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., 11/07/2025
• Venue Allegations: Venue is alleged based on Defendant operating a regular and established place of business within the district and selling the accused products in the district.
• Core Dispute: Plaintiff alleges that Defendant’s illuminated clocks infringe a patent related to a specific structural arrangement for providing uniform, indirect lighting for a clock face.
• Technical Context: The technology concerns the design and manufacture of analog clocks with internal illumination, aiming to improve light uniformity and reduce production complexity and cost.
• Key Procedural History: The complaint alleges a pre-existing business relationship between the parties, wherein Defendant was a customer of Plaintiff. Plaintiff claims it informed Defendant of the invention and the pending patent application before the patent issued, and that Defendant was provided with Plaintiff’s CAD files for the patented clock.

Case Timeline

Date	Event
2018-07-27	’721 Patent Priority Date
2018-09-20	’721 Patent Application Filing Date
2021-08-03	’721 Patent Issue Date
2025-11-07	Complaint Filing Date

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

U.S. Patent No. 11,079,721 - "Light-Emitting Clock"

• Patent Identification: U.S. Patent No. 11,079,721, "Light-Emitting Clock," issued August 3, 2021 (’721 Patent).

The Invention Explained

• Problem Addressed: The patent seeks to solve problems with prior art illuminated clocks, which either suffered from non-uniform lighting that was visually unappealing and caused eye strain, or required complex and costly manufacturing steps to achieve uniformity, such as machining special grooves into components or adding separate light-diffusing papers (’721 Patent, col. 1:26-33, col. 2:1-12).
• The Patented Solution: The invention proposes a simplified clock structure where an annular strip of lights (a "lamp strip") is positioned "at the washer," a ring-like component situated between the front and back covers of the clock case (’721 Patent, col. 2:42-48). This lamp strip is hidden from direct view and emits light inward, across the rim of the dial, as illustrated in the exploded view of Figure 5 (’721 Patent, Fig. 5, col. 3:45-51). The light then reflects off a screen-printed layer on the back of an acrylic plate to illuminate the clock face evenly, eliminating the need for complex grooves or extra diffusing layers (’721 Patent, col. 2:36-51).
• Technical Importance: This design simplifies the manufacturing process for an evenly illuminated clock, potentially reducing production costs and enhancing production efficiency by removing specialized machining and assembly steps (’721 Patent, col. 3:65-col. 4:2).

Key Claims at a Glance

• The complaint asserts independent claim 1 and dependent claims 2, 4-5, and 7-12 (Compl. ¶8).
• Essential elements of independent claim 1 include:
  • A case having a front cover, a back cover and a washer, with the washer disposed between the front and back cover.
  • A dial disposed between the washer and the back cover.
  • A light-emitting mechanism including a switch, power unit, and at least one lamp strip.
  • The switch and power unit are disposed on the back cover.
  • The lamp strip is annularly disposed at the washer.
  • A light-emitting surface of the lamp strip at least faces a rim of the dial.
  • A movement disposed on the back cover.
  • A plurality of hands coupled to the movement.
• The complaint asserts dependent claims adding limitations such as a receiving groove for the lamp strip (claim 2), the use of an acrylic plate with a screen printing ink layer (claim 8), and specific circuitry for the lamp strip (claim 12) (Compl. ¶¶9, 13-14).

III. The Accused Instrumentality

Product Identification

• 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 (Compl. ¶9). Its relevant functionality, as alleged in the complaint, involves an internal illumination system that lights up the clock face. The complaint provides photographic evidence depicting the clock's assembly, including a front cover, a back cover, a dial, and an internal ring of LED lights powered by batteries held in the back cover (Compl. p. 5, 7). The complaint alleges these "Infringing Clocks" incorporate the elements of the asserted claims (Compl. ¶9). An exploded-view photograph of the accused product shows its constituent parts, including a front cover, back cover, and a washer-like component (Compl. p. 5).

IV. Analysis of Infringement Allegations

Claim Chart Summary

• The complaint provides a detailed, element-by-element comparison of claim 1 of the ’721 Patent to the accused product, supported by photographic evidence (Compl. ¶9).

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a case having a front cover, a back cover and a washer, the front cover being coupled to the back cover, with the washer disposed between the front cover and the back cover	The accused clock is alleged to have a case with a front cover, back cover, and a washer component disposed between them.	¶9	col. 3:32-35
a dial disposed between the washer and the back cover	The accused clock allegedly includes a dial positioned between the washer and the back cover.	¶9	col. 3:40-42
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	The accused clock's light-emitting mechanism is alleged to include a switch, a battery power unit, and an LED lamp strip, all electrically connected.	¶9	col. 3:42-45
wherein the switch and the power unit are disposed on the back cover	The switch and battery-holding power unit of the accused clock are allegedly located on its back cover. A photograph shows the battery compartment on the clock's rear (Compl. p. 8).	¶9	col. 3:45-46
with the lamp strip annularly disposed at the washer, and a light-emitting surface of the lamp strip at least faces a rim of the dial	The accused clock allegedly has an annular LED lamp strip disposed at its washer, with the LEDs oriented to face the rim of the dial. A close-up photograph shows the lamp strip positioned to emit light inward (Compl. p. 9).	¶9	col. 3:46-48
a movement disposed on the back cover; and	The clock movement mechanism in the accused product is allegedly disposed on the back cover.	¶9	col. 3:51-52
a plurality of hands coupled to the movement and corresponding in position to a side of the dial	The accused clock allegedly has hour and minute hands coupled to the movement and positioned over the dial face.	¶9	col. 3:52-55

Identified Points of Contention

• Scope Questions: The dispute may center on the definition of "washer." The defense could argue that the annular component in the accused product is merely a structural frame or reflector and not a "washer" as contemplated by the patent, which describes it as being disposed between the front and back covers to create a stable assembly (’721 Patent, col. 5:14-19).
• Technical Questions: A primary question will be whether the lamp strip in the accused product is "disposed at the washer" in the manner required by the claim. The analysis will likely focus on the precise physical relationship—whether it is attached to, seated within, or merely adjacent to the component Plaintiff identifies as the washer. The complaint's photographs appear to show the lamp strip affixed to an annular ring, but the nature and function of that ring relative to the overall clock assembly will be a key factual issue.

V. Key Claim Terms for Construction

The Term: "washer"

• Context and Importance: The identity of this component is foundational to the infringement read, as the key limitation of claim 1 requires the "lamp strip [to be] annularly disposed at the washer." If the accused clock's annular ring is not construed as a "washer," the claim may not be infringed. Practitioners may focus on this term because its definition governs the location and structural context of the invention's core lighting element.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the washer as being "disposed between the front cover and the back cover" and being "made of a plastic material and thus is capable of plastic deformation" to ensure a stable connection (’721 Patent, col. 5:12-19). This functional description could support a broader definition that includes any annular plastic spacer serving a similar structural role.
  • Evidence for a Narrower Interpretation: The patent consistently labels component 13 in its figures as the "washer" and describes specific embodiments where the lamp strip is placed in a "receiving groove" on the washer (’721 Patent, Fig. 5; col. 5:10-13). A defendant might argue that the term is limited to a component with these specific characteristics or relationships shown in the preferred embodiments.

The Term: "disposed at the washer"

• Context and Importance: This term dictates the required location of the lamp strip. The infringement analysis depends on whether the accused product's lamp strip has the same positional relationship to its "washer" as required by the claim.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language "at the washer" could be interpreted broadly to mean near, adjacent to, or in the general vicinity of the washer. The Abstract states the lamp strip is "annularly disposed at the washer," without requiring direct attachment (’721 Patent, Abstract).
  • Evidence for a Narrower Interpretation: The detailed description specifies that in a preferred embodiment, the lamp strip "is disposed at the bottom of the washer 13" and, more specifically, "is disposed in the receiving groove 133" located at an inner edge of the washer's bottom (’721 Patent, col. 3:45-46; col. 5:10-13). This could support an argument that "at the washer" requires a more intimate or integrated physical connection, such as being seated within a feature of the washer itself.

VI. Other Allegations

Indirect Infringement

• The complaint does not contain specific counts or factual allegations for indirect infringement (inducement or contributory infringement).

Willful Infringement

• The complaint alleges willful infringement based on a pre-existing business relationship where Defendant was Plaintiff's customer (Compl. ¶16). It further alleges that Plaintiff gave Defendant "explicit notice of the pending application which matured into the '721 Patent" and that Defendant continued to sell the accused clocks after the complaint was filed (Compl. ¶¶17, 19, 21).

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

• A core issue will be one of definitional scope: can the term "washer," as described in the specification as a deformable plastic component that helps fix the case together, be construed to read on the annular ring component of the accused clock? The case may turn on whether the term implies a specific structural function that the accused component does or does not perform.
• A central evidentiary question will be one of structural location: does the placement of the lamp strip in the accused product meet the claim limitation of being "disposed at the washer"? This will require a detailed factual analysis of the components' physical relationship, weighing a broader interpretation ("near") against a narrower one ("attached to" or "seated within").
• Finally, the allegations of a pre-existing relationship and pre-suit notice of the pending application raise a significant question regarding willfulness. The outcome will depend on evidence presented regarding the content and timing of communications between the parties prior to litigation.