DCT

5:23-cv-02238

Diode Dynamics LLC v. 5dlight Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 5:23-cv-02238, C.D. Cal., 06/03/2025
  • Venue Allegations: Venue is alleged to be proper because both defendants are California corporations that reside in the Central District of California and each maintains a regular and established physical place of business within the district.
  • Core Dispute: Plaintiff alleges that Defendants' "Lasfit" brand of automotive LED light pods infringes a design patent covering the ornamental appearance of an LED lamp bezel.
  • Technical Context: The technology resides in the competitive aftermarket for automotive auxiliary lighting, where distinct product aesthetics can be a significant market differentiator.
  • Key Procedural History: The complaint alleges that Plaintiff provided Defendant 5DLight with actual notice of infringement via a letter dated February 17, 2023. The complaint also includes extensive allegations that Defendants copied Plaintiff's marketing materials, website layout, and product naming conventions, which may be presented as evidence of willful infringement.

Case Timeline

Date Event
2019-12-23 D'648 Patent Priority Date (via parent application)
2022-08-25 Plaintiff allegedly began virtual patent marking for its commercial products
2023-01-03 U.S. Design Patent No. D974,648 Issued
2023-02-17 Plaintiff allegedly sent actual notice of infringement letter to Defendant 5DLight
2025-06-03 First Amended Complaint for Patent Infringement Filed

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

U.S. Design Patent No. D974,648 - LED LAMP BEZEL

The Invention Explained

  • Problem Addressed: As a design patent, the D’648 Patent does not describe a technical problem but instead provides a novel aesthetic design for an article of manufacture (D’648 Patent, CLAIM).
  • The Patented Solution: The patent claims a specific ornamental design for the bezel, or front frame, of an LED lamp (D’648 Patent, Figs. 1-5). The claimed design, shown in solid lines, consists of a generally square frame with four concave, indented sections centered on the top, bottom, and side surfaces (D’648 Patent, Fig. 1). The patent specifies that the broken lines depicting the rest of the lamp assembly are for illustrative purposes only and "form no part of the claimed design" (D’648 Patent, DESCRIPTION).
  • Technical Importance: The complaint alleges this patented design is embodied in several of Plaintiff's commercial products, including its "SS3 LED Pod products," suggesting the design serves as a key element of the products' trade dress and brand identity in the aftermarket automotive lighting space (Compl. ¶23).

Key Claims at a Glance

  • The D’648 Patent contains a single claim for "the ornamental design for a LED lamp bezel, as shown and described" (D’648 Patent, CLAIM). The scope of this claim is defined by the visual appearance of the elements depicted in solid lines in the patent's figures.

III. The Accused Instrumentality

Product Identification

  • The "Lasfit 3" LED Pod Sport Series Off-Road Hood Ditch Light SAE Fog Flood 18W," also referred to as the "Lasfit 3" LED Pod Sport light" (Compl. ¶¶29, 55).

Functionality and Market Context

  • The accused instrumentality is an 18-watt auxiliary LED light pod designed for automotive use, such as for off-road hood or ditch lighting (Compl. ¶29). The complaint includes an image of the product taken from Defendant 5DLight's website (Compl. ¶29, p. 8).
  • Defendants are alleged to market, offer for sale, and sell the accused products in the United States through at least the website www.lasfit.com and an Amazon.com storefront (Compl. ¶¶29, 38, 57-58). The complaint alleges that Defendants have copied Plaintiff's product naming, website graphics, and technical data presentation, suggesting the products are positioned to compete directly against Plaintiff's own LED pods (Compl. ¶¶41-51).

IV. Analysis of Infringement Allegations

The standard for design patent infringement is whether, in the eye of an ordinary observer familiar with the prior art, the accused design is substantially the same as the patented design, such that the observer would be deceived into purchasing the accused product believing it to be the patented one. The complaint alleges this standard is met (Compl. ¶64). To support this, the complaint provides a side-by-side visual comparison of the patented design and the accused product's bezel (Compl. ¶60).

D'648 Patent Infringement Allegations

Patented Design Feature (from D'648 Patent, Fig. 1) Alleged Infringing Functionality (from Accused Product) Complaint Citation Patent Citation
A generally square overall shape with rounded corners. The bezel of the accused product features a generally square shape with rounded corners. ¶60 Fig. 1
Four concave, indented features, one centered on each of the top, bottom, left, and right sides of the frame. The bezel of the accused product incorporates four similarly shaped and located concave, indented features. ¶60 Fig. 1
A continuous raised inner lip and outer lip that frame the design. The bezel of the accused product displays a continuous raised lip structure forming an inner and outer frame. ¶60 Fig. 1
  • Identified Points of Contention:
    • Scope Questions: A central issue will be the application of the "ordinary observer" test. The dispute may turn on whether an ordinary observer, acquainted with other LED pod designs in the market (the "prior art"), would find the overall visual impression of the Lasfit bezel to be substantially the same as the D'648 patented design, or if perceived differences are significant enough to avoid confusion (Compl. ¶64).
    • Technical Questions: The analysis will focus on a visual comparison. The question for the fact-finder will be whether any minor differences in the proportions, curvatures, or surface textures between the accused bezel and the patented design are sufficient to create a different overall ornamental impression.

V. Key Claim Terms for Construction

In design patent litigation, the "claim" is understood to be the design itself as depicted in the drawings, rather than a set of textual limitations. Consequently, formal claim construction of specific terms is generally not a central part of the case. The legal analysis will focus on a comparison of the overall visual appearance of the accused product to the patented design shown in the figures of the D’648 Patent.

VI. Other Allegations

  • Willful Infringement: The complaint alleges willful infringement based on both actual and constructive knowledge (Compl. ¶¶72-75). Actual knowledge is alleged to stem from a cease-and-desist letter sent to Defendant 5DLight on February 17, 2023 (Compl. ¶¶32, 72). Constructive knowledge is alleged based on Plaintiff’s practice of virtual patent marking (Compl. ¶¶27, 67). The claim of willfulness is further supported by extensive allegations of copying, where Plaintiff asserts that Defendants replicated its product names, website layouts, marketing slogans, and technical graphics (Compl. ¶¶41-51). For example, the complaint provides a screenshot from Instagram allegedly showing two "Lasfit" accounts following Plaintiff's "diodedynamics" account as evidence of Defendants monitoring Plaintiff's activities (Compl. ¶51).

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

The resolution of this case will likely depend on the court's determination of two primary questions:

  • A core issue will be one of visual similarity: In the eyes of an ordinary observer familiar with the market for auxiliary LED lights, is the ornamental design of the accused Lasfit bezel "substantially the same" as the design claimed in the D'648 Patent, or are the visual differences sufficient to avoid deception?
  • A key evidentiary question will be one of intent: How will the extensive allegations and evidence of Defendants' alleged copying of Plaintiff's marketing materials, website content, and product branding influence the analysis of willfulness and, potentially, the primary infringement question itself?