DCT
1:25-cv-01439
Wang v. Capital Acquisitions 4 LLC
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Lei Wang (China) and Dingyuan Dinguan Import & Export Co. (China)
- Defendant: Capital Acquisitions 4 LLC (Delaware)
- Plaintiff’s Counsel: Amburn Law LLC
- Case Identification: 1:25-cv-01439, D. Del., 11/26/2025
- Venue Allegations: Venue is asserted based on the Defendant’s incorporation in the state of Delaware.
- Core Dispute: Plaintiffs allege that Defendant’s HALO-brand illuminated and rechargeable sports balls infringe a patent related to the internal construction and charging mechanism for such products.
- Technical Context: The technology at issue involves integrating rechargeable lighting systems into consumer sporting goods, aiming to enhance durability and user convenience over prior battery-replacement or wireless-charging models.
- Key Procedural History: The complaint alleges that Defendant was made aware of the patent-in-suit at least as early as September 24, 2025, via an infringement report submitted through Amazon's dispute resolution program, a fact which may be material to the allegations of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2023-10-31 | '617 Patent Priority Date |
| 2025-02-11 | '617 Patent Issue Date |
| 2025-09-24 | Alleged pre-suit notice to Defendant via Amazon |
| 2025-11-26 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,220,617 - "RECHARGEABLE LUMINOUS BALL"
- Patent Identification: U.S. Patent No. 12,220,617, "RECHARGEABLE LUMINOUS BALL," issued February 11, 2025 (the ’617 Patent).
The Invention Explained
- Problem Addressed: The patent's background section describes prior art luminous balls as suffering from drawbacks, including the inefficiency and high cost of wireless charging systems or the inconvenience of regularly replacing disposable batteries ( ’617 Patent, col. 1:18-25).
- The Patented Solution: The invention proposes a modular electronics unit ("luminous component") containing a battery, lamp, and a wired charge port, which is seated within a cavity inside a multi-layered ball. This component is secured by a "first cover cap" that creates a seal with the cavity's inner wall. A smaller "second cover cap" is set within the first, providing access to the charge port without requiring removal of the entire assembly, thereby aiming to improve durability and charging convenience (’617 Patent, Abstract; col. 3:1-14).
- Technical Importance: This design purports to offer a robust, low-cost, and efficient method for incorporating wired charging capabilities into sports balls designed for active use (’617 Patent, col. 2:20-25).
Key Claims at a Glance
- The complaint asserts independent Claim 1 and dependent Claims 2, 3, and 4 (’617 Patent, col. 5:12-6:26; Compl. ¶20).
- Independent Claim 1 requires:
- A ball with a plurality of cavities and composed of specific layers (exodermis, interlayer, yarn layer, inner liner).
- A luminous component comprising a luminous body, a battery, a lamp bead, and a charge port.
- A "first cover cap" featuring a "luminous component fix groove" that is "interference-fit" with the luminous component.
- The first cover cap is "detachably connected" to the cavity and "interference-fit" with the cavity's inner wall.
- The first cover cap has an opening that is "interference-fit" with a "second cover cap," with the charge port located below this opening.
- The first cover cap is attached to the edges of all four specified layers of the ball.
III. The Accused Instrumentality
Product Identification
The complaint identifies "illuminated rechargeable balls, including footballs, basketballs, and soccer balls" sold under the "HALO brand" as the Accused Products (Compl. ¶17-18).
Functionality and Market Context
The complaint alleges the Accused Products are sports balls containing internal, rechargeable illumination systems (Compl. ¶17). The complaint provides images of the Accused Products' retail packaging, which advertises them as "light-up" and "RECHARGEABLE" (Compl. p. 4). The complaint alleges these products are sold for subsequent resale or use in the United States (Compl. ¶18).
IV. Analysis of Infringement Allegations
The complaint alleges that the Accused Products "embody each and every limitation" of the asserted claims but does not provide a detailed mapping of specific product features to claim elements (Compl. ¶20). The infringement theory appears to rest on the assertion that the overall function and appearance of the Accused Products as rechargeable, illuminated balls are sufficient to read on the claims (Compl. ¶24).
’617 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a ball, wherein the ball is provided with a plurality of cavities; | The Accused Products are balls alleged to contain the claimed elements, implicitly including cavities for housing the electronics. | ¶20 | col. 1:36-37 |
| a luminous component...comprises a luminous body, an interior of the luminous body is provided with a battery, and the luminous body is provided with a lamp bead and a charge port; | The Accused Products are alleged to contain an internal, rechargeable light source, which Plaintiffs contend meets these limitations. | ¶20 | col. 1:38-41 |
| a first cover cap, wherein the first cover cap is provided with a luminous component fix groove, the luminous component is interference-fit with the luminous component fix groove... | The complaint makes a conclusory allegation that the Accused Products contain a first cover cap with these specific structural and relational features. | ¶20 | col. 1:42-45 |
| ...the first cover cap is provided with an opening, the opening is interference-fit with a second cover cap, and the charge port is located below the opening; | The complaint makes a conclusory allegation that the Accused Products utilize the claimed two-part cover system to provide access to a charge port. | ¶20 | col. 1:45-47 |
| wherein, the first cover cap is detachably connected to the cavity, when the first cover cap is installed in the cavity, the first cover cap is interference-fit with an inner wall of the cavity; | The complaint makes a conclusory allegation that the Accused Products' cover cap is connected and sealed in the claimed manner. | ¶20 | col. 1:48-51 |
| wherein the ball is composed of an exodermis, an interlayer, a yarn layer, and an inner liner layer...the first cover cap is attached to edges of the...layers. | The complaint makes a conclusory allegation that the Accused Products are constructed with the claimed multi-layer structure and cap attachment method. | ¶20 | col. 6:8-13 |
Identified Points of Contention
- Structural Questions: A primary point of contention will be factual: do the accused HALO products contain the specific internal structures mandated by Claim 1? The complaint provides no evidence regarding the products' internal construction, such as the "luminous component fix groove" or the two-part cover cap system.
- Scope Questions: The claim repeatedly uses the term "interference-fit" to describe the connections between the luminous component, the first cover cap, the second cover cap, and the cavity wall. The dispute may turn on whether the sealing and connection method used in the Accused Products, once discovered, falls within the technical scope of an "interference-fit" as understood in mechanical arts.
V. Key Claim Terms for Construction
- The Term: "interference-fit"
- Context and Importance: This term appears three times in Claim 1 to define the precise mechanical interface between key components. The infringement analysis will depend heavily on whether the Defendant's products achieve their seals and connections via a true interference fit (where components are held by friction after one is forced into another of a slightly smaller dimension) or through another means, such as a threaded connection, a gasket, or a snap-fit mechanism.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification does not provide an explicit definition of the term, which may suggest it should be given its plain and ordinary meaning to one of skill in the art of mechanical design.
- Evidence for a Narrower Interpretation: The patent states the interference fit between the first and second cover caps functions "to prevent liquid from flowing into a gap," which could be argued to require a specific level of sealing performance (’617 Patent, col. 3:5-9). The specific embodiment shown in the figures may also be used to argue for a narrower construction consistent with the depicted geometry.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Defendant actively encourages and instructs purchasers to use the Accused Products in an infringing manner, citing "online consumer reviews" as evidence of such use (Compl. ¶21, ¶25).
- Willful Infringement: Willfulness is alleged based on Defendant’s purported knowledge of the ’617 Patent. The complaint alleges this knowledge stems from an infringement report sent to Defendant via Amazon on September 24, 2025, and also asserts on "information and belief" that Defendant was aware of the patent even prior to that date (Compl. ¶22-23, ¶28).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of evidentiary proof: does the internal architecture of the accused HALO-brand products, which is not described in the complaint, actually contain the specific, multi-part structural arrangement required by Claim 1? The case's viability depends on whether discovery reveals a two-part cover cap system, a "luminous component fix groove," and the claimed multi-layer ball construction.
- A key legal question will be one of claim scope: can the term "interference-fit," a specific term of art in mechanical engineering, be construed to read on the actual fastening and sealing mechanisms used in the Accused Products? The resolution of this construction issue may be dispositive for the infringement analysis.