The Schedule A

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Centre Way Company Limited. (Hong Kong, China)
  • Defendant: The Individuals, Partnerships and Unincorporated Associations Identified on Schedule “A”
  • Plaintiff’s Counsel: The Law Offices of Jared W. Gasman, P.A.
• Case Identification: 0:22-cv-61705, S.D. Fla., 09/11/2022
• Venue Allegations: Venue is alleged to be proper based on Defendants targeting and conducting business with consumers in Florida through interactive e-commerce stores, offering shipping to Florida, and accepting payment in U.S. dollars.
• Core Dispute: Plaintiff alleges that Defendants’ e-commerce stores sell clocks that infringe a patent related to an intelligent, light-sensing backlight device.
• Technical Context: The technology concerns energy-saving, automated backlighting for consumer electronics, such as clocks, which improves usability in low-light conditions while conserving battery power.
• Key Procedural History: The complaint is filed against a group of unidentified defendants, common in actions targeting diffuse online sellers. Plaintiff alleges these defendants operate through multiple fictitious storefronts to conceal their identities and interrelationships.

Case Timeline

Date	Event
2004-09-28	'229 Patent Priority Date
2009-01-13	'229 Patent Issued
2022-09-11	Complaint Filed

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

U.S. Patent No. 7,477,229 - Clock with Intelligent Backlight Device, issued January 13, 2009

The Invention Explained

• Problem Addressed: The patent addresses shortcomings in prior art clocks, including luminous materials that fade over time, the inconvenience of manually pressing a button to activate a backlight in the dark, and the unnecessary power consumption of backlights that remain active during the day (ʼ229 Patent, col. 1:7-52).
• The Patented Solution: The invention is a battery-powered clock that uses a photosensitive resistor to detect ambient light levels. An electronic circuit automatically activates the backlight source (e.g., an LED) when the surroundings are dark and deactivates it when they are bright, thereby conserving battery life and improving user convenience (’229 Patent, Abstract; col. 4:8-24). The backlight is powered by an integrated circuit that stabilizes voltage and current to provide consistent brightness and prolong the operational life of the batteries (’229 Patent, col. 2:58-62).
• Technical Importance: The invention provides an automated and power-managed backlighting system for battery-operated devices, allowing for "set and forget" functionality that was an improvement over manual or continuously-on systems (’229 Patent, col. 5:11-18).

Key Claims at a Glance

• The complaint does not specify which claims are asserted, but generally alleges infringement of the patent. Independent Claim 1 is the broadest claim.
• Independent Claim 1 recites:
  • A casing, a power supply (in the form of dry batteries), timing components, a printed circuit board, and time setting buttons.
  • A backlight device and a backlight source disposed within the casing.
  • The printed circuit board is installed with integrated circuits.
  • A first output of the integrated circuits drives the timing components.
  • A second output drives the backlight source through a photosensitive resistor and an electronic switch in serial connection.
  • The second output also connects to another integrated circuit to stabilize and control the voltage and current supplied to the backlight source.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The accused products are identified as "the Clock with Intelligent Backlight Device of ‘229 Patent" (Compl. ¶1), sold through various e-commerce storefronts operated by the Defendants (Compl. ¶10).

Functionality and Market Context

The complaint alleges Defendants operate e-commerce stores that sell infringing products to consumers throughout the United States, including Florida (Compl. ¶¶12-13). These storefronts are alleged to use common templates, payment methods, and marketing tactics to appear as authorized retailers, making it difficult for consumers to distinguish them from genuine sellers (Compl. ¶¶14, 17). The complaint references "screenshot printouts showing the active e-commerce stores" as Exhibit 2, which allegedly depicts the accused products for sale (Compl. ¶10). However, the complaint provides no specific technical description of how the accused products operate, beyond the conclusory allegation that they are infringing.

IV. Analysis of Infringement Allegations

The complaint does not provide sufficient detail for a claim-chart analysis. It contains only conclusory statements of infringement without mapping any specific features of the accused products to the limitations of the patent claims. The infringement allegation in Count I contains a notable inconsistency, referring to the accused product as a "one hand held, one touch Jar Opener" (Compl. ¶24), which contradicts the patent's subject matter and the complaint's own definition of the infringing products as clocks (Compl. ¶1).

• Identified Points of Contention:
  • Pleading Sufficiency: A primary legal question is whether the complaint meets the plausibility standard for patent infringement under Twombly/Iqbal, given the lack of factual allegations explaining how the accused products infringe. The explicit and contradictory reference to a "Jar Opener" in the infringement count (Compl. ¶24) may provide grounds for a motion to dismiss.
  • Technical Questions: Should the case proceed, a key factual question will be whether the accused clocks contain the specific circuitry recited in Claim 1, particularly the combination of a photosensitive resistor, an electronic switch, and a separate integrated circuit for voltage and current stabilization for the backlight.

V. Key Claim Terms for Construction

• The Term: "photosensitive resistor and an electronic switch in serial connection" (from Claim 1)
• Context and Importance: This phrase describes the core mechanism for the "intelligent" automatic operation of the backlight. The construction of this term will be central to determining whether an accused product that automatically illuminates in the dark infringes, as the specific circuit configuration is claimed, not just the general function.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party could argue that "electronic switch" should be given its plain and ordinary meaning to one of skill in the art, which could encompass a variety of transistor-based switching circuits beyond the specific one depicted.
  • Evidence for a Narrower Interpretation: The specification discloses a specific embodiment where the electronic switch is "formed by Q1 and Q2" (ʼ229 Patent, col. 4:13-14; Fig. 3). A party may argue that this detailed disclosure limits the scope of the term to the depicted configuration or its structural equivalent.

VI. Other Allegations

• Indirect Infringement: The complaint makes conclusory allegations of contributory infringement and inducement (Compl. ¶26), but alleges no specific facts to support these claims, such as the provision of instructions or components with the knowledge and intent to cause infringement.
• Willful Infringement: Willfulness is alleged based on the assertion that Defendants "have notice of or knew of the ‘229 patent" (Compl. ¶27). The complaint further alleges that the Defendants' business practices—such as operating multiple anonymous storefronts, using fraudulent registration information, and communicating in online forums about evading litigation—constitute deliberate and egregious conduct supporting a finding of willfulness (Compl. ¶¶15-18, 26).

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

1. Pleading Validity: A threshold issue for the court will be one of legal sufficiency: does the complaint, with its conclusory allegations and a significant factual error in describing the accused product in its infringement count, plead a plausible claim for patent infringement, or will it be dismissed for failure to state a claim?

2. Infringement Evidence: Assuming the case survives dismissal, a central evidentiary question will be one of technical correspondence: can the Plaintiff produce evidence that the accused clocks, sold by a diffuse network of online sellers, actually incorporate the specific, multi-component light-sensing and power-regulating circuit architecture required by the patent's claims?