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 (jurisdictions unknown, believed to be China or other foreign jurisdictions)
  • Plaintiff’s Counsel: AVEK IP, LLC
• Case Identification: 1:24-cv-08816, N.D. Ill., 09/24/2024
• Venue Allegations: Venue is asserted based on Defendants’ operation of interactive e-commerce stores that directly target and solicit sales from consumers in Illinois.
• Core Dispute: Plaintiff alleges that Defendants’ online sales of "vine lamp products" infringe a U.S. patent related to the structural design of decorative light strings.
• Technical Context: The technology concerns flexible, decorative LED light strings, often styled as "vine lamps," designed for improved durability, weather resistance, and aesthetic appearance for indoor and outdoor use.
• Key Procedural History: The complaint targets a collective of unidentified online sellers, alleging they operate as a network selling the same or similar infringing products. Plaintiff asserts that joinder of these otherwise unrelated entities is proper under 35 U.S.C. § 299 due to common questions of fact arising from the sale of the same accused products.

Case Timeline

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

U.S. Patent No. 10,082,258 - VINE LAMP AND PRODUCTION METHOD THEREOF

Issued September 25, 2018

The Invention Explained

• Problem Addressed: The patent describes conventional LED decorative light strings, or "firecracker lamps," as suffering from several disadvantages: they are large in volume, use thick conducting wires, are difficult to package and install, and have poor waterproof properties, making them unsuitable for outdoor use (U.S. Patent No. 10,082,258, col. 1:20-32). The complaint similarly notes that traditional vine lamps have a "bloated size" (Compl. ¶8).
• The Patented Solution: The invention is a "vine lamp" constructed from a plurality of individual light strings. In each string, the wire between adjacent LED "lamp beads" is conceptually divided into three sequential sections. The first and third sections, which flank the lamp bead, are twisted together to create an offshoot. The middle "second" sections from multiple light strings are then wound together to form the central "vine." This architecture aims to create a more compact and lighter product, improve flexibility, and enable 360-degree illumination from the exposed lamp beads ('258 Patent, Abstract; col. 2:11-25).
• Technical Importance: The claimed construction method seeks to provide a decorative lighting product that is more aesthetically pleasing, versatile for indoor and outdoor use, and structurally robust compared to prior art designs ('258 Patent, col. 4:16-25).

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 1 (Compl. ¶24).
• Essential elements of Claim 1 include:
  • A plurality of light strings, each with linearly arranged light emitting components and two side-by-side conducting wires.
  • Each conducting wire has a conductor and two insulating layers, with openings to expose the conductor.
  • A transparent encapsulation layer is wrapped over the openings and light emitting components to form a "lamp bead."
  • The wire between adjacent lamp beads is divided into a first, second, and third conducting wire section in sequence.
  • The first and third conducting wire sections on the sides of a lamp bead are wound with each other, but not with the second conducting wire sections.
  • The second conducting wire section of each light string is wound with one or more second conducting wire sections from another light string.

III. The Accused Instrumentality

Product Identification

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

Functionality and Market Context

The complaint alleges that Defendants sell products that embody the plaintiff’s patented design (Compl. ¶4, ¶8). A representative figure included in the complaint depicts the patented vine lamp structure, suggesting the accused products share this configuration (Compl. p. 4). The figure shows wire sections (110, 112) twisted together as offshoots from a main vine composed of other wire sections (111) (Compl. p. 4). The accused products are allegedly marketed and sold to consumers in the United States, including Illinois, through e-commerce platforms such as Amazon, eBay, AliExpress, and Temu (Compl. ¶2, ¶7).

IV. Analysis of Infringement Allegations

’258 Patent Infringement Allegations

• Identified Points of Contention:
  • Factual Questions: The central dispute will likely be factual: do the accused products sold by the various Defendants actually incorporate the specific three-section wire structure and winding configuration required by every limitation of Claim 1? The complaint’s allegations are general, and infringement will depend on evidence from physical product analysis.
  • Scope Questions: The case raises the question of whether the accused products, which are described as "the same or similar" to the patented design, are identical in their construction. Proving that products from numerous independent online sellers all meet the specific structural limitations of the claim may be an evidentiary challenge.

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail to identify specific claim construction disputes. However, based on the patent, the following terms may be central to the infringement analysis.

• The Term: "wound with each other"

• Context and Importance: This term appears in the final two, and most structurally distinct, limitations of Claim 1. The specific manner in which different wire sections are "wound" defines the core of the invention. Practitioners may focus on this term because its definition will determine whether a simple twist is sufficient to infringe or if a more structured, machine-like winding is required.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language itself does not specify the method or tightness of the winding. A party may argue for a broad, plain-and-ordinary meaning that covers any intertwining of the wires.
  • Evidence for a Narrower Interpretation: The specification repeatedly discloses the use of a "numerical control filament winder" to perform this step, which could suggest a regular, mechanically produced winding is contemplated ('258 Patent, col. 4:43-48, col. 10:18-24). The patent figures also depict a relatively uniform, helical twist ('258 Patent, Fig. 7).

• The Term: "first conducting wire section, a second conducting wire section and a third conducting wire section in sequence"

• Context and Importance: The conceptual division of the wire into these three distinct sections is foundational to the claim's structure. The definition of these terms will determine how distinct and demarcated these sections must be in an accused product.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A party could argue these are merely positional labels for sequential portions of a continuous wire between two lamp beads, without strict requirements on their length or physical properties, so long as they are arranged sequentially.
  • Evidence for a Narrower Interpretation: Figure 7 distinguishes these sections functionally: sections 110 and 112 are wound together to form the lamp bead offshoot, while section 111 is part of the main trunk ('258 Patent, Fig. 7). A party could argue that this functional difference is a required aspect of the definition, potentially excluding products with a less differentiated or uniform wire structure.

VI. Other Allegations

• Indirect Infringement: The complaint makes boilerplate allegations of direct "and/or indirect" infringement (Compl. ¶23) and seeks an injunction against "aiding, abetting, [or] contributing to" infringement (Prayer for Relief, ¶A(2)). However, the factual allegations focus exclusively on the Defendants' own acts of making, using, selling, and importing the accused products, which supports a claim for direct infringement (Compl. ¶4, ¶18).
• Willful Infringement: The complaint alleges that Defendants' infringement "is and has been willful" (Compl. ¶19). This is based on allegations that Defendants have "knowingly and willfully" offered for sale products that trade upon Plaintiff's patented design (Compl. ¶18, ¶22).

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

This case appears to be a targeted enforcement action against a network of online sellers rather than a traditional dispute between two known competitors. The central questions are likely to be:

• A key evidentiary question will be one of structural identity: Can the plaintiff demonstrate through product acquisitions and technical analysis that the "vine lamps" sold by each of the numerous, anonymous defendant storefronts possess the specific, multi-part wire structure and winding configuration recited in every limitation of Claim 1 of the '258 patent?
• A core challenge will be procedural and logistical: Given the defendants are alleged to be a shifting group of foreign online entities operating under multiple aliases, can the plaintiff effectively link the accused sales to specific, identifiable parties and enforce any potential injunction or monetary judgment against them?