Dongguan Guanyi Light Decoration Co Ltd v. Partnerships Unincorp Associations

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Dongguan Guanyi Light-Decoration Co., Ltd. (China)
  • Defendant: The Partnerships and Unincorporated Associations Identified on Schedule A
  • Plaintiff’s Counsel: AVEK IP, LLC
• Case Identification: 1:24-cv-04625, N.D. Ill., 06/04/2024
• Venue Allegations: Venue is asserted based on Defendants targeting business activities toward consumers in Illinois through interactive e-commerce stores, offering shipping to the state, and allegedly making sales to Illinois residents.
• Core Dispute: Plaintiff alleges that string light products sold by numerous unidentified online merchants infringe a patent related to waterproof and shatterproof light string design.
• Technical Context: The technology concerns outdoor decorative string lights, a consumer product category where durability against weather and physical impact is a significant feature.
• Key Procedural History: This case is filed against a group of unidentified defendants, listed in a sealed Schedule A. Plaintiff alleges the defendants are a network of online infringers operating under multiple aliases and asserts that joinder is proper under 35 U.S.C. § 299 because they are all alleged to be selling the same or similar infringing products.

Case Timeline

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

U.S. Patent No. 11,408,585, "WATERPROOF AND SHATTERPROOF LIGHT STRING" (Issued Aug. 9, 2022)

The Invention Explained

• Problem Addressed: The patent’s background section notes that conventional decorative light strings have shortcomings, including being easily broken when dropped or squeezed and lacking a waterproof function, which makes them susceptible to damage from rain or accidental water exposure ('585 Patent, col. 1:21-32).
• The Patented Solution: The invention addresses these issues through a dual-feature design. First, to prevent breakage, the bulb is made with a "shatterproof plastic bulb shell" ('585 Patent, col. 2:49-51). Second, to manage water intrusion, the design incorporates a "circumferential gap" between the lamp holder and the bulb, which intentionally allows water to enter, and a "water discharge port" on the side of the lamp holder that allows the water to drain out, preventing short circuits or damage ('585 Patent, col. 2:44-49; Fig. 3).
• Technical Importance: This design approach offers a method for weatherproofing consumer-grade lighting that manages water rather than attempting to seal it out completely, potentially improving durability in outdoor settings.

Key Claims at a Glance

• Independent Claim Asserted: Claim 1 (Compl. ¶23).
• Essential Elements of Claim 1:
  • A waterproof and shatterproof light string comprising an electric wire.
  • A female socket at one end and a male plug at the other.
  • A plurality of lamps arranged in the middle of the wire, each comprising a lamp holder and a bulb connected to it.
  • A "circumferential gap that is defined between the lamp holder and the bulb" and that "surrounds the bulb when the bulb is fitted inside the lamp holder."
  • A "water discharge port" defined in one side of the lamp holder.
  • The bulb comprises a "shatterproof plastic bulb shell."
  • The gap is configured to lead water that enters the lamp holder to the water discharge port for drainage.
• The complaint does not explicitly reserve the right to assert dependent claims but makes general allegations of infringement of the ’585 patent (Compl. ¶22).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are "the string light products" sold by the Defendants through their various online stores (Compl. ¶4).

Functionality and Market Context

The complaint alleges that the Defendants operate e-commerce stores that make, use, offer for sale, sell, and/or import "the same or similar infringing product" (Compl. ¶3). These products are described as infringing the patented design, which includes features like a water discharge port and a gap between the lamp holder and bulb to make the string lights waterproof (Compl. ¶8). The complaint includes a representative figure from the patent to illustrate the accused design features. This figure shows a bulb (6) fitted into a lamp holder (5), with a gap (7) and a water discharge port (8) (Compl. p. 4). The Defendants are alleged to be part of an interrelated network of online sellers targeting U.S. consumers (Compl. ¶14).

IV. Analysis of Infringement Allegations

’585 Patent Infringement Allegations

• Identified Points of Contention:
  • Structural Questions: A primary question will be evidentiary: do the products sold by each of the numerous, unidentified Defendants in fact possess the specific structures recited in Claim 1? This includes the precise arrangement of a "circumferential gap" that "surrounds the bulb" and a distinct "water discharge port."
  • Functional Questions: The claim requires that the gap be "configured to lead water" to the port. The court may need to determine if this requires a specific structure designed for that purpose (e.g., channels or gradients) or if the mere potential for water to travel between the two points is sufficient to meet the limitation. The complaint does not provide sufficient detail for analysis of how the accused products perform this function.

V. Key Claim Terms for Construction

• The Term: "circumferential gap"

• Context and Importance: This term is central to the invention's novel waterproofing mechanism. The scope of "gap" will be critical. A narrow construction might require a specific, measurable space engineered for water flow, while a broader construction could potentially read on any incidental space between a bulb and its socket. Practitioners may focus on this term because the existence and nature of this "gap" in the accused products will be a core factual dispute.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The detailed description refers generally to "a gap 7 is arranged between the lamp holder 5 and the bulb 6" without specifying dimensions, which may support a broader reading covering any such space ('585 Patent, col. 3:17-18).
  • Evidence for a Narrower Interpretation: The claim language itself requires the gap to be "circumferential" and to "surround[] the bulb," which suggests a more specific and continuous structure than an arbitrary space ('585 Patent, col. 3:50-52). Figure 3, which depicts the gap (7), may be used to argue for a particular structural configuration.

• The Term: "water discharge port"

• Context and Importance: This is the second key element of the patented water management system. Whether a simple opening or hole in an accused product qualifies as a "port" will be a likely point of dispute. The term's definition will determine if any small opening constitutes infringement or if the opening must have specific characteristics of a "port" designed for drainage.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification simply states "a water discharge port 8 is formed in one side of the lamp holder 5" without further structural limitations, which could support a reading on any opening that allows water to exit ('585 Patent, col. 3:18-20).
  • Evidence for a Narrower Interpretation: The claim requires the gap to be "configured to lead water...to the water discharge port," which may imply the port is a specific, intended destination for water flow, not just an incidental hole ('585 Patent, col. 3:55-58). Figure 3 depicts the port (8) as a distinct, drilled-out feature on the side of the lamp holder base.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendants "knowingly and willfully" infringe "directly and/or indirectly" and asks the court to enjoin those "aiding, abetting, contributing to, or otherwise assisting anyone" in infringing (Compl. ¶22; Prayer for Relief ¶A(2)). However, the complaint does not plead specific facts detailing how any of the Defendants encourage or instruct third parties (e.g., end-users) to perform infringing acts.
• Willful Infringement: The complaint alleges that Defendants' infringement was and is willful (Compl. ¶19). The basis for this allegation appears to be the "knowing" conduct of offering the infringing products for sale, but the complaint does not allege that Defendants had pre-suit knowledge of the ’585 patent (Compl. ¶18, ¶22).

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

This case against a multitude of online sellers appears poised to turn on two central issues:

1. A core issue will be one of procedural propriety and proof: can the Plaintiff successfully group these numerous, unidentified e-commerce storefronts under the joinder provisions of 35 U.S.C. § 299, and subsequently prove that the specific products sold by each distinct defendant practice every element of Claim 1?

2. A key technical question will be one of structural identity: assuming the accused products are produced, does the physical construction of those products meet the specific claim limitations of a "circumferential gap" and a "water discharge port," or will any observed gaps and openings be argued as incidental manufacturing artifacts that do not perform the claimed water-management function?