Shangyou Jiayi Lighting Product Co Ltd v. Partnerships Unicorp 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-12696, N.D. Ill., 12/10/2024
• Venue Allegations: Venue is based on allegations that Defendants operate interactive e-commerce stores that target and sell products to consumers in the United States, including within the state of Illinois.
• Core Dispute: Plaintiff alleges that Defendants’ online sales of "vine lamp products" infringe a U.S. patent related to the structure and manufacturing of decorative light strings.
• Technical Context: The technology concerns decorative lighting, specifically flexible, multi-lamp "vine" or "firecracker" style light strings designed for enhanced durability and aesthetic appearance.
• Key Procedural History: The complaint joins numerous unidentified defendants pursuant to 35 U.S.C. § 299, alleging they are part of an interrelated network of online infringers selling the same or similar products and using common tactics to conceal their identities.

Case Timeline

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

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

• Patent Identification: U.S. Patent No. 10,082,258, "VINE LAMP AND PRODUCTION METHOD THEREOF," issued September 25, 2018.

The Invention Explained

• Problem Addressed: The patent's background section describes traditional LED decorative light strings ("firecracker lamps") as being large in volume, with relatively thick wires, making them difficult to package and install. It also notes their poor waterproof properties, rendering them unsuitable for outdoor or underwater use ( ’258 Patent, col. 1:23-32).
• The Patented Solution: The invention is a "vine lamp" constructed from multiple "light strings." Each string uses two parallel conducting wires with openings where light-emitting components (e.g., LED chips) are welded directly to the conductors. These connections are then sealed within a transparent encapsulation layer to form a "lamp bead" (’258 Patent, col. 1:39-62). Critically, the wire segments between the lamp beads are divided into three distinct sections. The first and third sections, which are adjacent to the lamp beads, are wound together, while the central second section is not. These central sections from multiple light strings are then wound together to form the final vine lamp structure (’258 Patent, col. 1:62-68, col. 2:1-4). This specific winding architecture is depicted in the patent's Figure 7, which is also included in the complaint (Compl. p. 4).
• Technical Importance: This design purports to create a light string that is less bulky, more flexible, and has improved waterproof and insulation properties compared to prior art designs, expanding its potential use to outdoor applications (’258 Patent, col. 2:5-17).

Key Claims at a Glance

• The complaint asserts infringement of at least independent 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.
  • Each conducting wire has a conductor and multiple insulating layers with openings where the conductor is exposed.
  • A light emitting component is welded to the exposed conductor surfaces of the two wires.
  • A transparent encapsulation layer is wrapped around the connection point to form a "lamp bead."
  • The conducting wire between adjacent lamp beads is divided into a first, second, and third wire section.
  • The first and third sections on both sides of a lamp bead "intersect and are wound with each other and not with the second conducting wire sections."
  • The second conducting wire section of one light string is "wound with one or more other second conducting wire sections of another one of the plurality of light strings."

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are "vine lamp products" ("the Infringing Products") sold by Defendants through various e-commerce stores listed in Schedule A (Compl. ¶¶4, 10).

Functionality and Market Context

• The complaint alleges that the Infringing Products embody the patented design, specifically referencing the unique winding structure of the conducting wires (Compl. ¶8). The complaint includes a representative figure from the patent to illustrate the accused product's structure (Compl. p. 4, Representative Figure). This figure shows a segment of a light string with first (110), second (111), and third (112) conducting wire sections, corresponding to the structure recited in claim 1. The complaint alleges that Defendants operate a network of online stores that use common tactics, such as similar product images and pricing, to sell these products to unknowing consumers in the United States (Compl. ¶¶5, 14).

IV. Analysis of Infringement Allegations

’258 Patent Infringement Allegations

Identified Points of Contention

• Factual Question: The complaint's infringement theory relies heavily on the final three limitations of claim 1, concerning the specific division and winding of wire sections. A central question will be whether discovery provides evidentiary support that the accused products, sold by numerous different entities, actually possess this specific and complex physical structure. The complaint currently bases these allegations on "information and belief" and a reproduction of a patent figure rather than analysis of a physical product.
• Scope Question: The claim requires that the first and third wire sections are wound "not with the second conducting wire sections." The interpretation of this negative limitation and the physical arrangement it requires will be a potential focus. The case may raise the question of what degree of separation or interaction between the wound sections and the "second" section is permissible.

V. Key Claim Terms for Construction

• The Term: "wound with"
• Context and Importance: This term appears in the final two limitations of claim 1 and defines the core structural relationship of the wire sections. Its construction is critical because the alleged novelty of the invention resides in this specific winding pattern. Practitioners may focus on this term to determine if it requires a particular density, tightness, or method of winding, or if any form of intertwining meets the limitation.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself does not specify a method or degree of winding, suggesting any form of intertwining could suffice. The specification describes the structure in general terms like "intersect and are winded with each other" without further qualification in the primary description (’258 Patent, col. 1:65-68).
  • Evidence for a Narrower Interpretation: The detailed description of the production method repeatedly mentions the use of a "numerical control filament winder" to perform the winding steps (’258 Patent, col. 4:43-48). A defendant could argue this implies a regular, machine-produced winding pattern, potentially excluding products that are wound irregularly or by hand.

VI. Other Allegations

• Indirect Infringement: The complaint makes conclusory allegations of indirect infringement (Compl. ¶¶18, 23), but it does not plead specific facts to support the knowledge and intent elements required for induced infringement, such as references to defendant-authored user manuals or instructions that encourage infringing use.
• Willful Infringement: Willfulness is alleged based on Defendants acting "knowingly and willfully" (Compl. ¶¶19, 22). The factual basis appears to be tied to allegations that Defendants operate as a network of infringers who use "common tactics to evade enforcement efforts," such as using fictitious names, creating new accounts after notice, and communicating via private groups to share tactics (Compl. ¶¶13-17). This suggests the willfulness claim is based on both alleged pre-suit knowledge within an infringing network and continued infringement post-filing.

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

1. A central issue will be one of evidentiary proof: Can the Plaintiff, through discovery from a large and allegedly anonymous group of defendants, develop the factual evidence required to prove that the accused "vine lamp products" actually incorporate the specific three-part wire division and multi-stage winding architecture required by the asserted claim? The complaint's current allegations are conclusory and not based on an analysis of a physical product.
2. The case will present a key procedural and case management challenge: Given the joinder of numerous unidentified online sellers under 35 U.S.C. § 299, a threshold question will be whether the Plaintiff can establish that all Defendants' actions truly arise out of the "same transaction, occurrence, or series of transactions or occurrences" and that common questions of fact apply, particularly if discovery reveals variations in the accused products sold by different storefronts.
3. A core legal question will be one of claim scope: The infringement analysis will likely turn on the construction of terms like "wound with" and the negative limitation "not with the second conducting wire sections." The court's interpretation of the precise physical arrangement required by this language will be critical in determining whether the accused products, once analyzed, fall within the scope of the claims.