DCT
2:25-cv-04549
Infinity X1 LLC v. Coast Cutlery Co
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Infinity X1 LLC (Nevada)
- Defendant: COAST CUTLERY CO. dba COAST PRODUCTS (Oregon)
- Plaintiff’s Counsel: Jeffer Mangels Butler & Mitchell LLP
- Case Identification: 2:25-cv-04549, C.D. Cal., 05/20/2025
- Venue Allegations: Venue is alleged to be proper in the Central District of California based on Defendant's sales of infringing products within the district, placement of products into the stream of commerce with the knowledge they will be sold in the district, and the derivation of substantial revenue from such sales.
- Core Dispute: Plaintiff alleges that Defendant’s rechargeable headlamp infringes two patents related to multi-source, multi-mode headlamp technology, and further engages in false advertising by misrepresenting the product's capabilities on its packaging.
- Technical Context: The technology concerns high-performance headlamps that incorporate multiple distinct light sources (e.g., spot, flood, peripheral) which can be operated independently or in various combinations to provide a broad and versatile field of illumination for the user.
- Key Procedural History: U.S. Patent No. 12,203,618 is a continuation of the application that matured into U.S. Patent No. 11,852,311. The complaint does not mention other prior litigation or administrative proceedings.
Case Timeline
| Date | Event |
|---|---|
| 2020-05-09 | ’311 and ’618 Patents Priority Date |
| 2023-12-26 | U.S. Patent No. 11,852,311 Issue Date |
| 2025-01-21 | U.S. Patent No. 12,203,618 Issue Date |
| 2025-05-20 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,852,311, "Broad View Headlamp" (Issued Dec. 26, 2023)
The Invention Explained
- Problem Addressed: The patent identifies a deficiency in prior art headlamps, which either provide a narrow forward-directed beam (requiring the user to constantly move their head) or a wide-angle, non-focused light without the ability to use different lighting effects or provide downward illumination (’311 Patent, col. 1:31-2:8).
- The Patented Solution: The invention is a headlamp with multiple, discrete light sources housed in separate compartments, each with its own reflector and lens (’311 Patent, col. 3:5-15). This structure allows for various lighting modes, including spot, flood, peripheral, and downward-directed light, which can be activated individually or in combination to create a total illuminated view area of at least 220 degrees (’311 Patent, col. 3:20-24, col. 3:37-45).
- Technical Importance: This design aims to provide a single, hands-free device that combines the benefits of focused, long-range illumination with broad, peripheral visibility, overcoming a common trade-off in portable lighting (’311 Patent, col. 1:50-2:8).
Key Claims at a Glance
- The complaint asserts independent claim 1 and dependent claims 6 and 7 (Compl. ¶45).
- Independent Claim 1 recites:
- A headlamp comprising a plurality of light sources;
- The plurality includes a "first light source" (with a first LED, lens, and reflector) illuminating a first view area and a "second light source" (with a second LED, lens, and reflector) illuminating a second view area;
- A "lighting control module" is configured to selectively activate the light sources; and
- A lighting mode exists that activates both the first and second light sources to create a "total combined view area that is wider than either" the first or second view area alone.
- The complaint reserves the right to assert additional claims.
U.S. Patent No. 12,203,618, "Broad View Headlamp" (Issued Jan. 21, 2025)
The Invention Explained
- Problem Addressed: The ’618 Patent addresses the same technical problem as its parent ’311 Patent: the limitations of conventional headlamps that lack combined long-range and peripheral illumination capabilities (’618 Patent, col. 1:33-2:10).
- The Patented Solution: The solution is substantively the same as in the ’311 Patent, describing a headlamp with multiple light sources that can be operated individually or in combination via a control module to achieve various illumination effects, including a wide field of view (’618 Patent, col. 3:5-25).
- Technical Importance: As with the parent patent, the invention's stated importance lies in its ability to offer enhanced situational awareness through a combination of different, controllable light beams in one device (’618 Patent, col. 1:52-2:10).
Key Claims at a Glance
- The complaint asserts independent claim 11 and dependent claims 12 and 13 (Compl. ¶60).
- Independent Claim 11 recites:
- A headlamp with a "first light source" illuminating a first view area and a "second light source" illuminating a second view area;
- A "lighting control module" configured for selective activation of the sources; and
- A lighting mode that activates both sources to create a "total combined view area that is wider than either" view area alone.
- The complaint reserves the right to assert additional claims.
III. The Accused Instrumentality
- Product Identification: The Coast CH1000R Rechargeable Headlamp (Itm./Art. No. 1806407) (Compl. ¶20).
- Functionality and Market Context:
- The complaint alleges the accused headlamp features multiple light sources and modes, including a spot light, a flood light, a wide angle mode, and a red light mode (Compl. ¶21). The complaint provides visual evidence identifying two distinct forward-facing light sources on the device (Compl. ¶¶ 46, 64). An image from the product packaging allegedly depicts the simultaneous emission of light from wide angle, spot, and flood sources (Compl. ¶23). A similar image is alleged to appear in the product manual (Compl. ¶24).
- The product is allegedly sold through major retailers like Costco, placing it in direct competition with Plaintiff's headlamp products (Compl. ¶¶ 19, 22).
IV. Analysis of Infringement Allegations
'311 Patent Infringement Allegations
The complaint provides a photograph of the accused device with callouts identifying two distinct forward-facing emitters as the "First light source" and "Second light source" to support its infringement allegations (Compl. ¶46).
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first light source comprising a first light emitting diode, a first lens, and a first reflector to illuminate a first view area in a first fixed direction from the headlamp | The accused device allegedly includes a first light source with an LED, lens, and reflector. | ¶46 | col. 3:7-15 |
| a second light source comprising a second light emitting diode, a second lens, and a second reflector to illuminate a second view area in a second fixed direction from the headlamp | The accused device allegedly includes a second light source with an LED, lens, and reflector. | ¶46 | col. 3:7-15 |
| a lighting control module configured to selectively activate the plurality of light sources according to a plurality of lighting modes | The accused device includes a lighting control module to selectively activate the light sources in different modes. | ¶47 | col. 4:40-44 |
| where the plurality of lighting modes comprises at least a first lighting mode that activates the first light source and the second light source... to create a total combined view area that is wider | The accused device allegedly includes a lighting mode that activates both the first and second light sources to create a combined view area wider than either individual source's view area. | ¶48 | col. 3:50-54 |
- Identified Points of Contention:
- Scope Questions: A potential issue arises from the complaint asserting both independent Claim 1 and dependent Claim 6. Claim 6 requires the "first light source" and "second light source" to be "peripheral" light sources. However, the complaint's allegations and visual evidence for Claim 1 appear to map these terms to the product's forward-facing spot and flood lights (Compl. ¶46). This raises the question of whether Plaintiff's infringement theory is consistent across its asserted claims, which may become a focus during claim construction.
- Technical Questions: What is the physical construction of the two light sources identified in the complaint's photograph (Compl. ¶46)? The court will need evidence to determine if each source truly comprises its own distinct "light emitting diode, a... lens, and a... reflector" as required by Claim 1.
'618 Patent Infringement Allegations
The complaint provides another annotated photograph of the accused device, identifying one forward-facing emitter as the "Spot light source" and the other as the "Flood light source" (Compl. ¶64).
| Claim Element (from Independent Claim 11) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first light source configured to illuminate a first view area in a first fixed direction from the headlamp | The accused device includes a first light source (allegedly the "spot light") to illuminate a first view area. | ¶¶61, 64 | col. 3:7-15 |
| a second light source configured to illuminate a second view area in a second fixed direction from the headlamp | The accused device includes a second light source (allegedly the "flood light") to illuminate a second view area. | ¶¶61, 64 | col. 3:7-15 |
| a lighting control module configured to selectively activate the first light source and the second light source according to a plurality of lighting modes | The accused device includes a control module that allows for selective activation of its light sources. | ¶62 | col. 4:40-44 |
| the plurality of lighting modes comprises a first lighting mode that activates the first light source and the second light source...to create a total combined view area... | The accused device allegedly has a lighting mode that activates both the spot and flood sources to create a total combined view area that is wider than either the spot or flood view area alone. | ¶63 | col. 3:50-54 |
- Identified Points of Contention:
- Scope Questions: How is the phrase "total combined view area that is wider" to be construed? A central factual dispute may be whether activating the accused product's spot and flood lights simultaneously results in an illuminated area that is meaningfully "wider" than the flood beam alone, or if the spot beam is merely a more intense region substantially within the flood beam's existing area.
- Technical Questions: Does the accused product operate as alleged? The complaint alleges the existence of a combined spot/flood mode (Compl. ¶63), a focused spot mode, a broad-beamed flood mode (Compl. ¶64), and a night vision mode (Compl. ¶65) to support infringement of claims 11, 12, and 13. The actual operational characteristics of the accused product will be a key evidentiary focus.
V. Key Claim Terms for Construction
For the '311 Patent:
- The Term: "first light source" / "second light source"
- Context and Importance: The construction of these terms is critical because the infringement theory appears to depend on their interpretation. Practitioners may focus on this term because the complaint's allegations for Claim 1 map it to forward-facing lights, while asserted dependent Claim 6 redefines it as a "peripheral" light source. This potential conflict makes the term's scope a central issue.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes multiple types of light sources, including a forward-directed "spot beam" (35) and "flood beam" (40), separate from the peripheral lights (50, 52) (’311 Patent, col. 3:41-49). This could support an argument that the general term "light source" in Claim 1 is not inherently limited to peripheral lights.
- Evidence for a Narrower Interpretation: The doctrine of claim differentiation may be invoked. The fact that dependent Claim 6 explicitly adds the "peripheral" limitation could suggest that the base claim's "first light source" and "second light source" are something different. The patent's abstract also highlights illuminating an area "adjacent to each side of the headlamp," which could be used to argue the core invention is focused on peripheral, not just forward, lighting (’311 Patent, Abstract).
For the '618 Patent:
- The Term: "total combined view area that is wider than either the first view area or the second view area alone"
- Context and Importance: This functional language is the core limitation of Claim 11. Infringement will hinge on whether the accused product's combined-light mode meets this geometric requirement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification repeatedly emphasizes the goal of creating an extremely wide field of view, stating the "total view area illuminated by headlamp 5 is at least 220 degrees" (’618 Patent, col. 3:23-25). This could support an expansive reading where any measurable increase in the combined beam's width satisfies the limitation.
- Evidence for a Narrower Interpretation: A defendant may argue that "wider" requires a meaningful, non-trivial increase in the illuminated area's footprint beyond the boundary of the larger of the two individual beams. The specification's distinction between a "focused beam" and a "broad-beamed" light source could be used to argue that simply overlaying a narrow spot on a wide flood does not make the total area "wider" in the sense intended by the patent (’618 Patent, col. 3:41-45).
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement for both patents. It alleges inducement based on acts of "marketing, promoting, and offering for use the Infringing Device, knowingly and intending that the use... infringes" the patents (Compl. ¶¶ 51, 66). It alleges contributory infringement on the basis that the accused headlamp is a material part of the invention, is not a staple article of commerce, and is known to be especially adapted for infringement (Compl. ¶¶ 52, 67).
- Willful Infringement: The complaint alleges willful infringement for both patents based on the allegation that "Defendants knew of the... Patent, or should have known, and despite such knowledge Defendants continued selling the Infringing Device" (Compl. ¶¶ 57, 72).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim scope consistency: For the ’311 Patent, can Plaintiff’s infringement theory, which maps the claim terms "first light source" and "second light source" to the accused product's forward-facing lights, be reconciled with its simultaneous assertion of a dependent claim that redefines those same sources as being "peripheral"? The resolution of this question will likely shape the claim construction battle.
- A key evidentiary question will be one of functional operation: For the ’618 Patent, does activating the accused product's spot and flood lights together create a "total combined view area that is wider" than the flood light alone, as claimed? This will require factual evidence, likely through expert testimony and testing, to resolve the geometric and functional aspects of the claim.
- The case presents a parallel factual dispute over false advertising: Independent of the patent claims, the court will be asked to decide if the illustrations on the accused product's packaging and manual (Compl. ¶¶ 23-24) create a materially misleading representation of the headlamp's capabilities, specifically whether it can operate its wide-angle, spot, and flood lights simultaneously as Plaintiff alleges it cannot (Compl. ¶26).