DCT

8:26-cv-00086

Columbia Vehicle Group Inc v. ICON Ev LLC

Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 8:26-cv-00086, M.D. Fla., 01/12/2026
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant is incorporated in Florida and has an established place of business within the Middle District of Florida.
  • Core Dispute: Plaintiff alleges that Defendant’s Epic-branded golf carts infringe two utility patents and one design patent related to illuminated rocker-panel lighting systems.
  • Technical Context: The technology at issue involves lighting assemblies integrated into the side rocker panels of golf carts, intended to provide visual safety signals regarding the vehicle's operational status and enhance aesthetic appeal.
  • Key Procedural History: The complaint does not reference any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the asserted patents. The '175 Patent is subject to a terminal disclaimer.

Case Timeline

Date Event
2023-01-23 Priority Date for ’175 Patent, ’836 Patent, and D’957 Patent
2025-05-27 ’836 Patent Issued
2025-08-19 ’175 Patent Issued
2025-08-19 D’957 Patent Issued
2026-01-12 Complaint Filed

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

U.S. Patent No. 12,391,175 - *"Systems and methods for a lighting assembly for a golf cart,"* Issued August 19, 2025

The Invention Explained

  • Problem Addressed: The patent background identifies a need to enhance the safety and visibility of golf carts by adding light illumination to their rocker panels. (’175 Patent, col. 1:30-34).
  • The Patented Solution: The invention is a golf cart lighting system featuring a rocker panel with an integrated light pipe and light source. (’175 Patent, Abstract). A processor controls the light source to emit a multi-color lighting sequence when a switch, such as the ignition, is activated. (’175 Patent, Claim 9). This system is designed to direct light outward from the side of the golf cart, providing a clear visual signal that the vehicle is in an active state. (’175 Patent, col. 1:39-42).
  • Technical Importance: This approach provides a direct visual indication of the vehicle's operational status to operators and bystanders, which may enhance safety. (’175 Patent, col. 10:9-15).

Key Claims at a Glance

  • The complaint asserts independent claims 1 and 9, and dependent claim 14. (Compl. ¶27).
  • Independent Claim 9, a system claim for a golf cart, includes these essential elements:
    • A frame, a body with a side panel, and a rocker panel coupled to the side panel.
    • The rocker panel includes a panel aperture and a separate pipe aperture.
    • A light pipe is secured within the pipe aperture.
    • A light source is housed within the light pipe and is configured to emit a multi-color lighting sequence when a switch on the golf cart is activated.
    • The light pipe is configured to direct the emitted light outward from the rocker panel.

U.S. Patent No. 12,311,836 - *"Systems and methods for a lighting assembly for a golf cart,"* Issued May 27, 2025

The Invention Explained

  • Problem Addressed: Similar to its continuation (’175 Patent), this patent addresses the need for improved safety and visibility on golf carts through illuminated rocker panels. (’836 Patent, col. 1:30-34).
  • The Patented Solution: The patent describes a lighting system comprising a rocker panel, a light pipe, a light source, and a processor. (’836 Patent, Abstract). The processor is configured to execute a specific two-stage lighting process: it provides a "first lighting sequence" when the golf cart's ignition is activated, and then switches to and maintains a "second lighting sequence" when the vehicle's drivetrain is turned on. (’836 Patent, col. 2:50-56). Figure 12 illustrates this multi-step process, starting with receiving an ignition signal (160) and displaying the first sequence (162), before switching to the second sequence (164). (’836 Patent, Fig. 12).
  • Technical Importance: The claimed two-stage lighting sequence provides distinct visual cues corresponding to different stages of vehicle activation (ignition vs. drivetrain ready), potentially offering more granular safety information. (’836 Patent, col. 10:20-24).

Key Claims at a Glance

  • The complaint asserts independent claims 1 (a system claim) and 10 (a method claim). (Compl. ¶27).
  • Independent Claim 1 includes these essential elements:
    • A rocker panel secured to a golf cart side panel, including a pipe aperture.
    • A light pipe secured within the pipe aperture.
    • A light source housed within the light pipe.
    • A processor connected to the system to provide lighting instructions.
    • The light pipe directs light outward from the side panel.
    • The lighting instructions are configured for both:
      • Providing a first lighting sequence when ignition is activated.
      • Switching to and maintaining a second lighting sequence when the drivetrain is turned on.

Multi-Patent Capsule

  • Patent Identification: U.S. Patent No. D1,088,957, "Golf cart with an illuminated rocker panel," Issued August 19, 2025. (Compl. ¶62).
  • Technology Synopsis: This design patent claims the ornamental appearance of a golf cart rocker panel that incorporates an illuminated light pipe. (D’957 Patent, Claim). The claimed design consists of the specific visual shape and arrangement of the light pipe segments along the lateral axis of the rocker panel, as depicted in solid lines in the patent's figures. (Compl. ¶67; D’957 Patent, Figs. 3-4).
  • Asserted Claims: The complaint asserts the single design claim. (Compl. ¶27).
  • Accused Features: The overall ornamental appearance of the illuminated rocker panels on the Accused Products are alleged to be "substantially the same in the eyes of the ordinary observer" as the claimed design. (Compl. ¶66).

III. The Accused Instrumentality

Product Identification

  • The Epic E20FX, E40FX, and E60FX Golf Carts (the "Accused Products"). (Compl. ¶4). The complaint presents the E40FX model as a representative example. (Compl. ¶24).

Functionality and Market Context

  • The Accused Products are Epic-branded golf carts alleged to "implement illuminated rocker-panel systems." (Compl. ¶23). The complaint alleges that publicly available materials confirm the products "incorporate rocker-panel light pipes and lighting sequences." (Compl. ¶26). An image provided in the complaint shows the representative Accused Product with a visible lighting element running along the length of the side rocker panel, below the passenger compartment. (Compl. p. 7). The complaint does not provide further technical detail on the operation of these lighting systems.

IV. Analysis of Infringement Allegations

The complaint references, but does not include, claim chart exhibits. (Compl. ¶27, ¶35, ¶50). The following analysis is based on the narrative allegations in the complaint and the patent specifications.

’175 Patent Infringement Allegations

Claim Element (from Independent Claim 9) Alleged Infringing Functionality Complaint Citation Patent Citation
a rocker panel coupled to the side panel...the rocker panel includes a panel aperture...and a pipe aperture The Accused Products allegedly have "illuminated rocker-panel systems." ¶23 col. 5:6-14
a light pipe secured within the pipe aperture The Accused Products allegedly "incorporate rocker-panel light pipes." ¶26 col. 6:31-34
a light source housed within the light pipe...configured to emit a multi-color lighting sequence when a switch...is activated The Accused Products allegedly incorporate "lighting sequences." ¶26 col. 9:50-54
the light pipe is configured to direct light emitted from the light source outward from the rocker panel The Accused Products' rocker panels are illuminated. ¶23 col. 6:47-50
  • Identified Points of Contention:
    • Scope Questions: The complaint alleges "lighting sequences" generally. A central question may be whether the Accused Products' lighting sequences are "multi-color" and are triggered "when a switch on the golf cart is activated" in the manner required by the claim.
    • Technical Questions: What evidence does the complaint provide that the accused lighting system is tied to a specific "switch" activation as claimed, rather than being, for example, a general accent light controlled independently?

’836 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a rocker panel secured to a side panel of the golf cart and including a pipe aperture The Accused Products allegedly have "illuminated rocker-panel systems." ¶23 col. 5:10-14
a light pipe secured within the pipe aperture The Accused Products allegedly "incorporate rocker-panel light pipes." ¶26 col. 6:30-33
a light source housed within the light pipe The Accused Products allegedly incorporate "lighting sequences." ¶26 col. 6:37-46
a processor...configured for...providing a first lighting sequence...when an ignition...is activated; and switching to and maintaining a second lighting sequence...when a drivetrain...is turned on The Accused Products allegedly incorporate "lighting sequences." ¶26 col. 9:10-40
  • Identified Points of Contention:
    • Scope Questions: A primary point of contention will likely be whether the accused "lighting sequences" map onto the specific two-step functional process recited in the claim. The complaint does not specify whether the accused system distinguishes between an "ignition" event and a "drivetrain...turned on" event.
    • Technical Questions: Does the accused system employ a processor that executes the claimed two-part logic, or does its lighting activate in a different manner (e.g., a single sequence upon power-on)? An image of Plaintiff's own product is provided as an example of a cart that practices the asserted patents. (Compl. p. 5).

V. Key Claim Terms for Construction

For the ’175 Patent:

  • The Term: "multi-color lighting sequence"
  • Context and Importance: The scope of this term is central to infringement, as it defines the required functionality of the light source. Practitioners may focus on this term because the complaint's general allegation of "lighting sequences" (Compl. ¶26) leaves open the question of whether the accused systems are in fact "multi-color."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself does not impose any limit on the number of colors beyond requiring more than one.
    • Evidence for a Narrower Interpretation: The specification describes the "first lighting sequence" as a "multi-color startup sequence," which may suggest the term is tied to a specific type of sequence rather than any sequence with multiple colors. (’175 Patent, col. 9:26-28).

For the ’836 Patent:

  • The Term: "when a drivetrain of the golf cart is turned on"
  • Context and Importance: This phrase defines the specific trigger for the "second lighting sequence." The infringement analysis will depend on whether the accused products' lighting is controlled by the drivetrain's status. The complaint does not provide sufficient detail for analysis of this specific element.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification defines this condition as when the "drivetrain is activated, meaning the golf cart 24 is capable of moving." (’836 Patent, col. 9:22-24). This could be interpreted broadly to mean any state where the motor is energized and ready for input.
    • Evidence for a Narrower Interpretation: An alternative interpretation could require that the drivetrain be engaged in a more active sense, such as being shifted into gear. The patent's distinction between this state and simple "ignition" suggests two distinct, sequential events are contemplated. (’836 Patent, Claim 1).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement. Inducement is based on allegations that Icon encourages authorized dealers and manufacturers to make, use, and sell the Accused Products. (Compl. ¶37, ¶52). Contributory infringement is based on allegations that the accused rocker panel lighting systems are material components of the invention that are not staple articles of commerce and have no substantial non-infringing use. (Compl. ¶38, ¶53).
  • Willful Infringement: Willfulness is alleged based on knowledge of the asserted patents and infringement occurring "at least as of the filing of this Complaint" and "since at least after the filing of this Complaint." (Compl. ¶40, ¶42, ¶55, ¶57).

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

  • A core issue will be one of functional mapping: Do the accused golf carts' "lighting sequences" perform the specific, event-driven functions required by the utility patent claims—namely, the "multi-color" sequence of the '175 Patent and, critically, the two-stage "ignition" versus "drivetrain" logic of the '836 Patent? The complaint's general allegations raise the question of whether there is a fundamental mismatch in technical operation.
  • A second central issue will be the design patent "ordinary observer" test: Is the overall ornamental appearance of the illuminated rocker panel on the Accused Products substantially the same as the design claimed in the D'957 Patent, or are the visual differences sufficient to distinguish them in the eyes of a potential purchaser?