Jiangmen Pengjiang Tianli New Tech Co Ltd v. Partnerships Unincorp Associations

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Jiangmen Pengjiang Tianli New Tech Co., Ltd. (China)
  • Defendant: The Partnerships and Unincorporated Associations Identified on Schedule A (jurisdictions unknown, alleged to be primarily People's Republic of China)
  • Plaintiff’s Counsel: AVEK IP, LLC
• Case Identification: 1:24-cv-05461, N.D. Ill., 06/28/2024
• Venue Allegations: Venue is based on allegations that Defendants operate interactive e-commerce stores that directly target and make sales to consumers in Illinois.
• Core Dispute: Plaintiff alleges that Defendants’ light-emitting diode (LED) lighting products infringe a patent related to an electronic driving system that uses two power sources to create a stable control signal over a power line.
• Technical Context: The technology addresses control systems for decorative or functional LED light strings, a large consumer and commercial market where product cost, reliability, and ease of installation are significant factors.
• Key Procedural History: The complaint is structured as an action against a group of unidentified online sellers, a common strategy in anti-counterfeiting and patent enforcement actions targeting e-commerce platforms. The complaint notes that Plaintiff purchased and tested the accused products prior to filing suit.

Case Timeline

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

U.S. Patent No. 10,863,608 - "LIGHT-EMITTING DIODE DRIVING SYSTEM FOR TRANSMITTING SIGNAL BASED ON POWER LINE"

• Patent Identification: U.S. Patent No. 10,863,608, "LIGHT-EMITTING DIODE DRIVING SYSTEM FOR TRANSMITTING SIGNAL BASED ON POWER LINE," issued December 8, 2020.

The Invention Explained

• Problem Addressed: The patent’s background section identifies a problem in prior art LED driving systems where the signal generation circuit is "weak." This can cause the control switch to enter a "turned-off state," leading to the entire LED light string becoming non-operational and creating an unstable display effect for the end-user (’608 Patent, col. 5:35-42).
• The Patented Solution: The invention proposes a system with two separate power supplies (a main and a secondary) providing different voltage levels. A control unit sends high or low level signals to a switch unit, which in turn selects power from either the main supply (on a high signal) or the secondary supply (on a low signal). This creates a composite driving signal that is always active, ensuring the LED light string remains continuously powered and "always in an operating state," thereby providing more stable light emission without requiring extra control wires (’608 Patent, Abstract; col. 6:30-41).
• Technical Importance: This approach aims to improve the visual stability and reliability of complex LED light strings by ensuring the LEDs are never unpowered during operation, addressing a perceived weakness in prior power-line control systems (’608 Patent, col. 5:46-51).

Key Claims at a Glance

• The complaint asserts infringement of at least independent Claim 1 (’Compl. ¶¶ 13, 26).
• The essential elements of independent Claim 1 include:
  • A system comprising a switch unit, a control unit, a main power supply, and a secondary power supply.
  • Specific electrical connections between the components and an output connection to an LED light string.
  • A functional requirement that the "switch unit is always turned on when the control unit is in an operating state."
  • A control scheme where a high-level signal from the control unit causes the switch to draw current from the main power supply, and a low-level signal causes it to draw from the secondary power supply.
  • The output of a "light emission driving signal composed of the main and secondary current power supplies" that keeps the LED string "always in an operating state."
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are "light-emitting diode (LED) lighting products" and their associated "LED driving systems," which are sold by the various Defendants through online e-commerce stores (’Compl. ¶¶ 4, 13).

Functionality and Market Context

• The complaint alleges that Defendants sell the same or similar infringing products across numerous online storefronts, suggesting the products are fungible goods potentially sourced from a common origin (’Compl. ¶¶ 3, 16). The complaint provides a representative figure from the patent, a block diagram illustrating the claimed system architecture, which Plaintiff alleges describes the infringing products. (Compl. ¶8). However, the complaint does not provide specific technical details about the operation of the accused products themselves, instead relying on a statement that "in-house tests" confirmed infringement (’Compl. ¶13).

IV. Analysis of Infringement Allegations

The complaint alleges that Plaintiff conducted "in-house tests" on the accused products and concluded that they infringe at least Claim 1 of the ’608 Patent (’Compl. ¶13). The complaint does not, however, provide a detailed claim chart or specific factual allegations mapping the accused products' features to the claim elements. The following summary is based on the complaint's general infringement allegations.

’608 Patent Infringement Allegations

Identified Points of Contention

• Evidentiary Question: A primary question will be what evidence Plaintiff’s "in-house tests" can show regarding the internal circuitry of the accused products (’Compl. ¶13). The infringement case depends on demonstrating that the products contain the specific claimed architecture (two distinct power supplies, a switch, a control unit) rather than a more conventional single-source, pulse-width-modulated driver.
• Functional Question: The analysis may focus on whether the accused products meet the functional limitations that the switch unit and the LED light string are "always turned on" and "always in an operating state" respectively, as required by the claim (’608 Patent, col. 6:41-43, 6:53-54).

V. Key Claim Terms for Construction

• The Term: "always turned on"

• Context and Importance: This term, which describes the state of the switch unit, is central to the patent's asserted novelty over prior art that allegedly suffered from a "turned-off state" (’608 Patent, col. 5:38). Whether an accused device infringes may depend on whether its switching component can be considered "always turned on."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent states that the "main and secondary switches are turned on alternately, so that the switch unit is always in a turned-on state" (’608 Patent, col. 5:15-18). This language may support an interpretation where the overall unit is considered "on" so long as at least one of its sub-components is active.
  • Evidence for a Narrower Interpretation: The term could be interpreted to require that the switch unit, as a whole, continuously draws power and is capable of passing current without interruption, even during the transition between the main and secondary power sources.

• The Term: "a light emission driving signal composed of the main and secondary current power supplies"

• Context and Importance: Practitioners may focus on this term because it defines the nature of the output signal. The infringement analysis will require a determination of whether the accused product's signal is merely modulated from a single source or is truly "composed of" two distinct power sources as claimed.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: This could be read to cover any signal whose waveform is shaped by switching between two different voltage or current sources, regardless of how they are electronically combined.
  • Evidence for a Narrower Interpretation: The specification describes the high and low levels of the output signal as being provided directly by the main and secondary supplies, respectively (’608 Patent, col. 6:3-7). This may support a narrower construction requiring the output signal to be a direct composite of the two sources, as illustrated in the waveform diagram of Figure 5.

VI. Other Allegations

Indirect Infringement

• The complaint makes passing references to indirect infringement and seeks injunctive relief against aiding and abetting (’Compl. ¶¶ 20, 25; Prayer for Relief ¶ A(2)). However, it does not plead specific facts to support such a claim, such as allegations related to user instructions or knowledge of direct infringement by downstream customers.

Willful Infringement

• Willfulness is alleged based on Defendants having "knowingly and willfully" infringed (’Compl. ¶20, ¶24). The complaint alleges that the Defendants are part of a network of infringers who actively conceal their identities and communicate about tactics for evading enforcement, which may be argued as evidence of willful conduct (’Compl. ¶¶ 15-19).

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

• A key question will be one of evidentiary proof: given the conclusory infringement allegations against numerous unidentified sellers, can the Plaintiff provide sufficient technical evidence from its "in-house tests" to establish that the accused products actually incorporate the specific dual-power-supply architecture required by Claim 1?
• The case may also turn on a question of functional scope: can the claim limitations requiring the switch unit and LED string to be "always" in an operating or turned-on state be construed to read on the actual performance of the accused drivers, or does the operation of the accused products include states that fall outside this claimed functionality?