Magic Christmas HK Co Ltd v. Holiday Deco

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Magic Christmas (HK) Co. Ltd. (China)
  • Defendant: Holiday Deco (China)
  • Plaintiff’s Counsel: Feldenkrais Law, P.A.
• Case Identification: 1:25-cv-25656, S.D. Fla., 12/03/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant, an alien entity, targets and sells the accused products to consumers in the district through an Amazon e-commerce store and is subject to personal jurisdiction.
• Core Dispute: Plaintiff alleges that Defendant’s LED lighting products infringe patents related to systems for transmitting power and control signals to LED light strings over a single power line.
• Technical Context: The technology involves methods for simplifying the wiring and control of complex, multi-light LED systems, such as decorative light strings, by combining power and data transmission.
• Key Procedural History: The complaint states that a prior, similar action against multiple defendants was dismissed without prejudice for improper joinder, and this case was re-filed against a single defendant. The complaint also notes that the licensor of the patents-in-suit has previously filed two other infringement actions, one of which was voluntarily dismissed and the other stayed.

Case Timeline

Date	Event
2009-11-06	U.S. Patent No. 8,344,659 Priority Date (Filing Date)
2013-01-01	U.S. Patent No. 8,344,659 Issued
2019-03-14	U.S. Patent No. 10,863,608 Priority Date (Foreign Application)
2020-12-08	U.S. Patent No. 10,863,608 Issued
2025-11-17	Prior related case (1:25-cv-23748) dismissed without prejudice
2025-12-03	Complaint Filed

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

U.S. Patent No. 10,863,608 - “Light-Emitting Diode Driving System for Transmitting Signal Based on Power Line” (Issued Dec. 8, 2020)

The Invention Explained

• Problem Addressed: The patent’s background section describes prior art LED driving systems as having weak signal generation circuits, which can cause the display effect of an LED light string to be unstable (’608 Patent, col. 1:36-42).
• The Patented Solution: The invention uses a control unit to alternate between a "main power supply" and a "secondary power supply," which provide different voltage levels. This creates a composite light emission driving signal transmitted over the power line. By switching between two active power sources rather than turning a single source on and off, the system ensures the switch unit is always in a "turned-on state," providing uninterrupted power and keeping the LED string in a normal operating state (’608 Patent, Abstract; col. 2:35-42). The complaint reproduces the patent's Figure 1 to illustrate this system architecture (Compl. p. 4).
• Technical Importance: This approach is designed to provide stable and continuous power and signals to an LED light string, thereby avoiding the flickering or instability seen in prior systems (’608 Patent, col. 2:35-42).

Key Claims at a Glance

• The complaint asserts infringement of at least independent Claim 1 (Compl. ¶25, ¶52).
• Claim 1 requires:
  • A switch unit, a control unit, a main power supply, and a secondary power supply.
  • The switch unit having a main input end connected to the main power supply, a secondary input end connected to the secondary power supply, a controlled end connected to the control unit, and an output end connected to an LED light string.
  • The switch unit is always turned on when the control unit is operating.
  • The switch unit imports current from the main power supply upon receiving a high level signal from the control unit.
  • The switch unit imports current from the secondary power supply upon receiving a low level signal from the control unit.
  • The switch unit outputs a light emission driving signal composed of the main and secondary current power supplies to maintain stable light emission.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 8,344,659 - “System and Method for Lighting Power and Control System” (Issued Jan. 1, 2013)

The Invention Explained

• Problem Addressed: The patent’s background section describes the significant complexity and expense of designing and manufacturing large-scale LED display systems, which require providing carefully metered and individually controlled electrical power to potentially millions of individual LEDs (’659 Patent, col. 1:46-61).
• The Patented Solution: The invention provides a "single-wire" power and control system. A "line driver circuit" at the head of the system drives an electrical current down a single output line. This line connects a series of individual "controlled units" (each operating one or more LEDs). Digital control data is modulated directly onto the electrical current, and each controlled unit draws its operating power from that same current while also demodulating the data to control its specific LED(s) (’659 Patent, Abstract; col. 5:21-32). The complaint includes a figure from the patent illustrating this architecture (Compl. p. 4).
• Technical Importance: This system architecture greatly simplifies the wiring required to construct complex, individually-addressable LED lighting or display systems, thereby significantly reducing design and construction costs (’659 Patent, col. 5:26-32).

Key Claims at a Glance

• The complaint asserts infringement of at least independent Claim 1 (Compl. ¶25, ¶52).
• Claim 1 requires:
  • A power supply for supplying electrical power.
  • A line driver circuit receiving power from the power supply and digital illumination control data from a controller.
  • The line driver circuit driving an output line with an electrical current and modulating the control data onto that current.
  • More than one controlled unit coupled in a series arrangement to the output line.
  • Each controlled unit drawing operating power from the electrical current on the output line.
  • Each controlled unit demodulating the control data from the output line.
  • Each controlled unit using the control data to control at least one illumination device.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

• Product Identification: The complaint does not identify specific accused products by name or model number. It refers to them generally as "Infringing Product" and "Counterfeit Copies" sold by Defendant Holiday Deco through an Amazon.com e-commerce storefront (Compl. ¶3, ¶19, ¶29).
• Functionality and Market Context: The complaint alleges that the accused products are LED lighting systems that embody the patented technologies (Compl. ¶25, ¶29). Specifically, it alleges the products provide an "LED driving system for transmitting a lamp control signal based on a single power line" (Compl. ¶9), consistent with the technology of the patents-in-suit. The complaint states that a pre-suit investigation, including lab testing and the creation of a claim chart, was conducted, but the results of that investigation are contained in exhibits that were not filed with the complaint (Compl. ¶25, Exs. 2-3).

IV. Analysis of Infringement Allegations

The complaint alleges that the accused products infringe at least Claim 1 of both the ’608 and ’659 patents (Compl. ¶25, ¶52). It references a claim chart (Exhibit 2) that was not provided with the complaint. Therefore, a claim chart summary cannot be constructed.

The narrative infringement theory alleges that Defendant’s products are "exact copies, or copies that literally embody the elements of at least one claim" of the patents-in-suit (Compl. ¶29). For the ’608 Patent, the complaint alleges the accused products incorporate a system using a switch unit to select between main and secondary power sources to create a stable driving signal on a single power line (Compl. ¶9). For the ’659 Patent, the complaint alleges the accused products incorporate a system with a line driver that modulates control data onto an electrical current to power and control multiple series-connected lighting units (Compl. p. 4).

• Identified Points of Contention:
  • Evidentiary Questions: As the complaint’s allegations are conclusory and rely on un-filed exhibits, a primary question will be whether discovery and expert analysis produce sufficient evidence to map the specific components and functionality of the accused products to the elements of the asserted claims.
  • Technical Questions (’608 Patent): A potential dispute may arise over whether the accused products’ power delivery architecture constitutes distinct "main" and "secondary" power supplies as required by Claim 1, or if it uses a single, variable power source that functions differently from the claimed invention.
  • Scope Questions (’659 Patent): A central issue may be whether the signaling method used in the accused products meets the claim limitation of "modulating said digital illumination control data onto said electrical current." The interpretation of this term, in light of the specific modulation scheme depicted in the patent’s figures, could be a key point of contention.

V. Key Claim Terms for Construction

’608 Patent, Claim 1:

• The Term: "a main power supply, and a secondary power supply"
• Context and Importance: This limitation defines the core power architecture of the claimed system. The infringement analysis will depend on whether an accused product must have two structurally or logically separate power sources, or if a single power source capable of outputting two different power levels would suffice. Practitioners may focus on this term to determine if the accused device's power management system falls within the claim's scope.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself does not specify that the supplies must be physically separate components. One might argue that any system capable of providing two distinct, selectable current or voltage levels from a "main" and "secondary" source meets the limitation, regardless of physical implementation.
  • Evidence for a Narrower Interpretation: The patent's Figure 1 depicts "Main power supply source" (4) and "Secondary power supply source" (5) as distinct blocks, which may suggest they are separate components (’608 Patent, Fig. 1). The specification refers to them having "two different voltage values," which could imply two separate sources are required to generate these values (’608 Patent, col. 2:28-30).

’659 Patent, Claim 1:

• The Term: "modulating said digital illumination control data onto said electrical current"
• Context and Importance: This term is central to how the patented system transmits information. The case may turn on whether the accused product's signaling method is properly characterized as "modulating," especially when compared to the specific embodiments disclosed in the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: Claim 1 uses the general term "modulating." Dependent Claim 3 further specifies "using increases and decreases of electrical current," which is still a relatively broad description of amplitude modulation (’659 Patent, col. 42:64-66).
  • Evidence for a Narrower Interpretation: The specification discloses a specific modulation technique involving positive and negative current spikes relative to a "nominal current value" (’659 Patent, Fig. 3; col. 8:1-10). A party could argue that the term "modulating" should be construed in light of this detailed disclosure, potentially limiting the claim's scope to this or similar forms of modulation and excluding other signaling methods.

VI. Other Allegations

• Indirect Infringement: The complaint makes a conclusory allegation of indirect infringement (Compl. ¶45) but provides no specific facts to support the knowledge and intent elements required for induced or contributory infringement.
• Willful Infringement: The complaint alleges that Defendant’s infringement is willful (Compl. ¶3, ¶47, ¶51). This allegation is based on the assertion that Defendant "knew or should have known of Plaintiff's ownership of the Patents" and acted with "reckless disregard or willful blindness to Plaintiff's rights" (Compl. ¶31, ¶33). The complaint does not allege specific facts indicating pre-suit knowledge of the patents.

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

1. A central issue will be one of evidentiary sufficiency: Can the Plaintiff, through discovery and expert testimony, produce the specific technical evidence required to map the functionality of the accused products onto each element of the asserted claims, thereby substantiating the currently conclusory allegations that rely on un-filed exhibits?
2. The case may turn on a question of architectural scope: For the ’608 Patent, does the term "a main power supply, and a secondary power supply" require two structurally distinct sources, or can it be construed to cover a single power unit capable of producing different, selectable output levels?
3. A key question of technical interpretation will arise for the ’659 Patent: Does the accused products' method for transmitting control signals over the power line constitute "modulating... onto said electrical current" as construed in light of the patent's specification, or is there a fundamental mismatch in the signaling technology employed?