Shangyou Jiayi Lighting Prodcut Co Ltd v. Partnerships Unincorp Associations

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Shangyou Jiayi Lighting Product Co., Ltd. (China)
  • Defendant: The Partnerships and Unincorporated Associations Identified on Schedule A
  • Plaintiff’s Counsel: AVEK IP, LLC
• Case Identification: 1:24-cv-15248, N.D. Ill., 02/16/2024
• Venue Allegations: Venue is alleged to be proper based on Defendants' operation of interactive e-commerce stores that directly target and make sales to consumers in the United States, including within the state of Illinois.
• Core Dispute: Plaintiff alleges that "vine lamp products" sold by a network of online retailers infringe a patent related to the specific construction of decorative light strings.
• Technical Context: The technology relates to flexible, decorative LED light strings, often marketed as "vine lamps" or "fairy lights," designed for aesthetic and holiday lighting.
• Key Procedural History: The complaint is structured as an action against a group of unidentified online sellers, identified in an attached schedule by their seller aliases. Plaintiff alleges joinder is proper under 35 U.S.C. § 299 because the defendants are all allegedly selling the same or similar infringing products and their conduct arises from the same series of transactions.

Case Timeline

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

U.S. Patent No. 10,082,258 - "VINE LAMP AND PRODUCTION METHOD," issued September 25, 2018

The Invention Explained

• Problem Addressed: The patent identifies shortcomings in traditional LED decorative light strings, such as their large volume, thick wires, difficulty in packaging and installation, and poor waterproofing, which limits their suitability for outdoor use (’258 Patent, col. 1:20-32). The complaint notes this solves the issue of "traditional vine lamp products having a bloated size" (Compl. ¶8).
• The Patented Solution: The invention is a "vine lamp" constructed from multiple "light strings." In each string, light-emitting components are welded directly to parallel wires, and these connections are sealed within a "lamp bead." The key feature is the structure of the wire between the lamp beads, which is divided into three sequential sections. The first and third sections, which flank the lamp bead, are twisted together. The "second conducting wire section," located between the twisted portions, is not twisted with them. Instead, the "second" sections from multiple different light strings are wound together to form the main "vine." (’258 Patent, Abstract; col. 5:55-68).
• Technical Importance: This construction method is purported to create a more compact, flexible, and weather-resistant decorative light string, while also enabling a 360-degree light irradiation from the exposed lamp beads (’258 Patent, col. 2:11-25).

Key Claims at a Glance

• The complaint asserts infringement of "at least claim 1" (Compl. ¶24).
• The essential elements of independent claim 1 include:
  • A plurality of light strings, each with light emitting components and two side-by-side conducting wires.
  • The wires have insulating layers with openings where the light emitting components are welded to the conductors.
  • A transparent encapsulation layer covers the connection point, forming a "lamp bead."
  • The conducting wire between any two lamp beads is divided into a first, second, and third section in sequence.
  • The first and third sections (flanking a lamp bead) are wound with each other, but not with the second section.
  • The second section of a given light string is wound with the second sections from other light strings.

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are "vine lamp products" ("the Infringing Products") offered for sale and sold by the Defendants through their online e-commerce stores (Compl. ¶4).

Functionality and Market Context

The complaint alleges that the Defendants operate a network of online stores that sell products embodying the patented design (Compl. ¶5, ¶8). It is alleged that these stores share common features, such as using the same product images, pricing strategies, and marketing text, suggesting a coordinated effort to sell the same infringing goods while obscuring the identities of the operators (Compl. ¶14). The complaint includes a representative figure illustrating the claimed wire structure, which it alleges is a feature of the Infringing Products (Compl. p. 4).

IV. Analysis of Infringement Allegations

The complaint does not contain a detailed claim chart. The infringement theory is based on the allegation that the "Infringing Products" possess the unique structural design claimed in the ’258 patent. The complaint includes a representative figure illustrating the claimed wire structure, showing thicker, wound sections of wire adjacent to un-wound sections that branch off (Compl. p. 4).

’258 Patent Infringement Allegations

Identified Points of Contention

• Evidentiary Questions: The complaint makes collective allegations against a schedule of unidentified online sellers. A central issue will be whether the Plaintiff can produce evidence that the specific products sold by each individual Defendant actually practice every limitation of the asserted claim.
• Technical Questions: The infringement analysis will depend on whether the accused products physically embody the specific three-part wire structure. What evidence does the complaint provide that the accused products' wires are divided into three distinct sections, and that the first and third sections are "wound with each other" while the second section is specifically not wound with them, but is instead wound with sections from other strings? The complaint's allegations on this point are conclusory (Compl. ¶24).

V. Key Claim Terms for Construction

• The Term: "wound with each other"
• Context and Importance: This term is used to define both the relationship between the first and third wire sections on a single string and the relationship between the second wire sections of different strings. The precise meaning of "wound" is critical to determining if a product's construction infringes, as it distinguishes the claimed invention from a simple twist or bundling of wires.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification uses the terms "intersect and are winded with each other" without defining a required tightness or number of turns, which may support an argument that any intentional intertwining meets the limitation (’258 Patent, col. 2:21-22).
  • Evidence for a Narrower Interpretation: The patent discloses using a "numerical control filament winder" to create the product (’258 Patent, col. 4:43-44). A party could argue this implies a regular, mechanically precise winding, as depicted in Figure 7, and that a loose or haphazard manual twisting would not qualify as being "wound."

VI. Other Allegations

• Indirect Infringement: The complaint makes a conclusory allegation of direct "and/or indirect" infringement (Compl. ¶18, ¶23) but does not plead specific facts to support a claim for either induced or contributory infringement, such as references to user manuals or product components.
• Willful Infringement: Willfulness is alleged based on the assertion that Defendants "knowingly and willfully" offered for sale infringing products (Compl. ¶18, ¶19). The complaint further alleges on "information and belief" that the defendants communicate in online groups and use websites concerning tactics for evading enforcement, which may be used to argue pre-suit knowledge of infringement (Compl. ¶16).

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

• A primary issue will be one of evidentiary linkage: can the Plaintiff, facing numerous anonymous online sellers, produce sufficient evidence to prove that the specific products sold by each named defendant practice every element of the asserted claim, particularly the complex wire structure?
• The case will also turn on a question of structural specificity: do the accused products actually possess the claimed three-part wire division where sections flanking the LEDs are "wound with each other," while the intermediate section is specifically not wound with them but is instead wound with corresponding sections from entirely separate light strings? Proving this precise combination of positive and negative structural limitations will be central to the infringement analysis.