DCT
1:20-cv-00247
E Link Technology Co Ltd v. Shenzhen Uni Sun Electronics Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: E-Link Technology Co., Ltd. (China)
- Defendant: Shenzhen Uni-Sun Electronics Co., Ltd, and Unknown Persons and/or Entities doing business under Amazon Seller IDs “FEISHAZO”, “LEMONGREEN”, AND “JIANGKUN” (China)
- Plaintiff’s Counsel: Wang, Leonard & Condon
- Case Identification: 1:20-cv-00247, N.D. Ill., 01/13/2020
- Venue Allegations: Venue is alleged to be proper because the defendants are foreign corporations with no regular and established place of business in the U.S. and have allegedly committed acts of infringement by selling products into the Northern District of Illinois via Amazon.
- Core Dispute: Plaintiff alleges that Defendants’ hoverboards, sold under various brand names, infringe a patent related to a wheel design that creates an "endless lights" or "infinity mirror" visual effect.
- Technical Context: The technology concerns a specific optical assembly within a vehicle wheel that uses multiple mirrors and an LED strip to create the illusion of lights receding into an infinite depth.
- Key Procedural History: The complaint alleges that Plaintiff first became aware of the accused infringing products being sold in the United States in or around November 2019.
Case Timeline
| Date | Event |
|---|---|
| 2017-12-22 | ’081 Patent Priority Date |
| 2019-07-23 | ’081 Patent Issue Date |
| 2019-11-01 (approx.) | Plaintiff first noticed Defendants' accused product sales |
| 2020-01-13 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. 10,358,081 - “WHEELED VEHICLE AND WHEEL OF THE SAME”, issued July 23, 2019.
The Invention Explained
- Problem Addressed: The patent’s background section states that while many wheeled vehicles like scooters have light-emitting wheels, the effects are often "relatively simple," and the "pleasure to the public need[s] to be improved" (’081 Patent, col. 2:29-32).
- The Patented Solution: The invention uses a specific optical arrangement to create a more compelling visual. A Light Emitting Diode (LED) light bar is placed between a conventional flat mirror and a "two-way mirror" (a semi-transparent, semi-reflective surface) (’081 Patent, Abstract). Because the mirrors are positioned to face the LEDs, light reflects back and forth, creating multiple images that appear to recede into the distance, generating a "black hole illusion that the LED lights extend indefinitely into the interior of the wheel" (’081 Patent, col. 2:32-35). This creates what the complaint calls the "endless lights" effect (Compl. ¶24).
- Technical Importance: This design achieves a complex visual effect ("hollow visual effect") with only a single set of LEDs, which can attract consumer attention while potentially reducing power consumption compared to other lighting methods (’081 Patent, col. 2:35-44).
Key Claims at a Glance
- The complaint asserts independent claims 1 and 9, and dependent claims 2, 7-8, 10-11, and 18-20 (Compl. ¶43).
- Independent Claim 1 breaks down into the following essential elements:
- A wheel body comprising a light-emitting module;
- The light-emitting module comprises an LED light bar, a flat mirror, and a two-way mirror;
- The LED light bar is arranged between the flat mirror and the two-way mirror;
- A mirror surface of the flat mirror and a reflective surface of the two-way mirror both face the LED light bar;
- A transparent surface of the two-way mirror faces an outer side of the wheel.
- The complaint alleges infringement of these claims either literally or under the doctrine of equivalents (Compl. ¶43).
III. The Accused Instrumentality
Product Identification
- The accused products are "Uni-Sun Hoverboards," specifically identified as model number HY-A06 (Compl. ¶29). These are allegedly sold under various brand names, including "FLYING-ANT," "SISIGAD," and "BENEDI," through different Amazon seller accounts (Compl. ¶5, ¶30).
Functionality and Market Context
- The key accused functionality is the hoverboards' wheel design. The complaint provides an image of a label from a purchased product identifying it as "Model: HY-A06" and listing the manufacturer as "Shenzhen Uni-sun Electronics Co., LTD" (Compl. p. 7).
- The complaint alleges the wheels of the accused products create the same "endless lights effect" as the patented invention (Compl. ¶41). It cites marketing descriptions from the defendants' Amazon listings, which describe the wheels as having an "[e]xcellent flashing wheel design" (Compl. ¶37) and a "magic mirror" effect that makes the wheel look like a "beautiful kaleidoscope" or a "time and space tunnel" (Compl. ¶38). A side-by-side photographic comparison is provided to show the visual similarity between Plaintiff's authorized product and the accused product (Compl. p. 8).
IV. Analysis of Infringement Allegations
- '081 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a wheel body comprising a light-emitting module; | The accused products are alleged to include at least one wheel with a light emitting module. | ¶40 | col. 5:1-2 |
| the light-emitting module comprises a Light Emitting Diode (LED) light bar, a flat mirror, and a two-way mirror; | The light emitting module is alleged to include an LED light bar, a flat mirror, and a two-way mirror. | ¶40 | col. 5:3-6 |
| wherein the LED light bar is arranged between the flat mirror and the two-way mirror; | The LED light bar in the accused product is alleged to be arranged between the flat mirror and the two-way mirror. | ¶40 | col. 5:6-8 |
| both a mirror surface of the flat mirror and a reflective surface of the two-way mirror face the LED light bar; | The mirror surface of the flat mirror and the reflective surface of the two-way mirror are both alleged to face the LED light bar. | ¶40 | col. 5:8-11 |
| and a transparent surface of the two-way mirror faces an outer side of the wheel. | The accused product's wheel is alleged to create an "endless lights effect," which implies the presence of an outward-facing transparent surface through which the effect is viewed. | ¶41 | col. 5:11-13 |
- Identified Points of Contention:
- Evidentiary Question: The complaint's infringement allegations largely mirror the language of the claim itself (Compl. ¶40). A central question will be what factual evidence Plaintiff possesses to support its allegations about the specific internal structure of the accused wheels. The complaint appears to infer the presence of a "flat mirror" and a "two-way mirror" from the external visual appearance and from marketing language rather than from a direct analysis of the product's components.
- Scope Questions: The dispute may turn on whether the accused product's lighting system, even if it creates a similar visual effect, is constructed in the specific manner required by the claims. For example, does the accused wheel use a component that meets the definition of a "two-way mirror" and is it "arranged between" that mirror and a separate "flat mirror" as claimed?
V. Key Claim Terms for Construction
The Term: "two-way mirror"
Context and Importance: This term is the technological heart of the invention. The infringement case depends on proving that the accused product contains a component that meets the definition of a "two-way mirror." Practitioners may focus on this term because the accused product might use an alternative optical element (e.g., a polished surface, a partially silvered plastic) that Defendants could argue falls outside the scope of this term.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims themselves define the term by its function: it must have a "reflective surface" facing the LEDs and a "transparent surface" facing the outside of the wheel (’081 Patent, col. 5:9-13). A party could argue that any component that performs these two functions meets the definition, regardless of its specific material composition.
- Evidence for a Narrower Interpretation: A party could argue that the term should be understood in the context of the described embodiment, which shows it as a distinct, ring-shaped component (’081 Patent, Fig. 1, element 5; col. 4:17-18). The specification also repeatedly refers to it as a "mirror," which may imply a specific class of optical device rather than any semi-reflective surface.
The Term: "arranged between"
Context and Importance: This term defines the required spatial relationship of the three core optical components. Infringement requires proving the LED light bar is physically located in the space separating the flat mirror and the two-way mirror.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The plain meaning of the term suggests a general positioning in the intermediate space.
- Evidence for a Narrower Interpretation: The specification describes an embodiment where the LED light bar, flat mirror, and two-way mirror are all "inlaid in the bracket 3 in turn" (’081 Patent, col. 4:24-25). A party could argue this specific sequence and mounting method informs the meaning of "arranged between," potentially narrowing it to exclude other configurations.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Defendants actively induce infringement by "soliciting and sourcing the manufacture of the Accused Products," "licensing and transferring technology and know-how," and "advertising the infringing...technology" (Compl. ¶46).
- Willful Infringement: The complaint alleges Defendants "knew or should have known" their actions constituted infringement and acted with "willful[] blind[ness]" (Compl. ¶47-48). The basis for knowledge is not explicitly stated as pre-suit notice but may be inferred from the continued sales after the lawsuit was filed.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of evidentiary sufficiency: Can Plaintiff provide factual proof, beyond conclusory allegations and observations of an external visual effect, that the internal architecture of the accused hoverboard wheel contains the specific three-part optical assembly—a flat mirror, a two-way mirror, and an LED bar arranged between them—as mandated by the patent claims?
- The case may also hinge on a question of definitional scope: Does the term "two-way mirror," as used in the patent, cover any material that is partially reflective and partially transparent, or is it limited by the specific embodiments to a more conventional optical component, potentially allowing Defendants to argue their product employs a non-infringing alternative?