DCT
1:25-cv-06684
Go Fan Yourself LLC v. Louvers Intl Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Go Fan Yourself, LLC (Delaware)
- Defendant: Louvers International, Inc. (Illinois)
- Plaintiff’s Counsel: VVN Law (Patrick F. Solon, Nicholas D. Niro)
- Case Identification: 1:25-cv-06684, N.D. Ill., 06/17/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is an Illinois corporation with its principal place of business in the district, and has a regular and established place of business in the district where it allegedly committed acts of infringement.
- Core Dispute: Plaintiff alleges that Defendant’s Cluvaire UVC Disinfection Panel devices infringe six patents related to ceiling tile-based air purification and circulation systems that utilize UV light.
- Technical Context: The technology involves integrating air circulation fans and UV-C germicidal light sources into fixtures sized for standard dropped ceilings, aiming to provide localized air purification independent of a building's main HVAC system.
- Key Procedural History: The complaint notes that on May 7, 2024, Plaintiff sent a letter to Defendant’s CEO providing notice of infringement of the ’141, ’026, ’223, and ’336 patents, including claim charts. This pre-suit notice is alleged as the basis for Defendant's knowledge supporting claims of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2016-12-28 | Earliest Priority Date for all Patents-in-Suit |
| 2019-03-05 | U.S. Patent No. 10,221,857 Issues |
| 2019-06-11 | U.S. Patent No. 10,316,141 Issues |
| 2020-06-02 | U.S. Patent No. 10,670,026 Issues |
| 2021-06-08 | U.S. Patent No. 11,028,223 Issues |
| 2022-02-22 | U.S. Patent No. 11,255,336 Issues |
| 2022-05-17 | U.S. Patent No. 11,332,573 Issues |
| 2024-05-07 | Plaintiff sends pre-suit notice letter to Defendant |
| 2025-06-17 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,316,141 - Ceiling Tile with Built-in Air Flow Mechanism and UV Air Purifying Device
The Invention Explained
- Problem Addressed: The patent addresses the dual needs in indoor commercial spaces for adequate air circulation and purification, as well as the problem of safely containing germicidal UV light within an air-handling fixture to avoid exposing occupants (Compl. ¶19; ’141 Patent, col. 2:39-43). The invention aims to provide a solution that supplements a building's main HVAC system and fits within the footprint of a standard ceiling tile (Compl. ¶19; ’141 Patent, col. 1:30-41).
- The Patented Solution: The invention is an air purifying device, configured as a ceiling tile, that uses a system of baffles to create an internal air chamber. A fan directs air through this chamber, where a UV-C light source creates a "kill zone" to irradiate airborne contaminants like bacteria and viruses (’141 Patent, col. 4:26-34). The baffles are specifically configured to direct airflow while also physically blocking the UV light from exiting the device, ensuring occupant safety (Compl. ¶20; ’141 Patent, col. 3:46-53).
- Technical Importance: This approach integrates localized air purification directly into a common building component (a ceiling tile), allowing for targeted air treatment in specific rooms without requiring modification to the central HVAC infrastructure (Compl. ¶19).
Key Claims at a Glance
- The complaint asserts independent claim 11.
- Claim 11 requires:
- a lower baffle configured the size of a ceiling tile, with a fan portion and a vent portion;
- an upper baffle adjacent to the lower baffle, forming an air chamber between them;
- a fan in the fan portion that directs air between the air chamber and the vent portion; and
- a UV-C light fixture in the air chamber that emits UV light to form a kill zone capable of killing airborne bacteria, viruses, or microbes.
- The complaint reserves the right to assert other claims, including claims 1, 3, 12-13, and 15-17 (Compl. ¶44).
U.S. Patent No. 10,670,026 - Ceiling Tile with Built-in Air Flow Mechanism
The Invention Explained
- Problem Addressed: Similar to the ’141 Patent, this patent addresses the need for a self-contained air circulation and purification unit for indoor spaces. It particularly emphasizes the need to create a "kill chamber" that is self-enclosed so that UV light does not escape (’026 Patent, col. 2:40-43).
- The Patented Solution: The invention is an air circulation device with a housing sized to fit in a ceiling tile grid. Inside the housing, a fan moves air into an "air chamber" where a UV light source is positioned (’026 Patent, Abstract). A key element is a "UV light screen" positioned in the air chamber to shield the UV rays from exiting, thereby protecting occupants while allowing purified air to be expelled (’026 Patent, col. 14:15-20).
- Technical Importance: This patent focuses on the safety aspect of containing UV light within an air handling unit, using a dedicated "screen" element to achieve this goal while allowing for effective air circulation (Compl. ¶19).
Key Claims at a Glance
- The complaint asserts independent claim 7.
- Claim 7 requires:
- a housing configured to fit within a ceiling tile grid;
- a fan mounted in the housing;
- an air chamber positioned in the housing adjacent to the fan;
- a vent where air from the fan enters the air chamber and proceeds through;
- a UV light source capable of emitting UV light rays, positioned in the air chamber; and
- a UV light screen positioned in the air chamber to shield the UV rays from exiting.
- The complaint reserves the right to assert other claims, including claims 8 and 10-16 (Compl. ¶72).
U.S. Patent No. 11,028,223 - Ceiling Tile with Built-in Air Flow Mechanism and UV Air Purifying Device
- Technology Synopsis: This patent describes an air purifying device comprising a face-plate sized as a ceiling tile and a cover that forms an air chamber. A baffle within the chamber is configured to both direct air toward a UV-C "kill zone" and prohibit UV light from exiting the device (Compl. ¶97).
- Asserted Claims: Independent claim 14 (Compl. ¶97).
- Accused Features: The complaint alleges the Cluvaire UVC device has a face-plate, a cover forming an air chamber, a fan, a UV-C light fixture, and an internal structure that functions as a baffle to direct air and contain UV light (Compl. ¶100-104).
U.S. Patent No. 11,255,336 - Ceiling Tile with Built-in Air Flow Mechanism
- Technology Synopsis: This patent claims an air circulation device with a housing configured to fit into a building structure. It includes a fan, an adjacent air chamber, and an air inlet, along with a UV light source and a "UV light screen" to shield the emitted rays (Compl. ¶121).
- Asserted Claims: Independent claim 10 (Compl. ¶121).
- Accused Features: The complaint alleges the Cluvaire UVC device has a housing that fits a ceiling grid, a fan, an air chamber, a UV light source, and a UV-shielding mechanism (Compl. ¶123-127).
U.S. Patent No. 10,221,857 - Ceiling Tile with Built-in Air Flow Mechanism
- Technology Synopsis: This patent claims an air purifying device built into a ceiling tile, comprising a fan, a baffle defining a first airway, and a UV light source mounted in that airway. The claim requires the airway to accommodate a UV-reflective material and include a UV-screen to block light from exiting (’857 Patent, col. 14:10-21; Compl. ¶145).
- Asserted Claims: Independent claim 10 (Compl. ¶145).
- Accused Features: The complaint alleges the Cluvaire UVC device is a ceiling tile with a fan, a baffle defining an airway, a UV light source, UV-reflective material, and a UV-screen (Compl. ¶148-151).
U.S. Patent No. 11,332,573 - Combination Built-in Air Flow Mechanism and LED Kill Chamber
- Technology Synopsis: This patent describes a recessed fixture for a ceiling that includes upper and lower baffles forming a "UV-C kill chamber." It further requires a fan to direct air through this chamber and a "light protection plate" at the vent to prohibit UV light from exiting (Compl. ¶168).
- Asserted Claims: Independent claim 13 (Compl. ¶168).
- Accused Features: The complaint alleges the Cluvaire UVC is a recessed fixture with a housing portion, fan, vent, baffles that form a UV-C kill chamber, a UV-C light fixture, and a light protection plate (Compl. ¶171-177).
III. The Accused Instrumentality
Product Identification
- Defendant’s Louvers Cluvaire Disinfection Panel Devices, also referred to as the "Cluvaire UVC" devices, including models CLUV-22-36W-NL-U, CLUV-22-36W-WL-U, CLUV-24-36W-NL-U, and CLUV-24-36W-WL-U (Compl. ¶7, 28).
Functionality and Market Context
- The complaint alleges the Cluvaire UVC is an air purification device installed in ceiling tile grids that "utilizes a standalone UVC deactivation chamber with airflow technology and an LED-backlit flat panel light fixture" (Compl. ¶29, 30). It is alleged to sanitize the air by drawing it into the fixture, passing it through a UVC light chamber, and then expelling the cleaned air down into the room (Compl. ¶31). The complaint includes an annotated photograph of the Cluvaire UVC's interior, identifying distinct areas labeled "Air chamber" and "Kill Zone" (Compl. p. 9). The device is marketed for use in indoor environments such as schools, restaurants, and medical offices and is described as operating independently of a building's main HVAC system (Compl. ¶30, 35).
IV. Analysis of Infringement Allegations
U.S. Patent No. 10,316,141 Infringement Allegations
| Claim Element (from Independent Claim 11) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| An air purifying device comprising: a lower baffle configured the size of a ceiling tile, wherein the lower baffle includes a fan portion and a vent portion; | The Cluvaire UVC is designed to fit into a standard ceiling grid and has a lower structure that includes both a fan portion and a vent portion. A photograph in the complaint shows separate fan and vent sections. | ¶48-49 | col. 18:1-4 |
| an upper baffle adjacent the lower baffle configured to form an air chamber between the lower baffle and the upper baffle; | The Cluvaire UVC includes an upper structure adjacent to its lower structure, which allegedly forms an air chamber between them. The complaint provides an annotated photograph identifying the "Upper Baffle," "Lower Baffle," and the resulting "Air Chamber." | ¶50-51 | col. 18:5-7 |
| a fan positioned in the fan portion of the lower baffle, wherein said fan directs air between the air chamber and the vent portion; and | The device contains fans in its fan portion that allegedly direct air into the air chamber and out through the vent portion. A diagram shows arrows indicating the path of airflow from the fan into the chamber. | ¶52-53 | col. 18:8-11 |
| a UV-C light fixture positioned in the air chamber wherein the UV-C light fixture emits UV light to form a kill zone within the air chamber capable of killing bacteria, viruses or microbes contained in air passing through the kill zone. | The device contains a UV-C light fixture inside the air chamber that sanitizes the air. An annotated photograph points out the "Kill Zone" in the same area as the "Air Chamber." | ¶54-56 | col. 18:12-17 |
- Identified Points of Contention:
- Scope Questions: A central question may be whether the accused device's structural components meet the claim definitions of "lower baffle" and "upper baffle." The defense may argue that these terms imply specific airflow-directing structures beyond merely being the lower and upper casings of the device. The complaint's visual evidence identifies the lower and upper housings of the device as the claimed "baffles" (Compl. p. 13).
- Technical Questions: The analysis may focus on whether the space between the alleged "baffles" functions as an "air chamber" in the manner required by the claim, which suggests a defined plenum for directing air, as opposed to simply the open interior of the device housing.
U.S. Patent No. 10,670,026 Infringement Allegations
| Claim Element (from Independent Claim 7) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| An air circulation device, comprising: a housing configured to fit within a ceiling tile grid; | The Cluvaire UVC is designed for installation into a standard 2x2 or 2x4 dropped ceiling grid. A photograph shows the device installed flush in a ceiling. | ¶75-76 | col. 14:41-42 |
| a fan mounted in the housing; | The device utilizes a fan system to circulate air. Photographs show multiple fans mounted inside the device housing. | ¶33 | col. 14:43 |
| an air chamber positioned within the housing adjacent the fan; | The device contains an "air chamber" within its housing. An annotated photograph shows the "Air Chamber" positioned next to the fans. | ¶77 | col. 14:44-45 |
| a vent in the housing wherein air from the fan enters the air chamber and proceeds through the vent; | The device draws air in, passes it through the UVC light chamber, and expels it back into the room. | ¶31 | col. 14:46-48 |
| a UV light source capable of emitting UV light rays positioned in the air chamber; and | The device contains a UV light source, specifically 36-Watt Philips germicidal UVC lamps, inside its air chamber to deactivate airborne pathogens. | ¶78 | col. 14:49-51 |
| a UV light screen positioned in the air chamber shielding the UV rays emitted from the UV light source from exiting the air chamber. | The device allegedly has a "UV kill chamber which includes a UV light screen adapted to shield UV light... from exiting the air chamber." | ¶79 | col. 14:52-55 |
- Identified Points of Contention:
- Scope Questions: The construction of "UV light screen" will be critical. The question will be whether this term requires a distinct, screen-like component or if it can be read on the general baffling and housing geometry that prevents light from escaping. The complaint does not show a specific component labeled "screen" but rather alleges that the "kill chamber" includes one (Compl. ¶79).
- Technical Questions: It raises the question of what structural element(s) in the Cluvaire UVC the Plaintiff will identify as the "UV light screen." The complaint's allegation is conclusory and does not point to a specific part in the provided images that constitutes the screen (Compl. ¶79).
V. Key Claim Terms for Construction
Term: "baffle" (from ’141 Patent, Claim 11)
- Context and Importance: This term is foundational to the structure of the asserted claim in the ’141 Patent. The infringement theory depends on identifying both an "upper baffle" and a "lower baffle" in the accused device that cooperate to form an "air chamber." The scope of this term will determine whether the main housing components of the Cluvaire UVC can be considered "baffles."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states that a baffle can be mounted to the ceiling tile and define an airway, suggesting it is a primary structural component (’141 Patent, col. 2:58-61). This may support an interpretation where the main top and bottom casings of the device, which define the primary airway, qualify as baffles.
- Evidence for a Narrower Interpretation: The detailed description and figures show baffles as specific, often angled, plates or surfaces within a larger housing or chamber, designed to direct airflow in a particular way (e.g., baffle 14 in Fig. 1; baffles 2040, 2042, 2044 in Fig. 20A). This could support a narrower construction requiring more than just the outer casing of the device.
Term: "UV light screen" (from ’026 Patent, Claim 7)
- Context and Importance: This is the key safety-related feature of claim 7 of the ’026 Patent. Infringement will turn on whether the accused device has a structure that meets this limitation. Defendant may argue its device achieves UV containment through overall geometry rather than a specific "screen."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the function of the screen as being "attached to the first airway to block UV light from exiting the airway" (’026 Patent, col. 3:20-22). This functional language may support reading the term on any structure that is attached to the airway and performs that blocking function, regardless of its specific form (e.g., a louver, a baffle, or an opaque wall).
- Evidence for a Narrower Interpretation: The term "screen" itself suggests a particular structure, perhaps a mesh, grate, or perforated plate, distinct from a solid baffle or housing wall. The patent does not appear to explicitly define "screen" or show a figure definitively labeling a structure as such, which may lead parties to rely on the term's ordinary meaning to argue for a more limited, physical form.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement for all six patents, stating that Defendant induces use by its customers (Compl. ¶62, 86, 110, 134, 157, 183). The basis for this allegation appears to be the ordinary and intended operation of the Cluvaire UVC products by end-users.
- Willful Infringement: The complaint alleges willful infringement for all six patents. The allegations are based on Defendant's alleged knowledge of the patents since at least May 7, 2024, the date it allegedly received a notice letter with claim charts from Plaintiff (Compl. ¶59, 83, 107, 131, 154, 180). Continued sales after this date are alleged to constitute willful, deliberate, and objectively reckless conduct.
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of claim construction and definitional scope: can the term "baffle," as used in the ’141 Patent, be construed broadly to read on the primary upper and lower housing components of the accused device, or does intrinsic evidence limit the term to more specific, internal airflow-directing plates? Similarly, what is the scope of "UV light screen" in the ’026 Patent—is it any structure that blocks light, or must it be a distinct, screen-like component?
- A key evidentiary question will be one of technical infringement: what specific structures within the accused Cluvaire UVC device perform the functions of the claimed "baffles," "air chamber," and "UV light screen"? The resolution of the case may depend on whether the Plaintiff can successfully map these claim elements to the physical components of the accused product in a manner consistent with the court's construction of those terms.
- Finally, the case presents a question of intent and willfulness: assuming infringement is found, did Defendant's alleged continued sales after receiving a detailed notice letter on May 7, 2024, constitute objectively reckless conduct sufficient to support a finding of willfulness and potential enhanced damages?