DCT
1:24-cv-03577
Tsuen Jer Enterprises Co Ltd v. Cinmar LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Tsuen Jer Enterprise Co., Ltd. (Taiwan)
- Defendant: Cinmar, LLC. d.b.a Frontgate (Delaware)
- Plaintiff’s Counsel: Handal & Morofsky, LLC
- Case Identification: 1:24-cv-03577, E.D.N.Y., 05/16/2024
- Venue Allegations: Venue is alleged based on Defendant having a regular and established place of business in the district, specifically a retail establishment in Manhasset, NY, where it allegedly sells the accused products.
- Core Dispute: Plaintiff alleges that Defendant’s "Jameson Illuminated Indoor/Outdoor Clock" infringes a patent related to the internal structure and illumination mechanism of light-emitting clocks.
- Technical Context: The technology concerns the design of backlit analog clocks, focusing on methods to achieve uniform illumination without creating visually distracting hot spots or incurring high manufacturing costs.
- Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2018-07-27 | U.S. Patent No. 11,079,721 Priority Date |
| 2018-09-20 | U.S. Patent No. 11,079,721 Application Filing Date |
| 2021-08-03 | U.S. Patent No. 11,079,721 Issue Date |
| 2024-05-16 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,079,721 - "Light-Emitting Clock", issued August 3, 2021
The Invention Explained
- Problem Addressed: The patent seeks to solve problems with prior art light-emitting clocks, which often suffered from non-uniform illumination, created visually unpleasing "bright ring" effects, and involved costly manufacturing steps like creating special grooves to house lighting elements (’971 Patent, col. 2:1-24). These issues could also place "limitations on the appearance design of the clock" (’971 Patent, col. 2:15-18).
- The Patented Solution: The invention proposes a specific structural arrangement for a clock's components. A key feature is the placement of an annular lamp strip "at the washer," which itself is positioned between the clock's front and back covers (’971 Patent, Abstract; col. 3:45-48). This arrangement hides the light source (LEDs) from direct view behind the washer, allowing light to be cast inward to illuminate the dial indirectly and uniformly, simplifying the manufacturing process by eliminating the need for special grooves or separate light-diffusing papers (’971 Patent, col. 3:57-65).
- Technical Importance: This design purports to simplify the manufacturing process and reduce costs while improving the visual aesthetics of illuminated clocks by providing more uniform, less direct lighting.
Key Claims at a Glance
- The complaint asserts independent claim 1 and dependent claims 2, 4-5, and 7-12 (Compl. ¶8).
- Independent Claim 1 requires:
- A case comprising a front cover, a back cover, and a washer, with the washer disposed between the front and back covers.
- A dial disposed between the washer and the back cover.
- A light-emitting mechanism with a switch, a power unit, and at least one lamp strip, where the switch and power unit are on the back cover and the lamp strip is "annularly disposed at the washer."
- A light-emitting surface of the lamp strip that "at least faces a rim of the dial."
- A movement disposed on the back cover.
- A plurality of hands coupled to the movement.
III. The Accused Instrumentality
Product Identification
The accused product is the "Jameson Illuminated Indoor/Outdoor Clock" sold by Defendant under its Frontgate brand (Compl. ¶9).
Functionality and Market Context
The accused product is an analog wall clock designed for indoor or outdoor use with a feature that illuminates the clock face (Compl. ¶9). The complaint presents detailed photographic evidence from a teardown of the product, showing its internal components including a clock case, a dial, a clock movement, and an LED lamp strip used for illumination (Compl. ¶9, pp. 5-10). The complaint does not provide specific details on the product's market position beyond alleging that Defendant sells it (Compl. ¶2).
IV. Analysis of Infringement Allegations
’971 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A light emitting clock, comprising: a case having a front cover, a back cover and a washer... | The accused clock allegedly includes a case with a front cover, a back cover, and a washer. A photograph shows these components disassembled. (Compl. ¶9, p. 5) | ¶9 | col. 3:32-34 |
| with the washer disposed between the front cover and the back cover; | The accused clock's washer is allegedly positioned between the front and back covers. A photograph depicts a component identified as the washer placed on the clock face, between the front and back covers. (Compl. ¶9, p. 6) | ¶9 | col. 3:34-36 |
| a dial disposed between the washer and the back cover; | The accused clock allegedly has a dial located between the washer and the back cover. A photograph shows the dial with hands, which the complaint alleges is positioned between the washer and back cover. (Compl. ¶9, p. 6) | ¶9 | col. 3:40-41 |
| a light-emitting mechanism comprising a switch, a power unit electrically connected to the switch, and at least one lamp strip electrically connected to the switch, wherein the switch and the power unit are disposed on the back cover... | The accused clock's back cover allegedly houses a light sensor switch and a power unit (batteries). Photographs show the back of the clock with these components. (Compl. ¶9, pp. 7-8) | ¶9 | col. 3:41-45 |
| with the lamp strip annularly disposed at the washer, and | The accused clock allegedly has an annular lamp strip disposed at the washer. A photograph shows the lamp strip being placed along the inner circumference of the washer. (Compl. ¶9, p. 8) | ¶9 | col. 3:45-46 |
| a light-emitting surface of the lamp strip at least faces a rim of the dial | The complaint alleges the accused clock's lamp strip has a light-emitting surface that faces a rim of the dial. A photograph shows the assembled clock face, implying this orientation. (Compl. ¶9, p. 9) | ¶9 | col. 3:46-48 |
| a movement disposed on the back cover; and | The accused clock allegedly has a clock movement mechanism mounted on the back cover. A photograph displays the back cover with the movement installed. (Compl. ¶9, p. 9) | ¶9 | col. 4:52-53 |
| a plurality of hands coupled to the movement and corresponding in position to a side of the dial | The accused clock allegedly has hands connected to the movement. A photograph shows the hands on the clock face, which are coupled to the movement on the reverse side. (Compl. ¶9, p. 10) | ¶9 | col. 4:53-56 |
- Identified Points of Contention:
- Technical Questions: While the complaint presents a visually compelling, side-by-side comparison of the patent figures and the accused product, a technical question is whether the accused product's components function in the manner required by the claims. For instance, what evidence demonstrates that the accused clock's "light-emitting surface... at least faces a rim of the dial" in operation, beyond the static positioning shown in photographs?
- Scope Questions: The dispute may center on the precise definition of claim terms. For example, what is the scope of "disposed at the washer"? Does it require direct physical contact, attachment, or merely proximate placement? The answer could determine whether the accused product's assembly, as shown in the complaint's photographs (Compl. ¶9, p. 8), meets this limitation. The plaintiff's pleading of the doctrine of equivalents suggests an anticipation that the defendant may argue for a narrow construction of this or other terms (Compl. ¶10).
V. Key Claim Terms for Construction
- The Term: "annularly disposed at the washer" (Claim 1)
- Context and Importance: This term is central as it defines the spatial relationship between the light source (lamp strip) and a key structural element (the washer), which is the core of the asserted inventive concept for achieving simplified, uniform illumination. The infringement analysis hinges on whether the accused clock's lamp strip is arranged "at the washer" as claimed.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the lamp strip as "annularly disposed at the bottom of the washer 13" (’971 Patent, col. 3:45-46). This language may support an interpretation that the strip need only be located at or near the washer's structure, not necessarily integrated within it.
- Evidence for a Narrower Interpretation: The specification also discloses a "preferred embodiment" where a "receiving groove 133 is annularly disposed at the inner edge of the bottom of the washer 13" and the "lamp strip 5 is disposed in the receiving groove 133" (’971 Patent, col. 5:10-13). A defendant may argue that "disposed at" should be interpreted more narrowly to require a specific form of seating or attachment, potentially pointing to the groove as the intended meaning, even though it is described in a preferred embodiment.
VI. Other Allegations
- Indirect Infringement: The complaint includes boilerplate allegations of induced and contributory infringement (Compl. ¶2), but does not plead specific facts, such as references to user manuals or marketing materials, that would support the requisite elements of knowledge and intent.
- Willful Infringement: The complaint alleges that Defendant's infringement is "willful, wanton, malicious and intentional" (Compl. ¶15). However, the complaint does not allege any facts to support pre-suit knowledge of the ’971 Patent, which is typically a predicate for establishing pre-suit willfulness.
VII. Analyst’s Conclusion: Key Questions for the Case
The complaint presents a detailed, visually-supported infringement theory. The case will likely focus on the following core questions:
A core issue will be one of definitional scope: can the term "disposed at the washer," which is central to the patent's claimed structure, be construed to read on the specific assembly method used in the accused clock? The outcome of claim construction for this term may be dispositive.
A key evidentiary question will be one of factual comparison: assuming a claim construction is established, are there subtle but material differences in the structure, materials, or functional relationships of the components in the accused "Jameson" clock that distinguish it from the literal language of the asserted claims? The plaintiff's decision to plead infringement under the doctrine of equivalents suggests it anticipates such arguments.