the claimed "control module."
- Finally, for claims other than Claim 18, a dispositive factual question will be whether the accused product includes "a first plurality of LEDs having a first power rating" and "a second plurality of LEDs having a second power rating," a feature that Plaintiff explicitly alleges its product lacks.