DCT
1:25-cv-03367
Go Fan Yourself LLC v. Olympia Lighting Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Go Fan Yourself, LLC (Delaware)
- Defendant: Olympia Lighting, Inc. (New Jersey)
- Plaintiff’s Counsel: Vitale, Vickrey, Niro, Solon & Gasey LLP (Lead Counsel); Spiro Harrison & Nelson (Local Counsel)
- Case Identification: 1:25-cv-03367, D.N.J., 04/28/2025
- Venue Allegations: Venue is alleged to be proper in the District of New Jersey because Defendant is a New Jersey corporation with its principal place of business in the district and maintains a regular and established place of business there.
- Core Dispute: Plaintiff alleges that Defendant’s UVC Troffer line of ceiling-mounted air purifiers infringes six patents related to devices that use fans and ultraviolet light to circulate and decontaminate air within a self-contained unit.
- Technical Context: The technology addresses indoor air quality by integrating air circulation and UV-C germicidal irradiation into fixtures designed to fit standard ceiling tile grids, operating independently from a building's primary HVAC system.
- Key Procedural History: The complaint states that on April 18, 2024, Plaintiff sent Defendant a letter that included claim charts detailing alleged infringement of four of the six patents-in-suit, placing Defendant on pre-suit notice for the purposes of willfulness allegations.
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 |
| 2024-04-18 | Plaintiff sends notice letter with claim charts to Defendant |
| 2025-04-28 | 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,” issued June 11, 2019
The Invention Explained
- Problem Addressed: The patent describes the need for a supplemental air circulation and purification system for indoor spaces that can operate separately from a building's main HVAC system, particularly to address airborne contaminants like bacteria and viruses and create a self-enclosed "virus or bacteria kill chamber" (’141 Patent, col. 2:37-43; Compl. ¶19).
- The Patented Solution: The invention is an air purifying device built into the form factor of a standard ceiling tile (Compl. ¶20). It uses a fan to draw air into an internal chamber where baffles guide the airflow across a UV-C light source, creating a "kill zone" to irradiate pathogens (’141 Patent, col. 4:45-51). The design incorporates UV-reflective material to enhance the light's effectiveness and barriers to prevent harmful UV light from escaping into the room (’141 Patent, Abstract).
- Technical Importance: This approach allows for targeted, localized air purification in high-risk environments like hospitals or schools without requiring modification to the central HVAC infrastructure (Compl. ¶19, ¶25).
Key Claims at a Glance
- The complaint asserts infringement of at least independent claim 11 (Compl. ¶45-46).
- Claim 11 Elements:
- 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;
- an upper baffle adjacent the lower baffle configured to form an air chamber between the lower baffle and the upper baffle;
- 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
- 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 complaint reserves the right to assert other claims, including claims 1, 3, 12-13, and 15-17 (Compl. ¶45).
U.S. Patent No. 10,670,026, “Ceiling Tile with Built-in Air Flow Mechanism,” issued June 2, 2020
The Invention Explained
- Problem Addressed: The patent addresses the same technical problems as the ’141 Patent, focusing on the need for effective, localized air circulation and purification to combat indoor air quality issues like "sick building syndrome" and airborne contaminants (’026 Patent, col. 2:25-36; Compl. ¶19).
- The Patented Solution: The invention is an air circulation device housed within a unit configured to fit a standard ceiling tile grid. It comprises a fan, an adjacent air chamber, a vent, a UV light source positioned within the chamber, and a "UV light screen" to shield the UV rays and prevent them from exiting the device (’026 Patent, Abstract; Compl. ¶75). This configuration creates a self-contained purification system within a standard lighting troffer footprint.
- Technical Importance: This design integrates air purification directly into a common building component (a ceiling fixture), providing a modular solution for improving air quality in commercial or institutional settings (Compl. ¶20).
Key Claims at a Glance
- The complaint asserts infringement of at least independent claim 7 (Compl. ¶74-75).
- Claim 7 Elements:
- An air circulation device, comprising:
- a housing configured to fit within a ceiling tile grid;
- a fan mounted in the housing;
- an air chamber positioned within the housing adjacent the fan;
- a vent in the housing wherein air from the fan enters the air chamber and proceeds through the vent;
- 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 shielding the UV rays emitted from the UV light source from exiting the air chamber.
- The complaint reserves the right to assert other claims, including claims 8 and 10-16 (Compl. ¶74).
U.S. Patent No. 11,028,223, “Ceiling Tile with Built-in Air Flow Mechanism and UV Air Purifying Device,” issued June 8, 2021
- Technology Synopsis: This patent describes an air purifying device with a "face-plate" configured to the size of a ceiling tile and a cover attached to form an air chamber. A fan directs air through this chamber, where a UV-C light fixture creates a "kill zone," and a baffle is positioned to direct air toward the kill zone while prohibiting UV light from exiting (Compl. ¶100).
- Asserted Claims: Claims 1-7, 10-11, and 14-17, with independent claim 14 highlighted (Compl. ¶99-100).
- Accused Features: The complaint alleges that the UVC Troffer's ceiling-tile-sized body, internal chamber, fan, UV light, and internal baffles meet the elements of the asserted claims (Compl. ¶101-107).
U.S. Patent No. 11,255,336, “Ceiling Tile with Built-in Air Flow Mechanism,” issued February 22, 2022
- Technology Synopsis: This patent claims an air circulation device with a housing configured to fit into a building structure. The device includes a fan, an adjacent air chamber, an air inlet, a vent, a UV light source within the chamber, and a UV light screen to shield the emitted rays (Compl. ¶124).
- Asserted Claims: Claims 1-2, 7, 10-11, and 13-16, with independent claim 10 highlighted (Compl. ¶123-124).
- Accused Features: The allegations map the UVC Troffer's housing, fan, internal air chamber, UV light source, and shielding components to the asserted claim elements (Compl. ¶125-131).
U.S. Patent No. 10,221,857, “Ceiling Tile with Built-in Air Flow Mechanism,” issued March 5, 2019
- Technology Synopsis: This patent describes an air purifying device comprising a ceiling tile with at least one vent, a fan mounted to the tile, and a baffle that defines an airway between the fan and vent. The airway contains a UV light source, UV-reflective material, and a UV-screen to block light from exiting (Compl. ¶148).
- Asserted Claims: Claim 10 is asserted (Compl. ¶147-148).
- Accused Features: The complaint alleges the UVC Troffer functions as a ceiling tile with a vent and fan, and that its internal components constitute the claimed baffle, airway, UV light source, reflective material, and UV-screen (Compl. ¶149-154).
U.S. Patent No. 11,332,573, “Combination Built-in Air Flow Mechanism and LED Kill Chamber,” issued May 17, 2022
- Technology Synopsis: This patent claims an air purifying device in a recessed fixture that fits into a ceiling. The fixture includes housing, fan, and vent portions, with upper and lower baffles forming a "UV-C kill chamber." A fan directs air into the chamber, where a UV-C light kills viruses, and a "light protection plate" at the exit prohibits UV light from escaping (Compl. ¶177).
- Asserted Claims: Claims 1-2 and 13-19, with independent claim 13 highlighted (Compl. ¶176-177).
- Accused Features: The complaint maps the UVC Troffer's recessed fixture design, internal baffles forming a kill chamber, fan, UV light, and light-blocking structures to the asserted claim elements (Compl. ¶178-189).
III. The Accused Instrumentality
Product Identification
- Defendant’s line of “UVC Disinfection Lay-in LED Troffer” products, referred to as the “UVC Troffer” or the “Accused Devices” (Compl. ¶28-29).
Functionality and Market Context
- The UVC Troffer is an air purification and disinfection device designed to be installed in the ceiling tile grid of indoor environments like offices, hospitals, and schools (Compl. ¶31). The complaint alleges the device utilizes a fan system to circulate air through an internal chamber where it is irradiated by a "hidden UVC light" to form a "kill zone" and destroy pathogens (Compl. ¶32-35). An annotated photograph of the device's interior provided in the complaint labels the "Kill Zone" and "Air chamber" (Compl. p. 10). The product is marketed as being "Tested for 99.9% Microbial Reduction" and is designed to operate independently of a building's central HVAC system (Compl. ¶30, ¶36).
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 |
|---|---|---|---|
| a lower baffle configured the size of a ceiling tile, wherein the lower baffle includes a fan portion and a vent portion | The UVC Troffer device has a lower body configured to fit into a standard ceiling grid and contains both a fan and a vent. An annotated photograph shows the distinct "Fan portion" and "Vent Portion" of the device's lower external face (Compl. p. 13). | ¶49, ¶50 | col. 5:46-53 |
| an upper baffle adjacent the lower baffle configured to form an air chamber between the lower baffle and the upper baffle | The UVC Troffer allegedly has an upper internal component adjacent to its lower body, which together form an internal air chamber. An annotated photograph identifies the separate "Upper Baffle" and "Lower Baffle" components and the resulting "Air Chamber" between them (Compl. p. 14). | ¶51, ¶52 | col. 11:30-33 |
| a fan positioned in the fan portion of the lower baffle, wherein said fan directs air between the air chamber and the vent portion | The UVC Troffer includes a fan located in the fan portion of its lower body, which allegedly directs air through the internal air chamber towards the vent. An annotated photograph explicitly labels the fan and illustrates the air path (Compl. p. 15). | ¶53, ¶54 | col. 6:8-14 |
| a UV-C light fixture positioned in the air chamber wherein the UV-C light fixture emits UV light to form a kill zone ... capable of killing bacteria, viruses or microbes... | The UVC Troffer has a UV-C light fixture inside the air chamber that emits UV light to create a kill zone for destroying airborne pathogens. An annotated photograph identifies the "UV-C Light Fixture" inside the "Air chamber" and labels the "Kill Zone" (Compl. p. 15-16). | ¶55, ¶57 | col. 12:50-55 |
U.S. Patent No. 10,670,026 Infringement Allegations
| Claim Element (from Independent Claim 7) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a housing configured to fit within a ceiling tile grid | The UVC Troffer's housing is designed to fit into a standard dropped ceiling grid. A marketing screenshot describes the product as a "UVC Disinfection Lay-in LED Troffer" (Compl. p. 8). | ¶77, ¶78 | col. 5:46-49 |
| a fan mounted in the housing | The device includes a fan mounted within its housing. A photograph of the device's interior shows the fan component (Compl. p. 13). | ¶75 | col. 5:1-2 |
| an air chamber positioned within the housing adjacent the fan | An air chamber is allegedly positioned inside the housing next to the fan. An annotated photograph labels the "Air Chamber" within the device (Compl. p. 20). | ¶79 | col. 5:3-4 |
| a vent in the housing wherein air from the fan enters the air chamber and proceeds through the vent | The device has a vent, and air allegedly flows from the fan, into the air chamber, and out through the vent. A photograph labels the "Vent Portion" on the device's exterior (Compl. p. 13). | ¶75 | col. 5:50-53 |
| a UV light source capable of emitting UV light rays positioned in the air chamber | The UVC Troffer contains a UV-C light source within its air chamber. A photograph provided in the complaint labels "A UV-C light fixture positioned in the air chamber" (Compl. p. 20). | ¶80 | col. 12:45-48 |
| a UV light screen positioned in the air chamber shielding the UV rays ... from exiting the air chamber | The UVC Troffer's "kill chamber" allegedly includes a UV light screen or shield adapted to block UV light from exiting the air chamber, as described by Defendant's marketing that the light is "hidden away for human eye safety" (Compl. p. 20). | ¶81 | col. 3:15-19 |
Identified Points of Contention
- Scope Questions: A potential issue may be whether the integrated components of the accused UVC Troffer's housing meet the definitions of the distinct claimed elements such as "lower baffle," "upper baffle" (’141 Patent), "face-plate," and "cover" (’223 Patent). The dispute may center on whether these terms require structurally separate pieces or can read on different sections of a single molded part.
- Technical Questions: The complaint alleges the UVC Troffer contains a "UV light screen" that "shields" UV rays from exiting. The analysis may raise the question of what degree of "shielding" is required by the claim and what evidence shows the accused device meets that standard beyond marketing statements about eye safety.
V. Key Claim Terms for Construction
The Term: "baffle"
Context and Importance
- This term is central to multiple asserted patents (e.g., ’141, ’223, ’857, ’573 Patents) as the baffles are claimed to define the "air chamber" and "kill zone." The construction of "baffle" will be critical in determining whether the internal structures of the accused product meet these structural limitations.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The specification describes baffles functionally, as they "direct the air flowing" and "guide air" (’141 Patent, col. 10:20-22, col. 10:60-61). This may support a construction covering any internal surface that directs airflow, regardless of its specific form.
- Evidence for a Narrower Interpretation: The figures consistently depict baffles as distinct, plate-like structures (e.g., upper baffle 1610 and lower baffles 1620, 1621 in ’141 Patent, Fig. 16A). This may support a narrower construction requiring a separate component, rather than an integral feature of a larger housing.
The Term: "air chamber"
Context and Importance
- The "air chamber" is the claimed location of the UV-C light fixture and the "kill zone." Its existence and configuration are fundamental to the infringement allegations for the ’141, ’026, ’223, and ’336 Patents.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The term is used generally to describe the space where air circulates, such as "an air chamber positioned within the housing adjacent the fan" (’026 Patent, cl. 7). This could suggest any defined internal void through which air is directed.
- Evidence for a Narrower Interpretation: Claim 11 of the ’141 Patent specifically defines the chamber as being formed "between the lower baffle and the upper baffle." This language, tied to specific structural components, may support a narrower construction requiring a void created by the assembly of distinct parts, not just any open space within a housing.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Defendant induces its customers to use the infringing UVC Troffer products (Compl. ¶64, ¶89, ¶113, ¶137, ¶166, ¶195). The factual basis for inducement may be inferred from allegations that Defendant advertises and sells the products with instructions and explanations of their infringing use (e.g., "Air is circulated through the fixture," "Invisible UVC light destroys the germs") (Compl. p. 9).
- Willful Infringement: Willfulness is alleged for all six patents based on Defendant’s alleged continued infringement after receiving Plaintiff’s notice letter of April 18, 2024 (Compl. ¶38). The complaint alleges this letter provided "knowledge of its infringement" and included detailed claim charts for four of the asserted patents, establishing a basis for pre-suit knowledge and deliberate disregard of Plaintiff's patent rights (Compl. ¶60-61, ¶65, ¶85-86, ¶90).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction and structural scope: Can claim terms rooted in the assembly of distinct components—such as "lower baffle," "upper baffle," "face-plate," and "cover"—be construed to read on the integrated sections of the accused UVC Troffer's single-body housing? The outcome will depend on whether these terms are interpreted functionally or as requiring separate structural elements as depicted in the patent figures.
- A key evidentiary question will be one of component identity: The complaint provides annotated photographs labeling various parts of the accused device to correspond with claim elements like "Upper Baffle" and "UV-C light screen." The case may turn on whether Defendant can demonstrate a fundamental structural or functional mismatch between these labeled sections and the specific limitations recited in the asserted claims.
- A central dispute regarding damages will likely be one of willfulness: Given the complaint's allegation that Plaintiff provided detailed pre-suit notice with claim charts, a key question for the court will be whether Defendant's continued sales were objectively and subjectively reckless, potentially justifying an award of enhanced damages.