DCT
3:25-cv-00888
Sigma Switches Plus Inc v. ABC Marketing Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Sigma Switches Plus, Inc. (Indiana)
- Defendant: ABC Marketing, Inc. (Indiana)
- Plaintiff’s Counsel: Botkin & Hall, LLP
- Case Identification: 3:25-cv-00888, N.D. Ind., 10/28/2025
- Venue Allegations: Venue is alleged to be proper because the Defendant corporation is incorporated within the Northern District of Indiana.
- Core Dispute: Plaintiff alleges that Defendant’s LED lighting systems, marketed under the "Stellar Lighting" brand, infringe four patents related to mounting systems for LED light strips.
- Technical Context: The technology concerns extruded plastic holders designed to secure LED light strips in an aesthetically pleasing manner, particularly within the interiors of recreational vehicles (RVs).
- Key Procedural History: The complaint alleges that Defendant received letters regarding infringement of each of the patents-in-suit prior to the filing of the lawsuit, which may form a basis for allegations of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2023-12-26 | Priority Date for ’127, ’396, ’411, and ’412 Patents |
| 2024-12-31 | U.S. Patent No. 12,181,127 Issues |
| 2025-04-15 | U.S. Patent No. 12,276,396 Issues |
| 2025-07-08 | U.S. Patent No. 12,352,411 and U.S. Patent No. 12,352,412 Issue |
| 2025-10-28 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,181,127 - “LED Light Holder System,” issued Dec. 31, 2024
The Invention Explained
- Problem Addressed: The patent describes the installation of traditional lighting in RVs, such as "puck lights," as cumbersome, requiring large holes to be cut in ceiling panels and involving difficult-to-access electrical connections above the ceiling. This process complicates both installation and repair ('127 Patent, col. 1:11-25).
- The Patented Solution: The invention provides a two-part system for mounting LED light strips. A "retaining strip" is first fastened to a structural element like a ceiling joist. An "elongate light holder," which contains the LED strip, then snaps into the retaining strip. This snap-fit is achieved by a "retention barb" on the light holder that engages "retention nubs" within a groove on the retaining strip. The light holder also has resilient "wings" that press against the ceiling panels to create a secure and aesthetically pleasing finish ('127 Patent, Abstract; col. 2:40-57). The system is completed by an end cap that gives a finished appearance ('127 Patent, col. 2:58-61).
- Technical Importance: This design sought to simplify lighting installation in vehicle interiors by eliminating the need for large ceiling cuts and keeping electrical connections accessible below the ceiling plane ('127 Patent, col. 1:20-25).
Key Claims at a Glance
- The complaint asserts infringement of at least Claim 1 (Compl. ¶68).
- The essential elements of independent Claim 1 are:
- An elongate light holder with wings defining an outer contoured surface and a channel beneath it.
- A ridge wall extending from the channel's bottom surface, which includes a retention barb.
- The wings are resiliently bendable and, when installed, are biased away from the channel's opening.
- An end cap with a coped portion that has a complementary fit with the light holder's contoured surface.
U.S. Patent No. 12,276,396 - “LED Light Holding System,” issued Apr. 15, 2025
The Invention Explained
- Problem Addressed: The '396 Patent addresses the same technical problem as the ’127 Patent: the difficulty and aesthetic compromises associated with installing traditional lighting in RV interiors ('396 Patent, col. 1:11-25).
- The Patented Solution: The solution is substantively identical to that of the ’127 Patent, describing an elongate light holder with resilient wings and a retention barb designed to snap into a grooved retaining strip ('396 Patent, Abstract; col. 2:35-54). A notable distinction is that the independent claim of the ’396 Patent does not recite the end cap, focusing solely on the light holder and its mechanical interaction with the retaining strip and ceiling panels.
- Technical Importance: The technical importance is the same as described for the ’127 Patent, focusing on simplified and aesthetically improved installation of LED lighting ('396 Patent, col. 1:20-25).
Key Claims at a Glance
- The complaint asserts infringement of at least Claim 1 (Compl. ¶115).
- The essential elements of independent Claim 1 are:
- An elongate light holder with wings defining an outer contoured surface and a channel beneath it.
- A ridge wall extending from the channel's bottom surface, which includes a retention barb.
- The wings are resiliently bendable and, when installed, are biased away from the channel's opening and toward their uninstalled position.
U.S. Patent No. 12,352,411 - “LED Light Holding System,” issued Jul. 8, 2025
- Technology Synopsis: This patent also discloses a system for mounting an LED light strip by fastening an elongate holder to a surface using a retaining strip. Asserted Claim 8 describes the mechanical interface more broadly, claiming a system where one component (either the light holder or the retaining strip) has a groove, and the other component has a corresponding ridge wall with a retention barb that engages the groove, allowing for inverse structural configurations ('411 Patent, Abstract; col. 9:48-51).
- Asserted Claims: Claim 8 is asserted (Compl. ¶147).
- Accused Features: The complaint alleges that the "LineLite Track" infringes this patent (Compl. ¶148).
U.S. Patent No. 12,352,412 - “LED Light Holding System,” issued Jul. 8, 2025
- Technology Synopsis: This patent claims the light holding system itself, comprising both the retaining strip and the elongate light holder. Asserted Claim 1 covers the combination where "one of said bottom surface and said retaining strip" has the ridge wall with a retention barb, and "the other" has the groove with retention nubs, thereby claiming two alternative embodiments of the snap-fit mechanism in a single claim ('412 Patent, col. 9:22-30).
- Asserted Claims: Claim 1 is asserted (Compl. ¶180).
- Accused Features: The "LineLite Track" is accused of infringing this patent (Compl. ¶181).
III. The Accused Instrumentality
Product Identification
The accused products are components of an LED lighting system sold under the "Stellar Lighting" brand, primarily identified as the "LineLite Track" and associated "End Cap" (Compl. ¶¶19, 21, 39, 40).
Functionality and Market Context
The Accused Products are marketed as "Industrial and automotive-style LED lighting" for "the RV OEM and specialty vehicle OEM markets" (Compl. ¶¶26, 52). The complaint alleges that Defendant ABC Marketing is the product developer for the "Stellar Lighting" line (Compl. ¶23, 49). A photo included in the complaint shows an "Installation Tool" being used to press a lighting track, presumably the Accused Product, into place (Compl. ¶34). Another image shows the Accused Product installed between two panels, with color alteration by the Plaintiff to highlight a retaining strip (Compl. ¶75).
IV. Analysis of Infringement Allegations
U.S. Patent No. 12,181,127 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an elongate light holder having wings defining an outer contoured surface and said wings having tips | The "LineLite Track" is alleged to be an elongate light holder with wings and an outer contoured surface. A photo is provided (Compl. ¶71). | ¶71 | col. 3:5-10 |
| a channel extending beneath said outer contoured surface, said channel including overhanging walls adjacent to said outer contoured surface, said channel having lateral walls... joined to a bottom wall | The Accused Product is alleged to have a channel with overhanging and lateral walls beneath its outer surface. | ¶¶73-75 | col. 3:11-24 |
| a ridge wall extending from a bottom surface of said bottom wall opposite said channel and said ridge wall including a retention barb | The Accused Product is alleged to have a ridge wall with a retention barb. A photo points to this feature (Compl. ¶76). | ¶76 | col. 3:36-41 |
| said wings being resiliently bendable between an uninstalled position and an installed position... when said wings are in said installed position said wings being biased away from said opening and toward said uninstalled position | The complaint alleges the wings of the Accused Product are resiliently bendable between installed and uninstalled positions. | ¶77 | col. 3:42-51 |
| an end cap having an outer shell and said end cap having a coped portion, said coped portion having a complementary fit with said outer contoured surface when said elongate light holder is inserted into said coped portion | The Accused Product is alleged to have an end cap with an outer shell and a coped portion that fits the light holder. A photo is provided (Compl. ¶78). | ¶78 | col. 6:42-50 |
U.S. Patent No. 12,276,396 Infringement Allegations
The complaint alleges the Accused Product meets all limitations of Claim 1 of the ’396 Patent but does so by incorporating the more detailed allegations made for the ’127 Patent, which map to the shared elements of both claims (Compl. ¶¶114-118).
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an elongate light holder having wings defining an outer contoured surface and said wings having tips | The "LineLite Track" is alleged to be the elongate light holder (Compl. ¶116). | ¶¶71, 116 | col. 3:3-8 |
| a channel extending beneath said outer contoured surface, said channel including overhanging walls adjacent to said outer contoured surface... | The Accused Product is alleged to have the claimed channel structure (Compl. ¶116). | ¶¶73-75, 116 | col. 3:9-22 |
| a ridge wall extending from a bottom surface of said bottom wall opposite said channel and said ridge wall including a retention barb | The Accused Product is alleged to have a ridge wall with a retention barb (Compl. ¶116). | ¶¶76, 116 | col. 3:34-39 |
| said wings being resiliently bendable between an uninstalled position and an installed position... when said wings are in said installed position said wings being biased away from said opening and toward said uninstalled position | The complaint alleges the wings of the Accused Product are resiliently bendable as claimed (Compl. ¶116). | ¶¶77, 116 | col. 3:40-49 |
Identified Points of Contention
- Scope Questions: The case may turn on whether the accused "LineLite Track's" locking feature constitutes a "retention barb" as that term is used in the patents. The patents describe a specific structure with "inclined surfaces" and "catch surfaces," raising the question of whether any deviation in the accused product's geometry falls outside the scope of the claims.
- Technical Questions: A potential point of dispute is whether the wings of the accused "LineLite Track" function as claimed. The claims require the wings to be "biased away from said opening and toward said uninstalled position," a specific spring-like action that allegedly secures the assembly. The complaint alleges this functionality but does not provide technical evidence, raising the question of whether the accused product's wings operate in the same way to achieve the same result.
V. Key Claim Terms for Construction
The Term: "retention barb" ('127 Patent, Claim 1; '396 Patent, Claim 1)
- Context and Importance: This term defines the primary locking element of the invention. Its construction is central because infringement will depend on whether the specific structure on the bottom of the accused LineLite Track meets this definition.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests the exact geometry may be flexible, stating that the barb "may be of a circular cross-sectional shape," which could imply that the specific angled "catch surfaces" shown in the preferred embodiment are not strictly required ('127 Patent, col. 5:1-4).
- Evidence for a Narrower Interpretation: The figures and detailed description consistently depict a barb with distinct "inclined surfaces (71)" that facilitate insertion and "catch surfaces (73)" that prevent removal, which may support an argument that both features are necessary components of the claimed "retention barb" ('127 Patent, col. 4:8-14; Fig. 7).
The Term: "biased away from said opening and toward said uninstalled position" ('127 Patent, Claim 1; '396 Patent, Claim 1)
- Context and Importance: This phrase describes the specific resilient force generated by the light holder's wings when installed. Practitioners may focus on this term because it is not merely structural but functional, and proving that the accused product generates this exact directional force will be critical to the infringement analysis.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The general claim language could be argued to cover any outward spring force exerted by the wings against adjacent panels.
- Evidence for a Narrower Interpretation: The specification links this biasing force to a specific result: it "drives the barb 70 toward the nubs and keeps the wings 44 in biased tension against the ceiling boards," suggesting a multi-part function of both sealing against the ceiling and securing the lock ('127 Patent, col. 4:32-35).
VI. Other Allegations
Indirect Infringement
The complaint alleges both induced and contributory infringement. Inducement is based on allegations that Defendant encourages its customers to assemble the accused system in an infringing manner, supported by the sale of a dedicated "installation tool" and the provision of instructions (Compl. ¶¶90, 95-96). Contributory infringement is based on the allegation that the Accused Products are not staple articles of commerce and have no substantial non-infringing use apart from their intended, infringing application (Compl. ¶¶104, 137).
Willful Infringement
The complaint does not contain a separate count for willful infringement. However, it alleges that Defendant had pre-suit knowledge of the patents via "letters regarding infringement" and continued its allegedly infringing conduct (Compl. ¶¶58, 61). The prayer for relief requests treble damages pursuant to 35 U.S.C. § 284, the statutory provision for enhanced damages based on willful or egregious infringement (Compl., Prayer for Relief ¶d).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim scope: can the term "retention barb," which is described in the patents with specific inclined and catch surfaces, be construed to cover the precise geometry of the locking feature on the accused "LineLite Track"?
- A key evidentiary question will be one of mechanical function: does the accused product's flexible "wings" generate the specific, dual-purpose force of being "biased away from said opening and toward said uninstalled position" as required by the claims, or is there a fundamental mismatch in its technical operation?
- The viability of the indirect infringement claims may depend on the nature of customer-facing materials: what specific instructions and marketing does the Defendant provide for its "Installation Tool" and lighting systems, and do those materials direct an end-user to perform every step of the patented method?