Get Lit LLC v. Heilongjiang Aishuo Wangluokejiyouxiangongsi

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Get Lit, LLC (Kansas)
  • Defendant: Heilongjiang Aishuo Wangluokejiyouxiangongsi (China)
  • Plaintiff’s Counsel: Dickinson Wright PLLC
• Case Identification: 1:23-cv-01805, N.D. Ill., 03/22/2023
• Venue Allegations: Venue is alleged to be proper based on Defendant targeting and conducting business in Illinois through an interactive e-commerce store on Amazon.com, including sales of the accused products to Illinois residents.
• Core Dispute: Plaintiff alleges that Defendant’s Wi-Fi connected touch lamps infringe a patent related to communicative lighting systems that change state in response to remote user inputs.
• Technical Context: The technology involves a system of networked lights that allow for non-verbal, long-distance communication by translating a physical interaction with one device into a visual change in one or more associated devices.
• Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of infringement through Amazon on November 23, 2022, and again through its attorneys, including a detailed claim chart, on January 24, 2023. These notices may be relevant to the allegations of willful infringement.

Case Timeline

Date	Event
2016-05-02	’202 Patent Priority Date
2020-03-10	’202 Patent Issue Date
2022-11-23	Plaintiff provides first notice of infringement
2023-01-24	Plaintiff provides second notice with claim chart
2023-03-22	Complaint Filing Date

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

U.S. Patent No. 10,588,202 - "Communicative Lighting Systems"

Issued March 10, 2020

The Invention Explained

• Problem Addressed: The patent addresses the limitation of using light for communication, which has historically been restricted to the distance from which a light source is directly visible (’202 Patent, col. 1:20-31, 1:33-36).
• The Patented Solution: The invention describes a system of two or more light sources connected over a network. Each light source has a unique, permanent identifier allowing a central server to associate them. An input at one light source (e.g., a touch) causes it to send a message to the server, which in turn relays a message to the associated light source(s), causing their light output to change (’202 Patent, Abstract; col. 1:47-col. 2:13). The system architecture is depicted in Figure 1, which shows two light sources (110, 120) communicating via networks (170, 172) and a server (190).
• Technical Importance: This approach enables the use of light to convey emotion and presence over great distances where direct viewing is impossible, creating a novel form of non-verbal communication (’202 Patent, col. 1:40-46).

Key Claims at a Glance

• The complaint asserts independent claims 1 and 11 (Compl. ¶18). Claim 1, which is recited in the complaint, requires:
  • A first light source with an input mechanism, an output mechanism, a processor, memory, and a permanently assigned identifier, connected to a first network.
  • A second light source with similar components, connected to a second network.
  • A server connected to a network accessible to both light sources, which receives messages to associate the first and second light sources.
  • An input at the first light source alters the output of the second, and an input at the second alters the output of the first.
  • The system operates via a specific message pathway: input at one light source causes a message transmission to the server, which then transmits a message to the other light source to alter its light output.
• The complaint’s prayer for relief seeks a judgment of infringement of "one or more claims," preserving the right to assert additional claims (Compl. p. 7).

III. The Accused Instrumentality

Product Identification

The "Accused Products" are identified as Wi-Fi connected "touch lamps" sold under the "Hthconvey" brand through the "Ai Sound US-Store" on Amazon.com (Compl. ¶16).

Functionality and Market Context

The complaint alleges that the Accused Products operate by having users connect a lamp to Wi-Fi and set up a "Group ID," which friends or family can join. The complaint quotes the product description: "When you tap the light, all your friends and family will know it" (Compl. ¶17). This functionality is presented as the basis for infringement, mirroring the patented concept of a touch-activated, network-communicating lighting system.

IV. Analysis of Infringement Allegations

The complaint references a claim chart in its Exhibit B purporting to show that the Accused Products meet every element of independent claims 1 and 11; however, this exhibit was not filed with the complaint (Compl. ¶18, ¶25).

The narrative infringement theory is that the system of Accused Products, when used as instructed, embodies the claimed invention. The "touch lamps" are alleged to be the "first light source" and "second light source." The user's Wi-Fi connection serves as the "network." The functionality of creating a "Group ID" to link lamps implies the existence of a "server" that "associates" the devices. A user "tapping" the lamp is the "input," which allegedly causes a message to be sent to the server and then relayed to the other lamps in the group, causing their light output to alter, thereby letting friends and family "know it" (Compl. ¶17, ¶33). No probative visual evidence provided in complaint.

Identified Points of Contention

• Architectural Questions: A primary question will be whether the Accused Products' system architecture maps onto the claim's required "server"-based model. The complaint relies on marketing language, but the case will turn on technical evidence of how the "Group ID" system actually functions. The defense may argue that the system operates on a different architecture (e.g., peer-to-peer) that does not involve a central server for associating devices and relaying messages as claimed.
• Evidentiary Questions: The allegation that a tap on one lamp causes the other to light up will require proof of the specific communication pathway recited in Claim 1: a message from the first lamp to the server, and then a subsequent message from the server to the second lamp. Discovery into the defendant's network infrastructure and the data packets sent by the devices will be necessary to substantiate this element.

V. Key Claim Terms for Construction

Term for Construction: "a server"

• Context and Importance: The existence and function of "a server" is a central element of the asserted independent claim. The infringement case depends on demonstrating that the Accused Products' "Group ID" system utilizes a component that meets the legal definition of this term, specifically by "receiving messages...to associate" the light sources and relaying messages between them. Practitioners may focus on this term because the defendant's system architecture is unknown and may not align with a traditional understanding of a single, centralized server.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent specification describes the server in functional terms, without limiting it to a specific hardware configuration. It is depicted as a single block (190) in Figure 1 and described as a component that can be reached via an address that "may be permanent or temporary" (’202 Patent, col. 4:60-67). This could support a construction covering a range of implementations, including distributed or cloud-based systems that perform the claimed functions.
  • Evidence for a Narrower Interpretation: The claim consistently uses the singular term "a server." This could support an argument that the claim requires a single, discrete entity, potentially one operated or controlled by the defendant, rather than a distributed set of resources.

Term for Construction: "permanently assigned first identifier"

• Context and Importance: This term is critical for distinguishing the claimed light sources from generic network devices. The infringement analysis will require determining if the Accused Products have an identifier that is "permanently assigned." The nature of this identifier (e.g., a MAC address, a manufacturer-set serial number) and the degree to which it is unchangeable will be a point of dispute.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests the identifier's purpose is to "facilitate the unique identification of individual light sources" and notes that it "may be provided during the manufacturing of a given light source" (’202 Patent, col. 5:8-14). This suggests the key quality is its uniqueness and its assignment at a foundational level, not necessarily that it is physically impossible to alter.
  • Evidence for a Narrower Interpretation: The word "permanently" implies immutability. If the identifier used by the Accused Product can be changed by the end-user or is otherwise not fixed for the life of the device, a defendant may argue that this limitation is not met.

VI. Other Allegations

Indirect Infringement

The complaint pleads induced infringement (mislabeled as "Contributory Patent Infringement"), alleging Defendant had knowledge of the ’202 Patent since at least November 23, 2022 (Compl. ¶32). It alleges Defendant intentionally encourages infringement by selling the Accused Products and providing instructions on its Amazon store for users to connect and operate them in an infringing manner (Compl. ¶33).

Willful Infringement

Willfulness is alleged based on Defendant’s continued infringing conduct after receiving two separate notices of infringement from Plaintiff, one in November 2022 and a more detailed one with a claim chart in January 2023 (Compl. ¶26-27).

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

• A core issue will be one of architectural equivalence: Does the Defendant’s "Group ID" system rely on the specific "server"-based architecture required by Claim 1? The case will likely depend on technical evidence from network analysis and source code review to determine if a central component performs the claimed functions of "associating" devices and "relaying" messages between them.
• A second key issue will be one of definitional scope: Can the "permanently assigned ... identifier" required by the patent be read to cover the type of identifier used in the accused lamps? This will involve claim construction and a factual inquiry into whether the Accused Products' identifiers are fixed in a manner that provides the "unique identification" taught by the patent.