DCT

1:23-cv-15836

Hong Kong Xingtai Intl Trade Co Ltd v. T Schedule A

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:23-cv-15836, N.D. Ill., 02/12/2024
  • Venue Allegations: Venue is based on allegations that the defendants operate interactive e-commerce stores that target and make sales to consumers in the United States, including within the state of Illinois.
  • Core Dispute: Plaintiff alleges that a network of online sellers, operating under various aliases, are infringing a patent for solar-powered outdoor decorative string lights.
  • Technical Context: The technology concerns self-contained, solar-powered consumer lighting products designed to operate automatically, eliminating the need for household electrical outlets and manual switching.
  • Key Procedural History: The filing is a First Amended Complaint against a "Schedule A" list of unnamed defendants, a legal strategy commonly employed against diffuse online seller networks to overcome challenges in identifying the responsible parties. The complaint does not mention any prior litigation or post-grant proceedings involving the patent-in-suit.

Case Timeline

Date Event
2008-07-14 '545 Patent Priority Date
2010-10-26 '545 Patent Issue Date
2024-02-12 Complaint Filing Date

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

U.S. Patent No. 7,819,545 - "Outdoor Solar Decorative Lights"

  • Patent Identification: U.S. Patent No. 7,819,545, "Outdoor Solar Decorative Lights", issued October 26, 2010.

The Invention Explained

  • Problem Addressed: The patent identifies the safety hazards and inconvenience associated with traditional, plug-in outdoor decorative lights. These problems include the risk of electrical shorts from exposure to weather and the physical hazard of tripping over long extension cords needed to reach outdoor power outlets ('545 Patent, col. 1:35-49).
  • The Patented Solution: The invention is a self-contained lighting system that eliminates the need for external power. It comprises a string of lights electrically connected to a solar collector unit, which contains solar panels, a rechargeable battery, and a light-sensing switch. This switch automatically activates the lights at dusk and deactivates them at dawn, providing a safe and automated alternative to conventional string lights ('545 Patent, col. 2:23-39; Fig. 7).
  • Technical Importance: The patented approach sought to improve the convenience, safety, and energy efficiency of a widely used consumer product by integrating solar power generation, energy storage, and automatic environmental sensing into a single system ('545 Patent, col. 2:45-49).

Key Claims at a Glance

  • The complaint asserts independent Claim 1 and alleges infringement of all claims ('545 Patent, Compl. ¶30).
  • The essential elements of independent Claim 1 are:
    • A flexible, elongated light string with an internal electrical wire.
    • A plurality of evenly spaced sockets mounted on the string.
    • A plurality of light bulbs mounted in the sockets.
    • A solar collector electrically connected to the light string.
    • The solar collector includes a housing, at least one solar panel, and a rechargeable battery.
    • A regulator switch that automatically switches the lights on and off, being in an "open state from sunrise to sunset" and a "closed state upon sunset."
  • The complaint notes that Claims 2-3 are dependent claims and reserves the right to assert them (Compl. ¶9, ¶30).

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as "Unauthorized Products," which are solar-powered outdoor decorative string lights (Compl. ¶3).

Functionality and Market Context

The complaint alleges that defendants sell these products through various e-commerce storefronts on platforms including Amazon, eBay, and Temu (Compl. ¶14). A screenshot provided as Figure 1 in the complaint depicts an accused product described as "Solar String Lights for Outside" featuring a solar panel and a light sensor that "controls the solar globe lights auto on at dark and auto off at daytime" (Compl. p. 5, Fig. 1). The complaint characterizes the defendants as a network of infringers who use fictitious aliases and other tactics to conceal their identities while profiting from the alleged infringement (Compl. ¶3, ¶13, ¶22).

IV. Analysis of Infringement Allegations

The complaint references an illustrative claim chart in an exhibit that was not attached to the filing; however, the complaint's narrative allegations and visual evidence form the basis for the following summary of Plaintiff's infringement theory against the accused products.

'545 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
An outdoor decorative solar powered lighting system, comprising a flexible, elongated light string; The accused products are described as "Solar String Lights" that are flexible and elongated for outdoor decoration. A visual example is provided in the complaint's Figure 1 (Compl. p. 5, Fig. 1). ¶3, ¶14 col. 4:15-16
an electrical wire extending through the light string and commensurate in length therewith; The complaint alleges the accused products are functional light strings which, by necessity, contain an electrical wire to power the bulbs. ¶8, ¶30 col. 4:19-20
a plurality of sockets mounted on the light string and spaced evenly therealong; The accused products are shown with multiple light bulbs, which are mounted in sockets along the string. ¶8; p. 5, Fig. 1 col. 4:20-22
a solar collector electrically connected to the light string... The accused products are advertised as "Solar Powered" and include a distinct solar collector unit connected to the string of lights (Compl. p. 5, Fig. 1). ¶8; p. 5, Fig. 1 col. 4:48-49
the solar collector including a housing and at least one solar panel supported in the housing for collecting radiant energy from the sun; The accused products are depicted with a housing containing a solar panel for energy collection. ¶8; p. 5, Fig. 1 col. 4:50-54
a rechargeable battery contained within the housing and electrically connected to the solar panel... The accused products are described as solar-powered, which implies the presence of a rechargeable battery to store energy for nighttime use. The patent number listed in the accused product's description further suggests this feature (Compl. p. 5, Fig. 1). ¶8; p. 5, Fig. 1 col. 4:53-56
a regulator switch...for automatically switching the light bulbs on and off whereby the switch is disposed to the open state from sunrise to sunset...and the switching automatically going to the closed state upon sunset... The description for an accused product explicitly states that a "Light sensor controls the solar globe lights auto on at dark and auto off at daytime," which directly corresponds to the claimed automatic switching function (Compl. p. 5, Fig. 1). ¶8; p. 5, Fig. 1 col. 5:14-25

Identified Points of Contention

  • Evidentiary Questions: The central challenge for the plaintiff may not be proving the products infringe, but rather providing sufficient evidence to link the specific, anonymous "Schedule A" defendants to the manufacture, importation, or sale of the accused products.
  • Scope Questions: A potential point of dispute could involve the term "spaced evenly therealong." The defense could argue for a strict, literal interpretation of "evenly" and present evidence that the accused products' sockets have spacing variations, raising the question of whether such variations fall outside the claim's scope.

V. Key Claim Terms for Construction

  • The Term: "regulator switch"
  • Context and Importance: This term defines the core automatic functionality of the invention. The construction of this term will determine whether any automatic on/off mechanism is covered or only one that operates in the specific manner described in the patent.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself is functional, defining the switch by what it does: "for automatically switching the light bulbs on and off" ('545 Patent, col. 6:19-21). This may support an argument that any component performing this function infringes.
    • Evidence for a Narrower Interpretation: The specification describes a specific operational logic based on ambient light detection: "the switch 66 is maintained in an open state during periods of daylight (detection of light...)" and is "disposed to the closed state by the non-detection of light" ('545 Patent, col. 5:17-22). The flowchart in Figure 7 further illustrates this light-dependent logic, which could be used to argue for a narrower construction limited to light-sensing switches.

VI. Other Allegations

  • Indirect Infringement: The complaint's prayer for relief seeks to enjoin defendants from "Aiding, abetting, contributing to, or otherwise assisting anyone in infringing" ('545 Patent, p. 13, ¶1(b)). The factual basis for such a claim may rest on allegations that defendants import infringing products "for subsequent resale or use," potentially implicating them in inducing infringement by downstream sellers or end-users (Compl. ¶29).
  • Willful Infringement: The complaint alleges that defendants' infringement "has been and continues to be willful" (Compl. ¶34). This allegation is supported by claims of knowing conduct (Compl. ¶26, ¶29) and, most notably, by visual evidence. Figure 1 in the complaint is a screenshot of an accused product listing on Amazon that explicitly states "Patent Number: US7819545B2" in the product description, which, if authenticated, would be strong evidence of pre-suit knowledge of the patent (Compl. p. 5, Fig. 1).

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

  • A primary issue will be procedural and evidentiary: can the plaintiff successfully pierce the defendants' alleged anonymity to link the specific entities on Schedule A to the sale of the accused products? The case's progression may depend heavily on the success of early discovery and enforcement actions against the online marketplace platforms themselves.
  • A second core question will concern willfulness and damages: given that some accused product listings allegedly display the patent number, the dispute may focus less on the technical question of infringement and more on the legal question of intent. Evidence proving the defendants knowingly advertised their products using the plaintiff's patent number would significantly strengthen the claim for willful infringement and potential treble damages.