DCT
1:26-cv-00053
Simplismart LLC v. Wuhan Tiejinni Technology Co
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: SimpliSmart LLC (Delaware)
- Defendant: Wuhan Tiejinni Technology Company d/b/a Slochi (China) and Ningbo Meishan Bonded Port Maisilang Photoelectric Technology Co., Ltd. d/b/a Amico (China)
- Plaintiff’s Counsel: Garson, Segal, Steinmetz, Fladgate LLP
- Case Identification: 1:26-cv-00053, S.D.N.Y., 01/05/2026
- Venue Allegations: Plaintiff alleges venue is proper in the Southern District of New York because Defendants are subject to personal jurisdiction in the district and have committed acts of infringement there, including offering for sale and selling the accused products to customers in New York via e-commerce platforms like Amazon.com.
- Core Dispute: Plaintiff alleges that Defendants’ multi-state LED lighting products infringe two patents related to a control architecture that uses momentary power interruptions from a standard wall switch to change lighting characteristics such as color temperature and brightness.
- Technical Context: The technology enables advanced lighting features in a self-contained fixture, eliminating the need for wireless hubs, mobile applications, or specialized wiring common in the consumer smart lighting market.
- Key Procedural History: The complaint alleges that Defendants reverse-engineered and deliberately copied Plaintiff's patented technology, but does not reference prior litigation, inter partes review proceedings, or licensing history between the parties.
Case Timeline
| Date | Event |
|---|---|
| 2017-01-23 | U.S. Patent No. 10,448,477 Priority Date |
| 2017-01-23 | U.S. Patent No. 10,802,524 Priority Date |
| 2019-10-15 | U.S. Patent No. 10,448,477 Issued |
| 2020-10-13 | U.S. Patent No. 10,802,524 Issued |
| 2026-01-05 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,448,477 - Adjustable Lighting System (Issued Oct. 15, 2019)
The Invention Explained
- Problem Addressed: The patent's background section describes the limitations of conventional lighting controls. These include the need for special fixtures for 3-way bulbs, the installation and capacity limits of electronic dimmers, and the complexity of smart systems that rely on RF remotes or Wi-Fi hubs, which can be difficult for non-technical users (’477 Patent, col. 1:11-63).
- The Patented Solution: The invention is a self-contained light bulb or fixture that interprets brief, user-generated toggles of a standard wall switch as control signals. This method, termed "continuous wave modulation," allows a user to cycle through different lighting states (e.g., color temperatures, brightness levels) without any rewiring or external devices ('477 Patent, col. 2:31-46). Internal circuitry, including a power-off detection circuit and a memory unit, detects these power fluctuations and retains the selected setting across power cycles ('477 Patent, Fig. 1).
- Technical Importance: This approach provided a "plug-and-play" method for retrofitting existing lighting infrastructure with advanced, adjustable features, removing technical barriers for consumers (Compl. ¶¶29-31).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶69).
- Essential elements of claim 1 include:
- A light-emitting device with three or more visually distinguishable lighting states (based on color temperature or brightness).
- A first circuit to detect a first sequence of "momentary fluctuations of power" (e.g., from On to Off to On) as a first user control message.
- A second circuit to detect a different, second sequence of "momentary fluctuations of power" (e.g., from Off to On to Off) as a second user control message.
- A memory circuit to store the current lighting state and retain it during periods of power-off.
- The complaint reserves the right to assert additional claims (Compl. ¶80).
U.S. Patent No. 10,802,524 - Adjustable Electronic Control System (Issued Oct. 13, 2020)
The Invention Explained
- Problem Addressed: The patent expands on the problem of its parent ('477 Patent), noting that similar control limitations exist for other electrical devices, such as ceiling fans with separate, often inconvenient, controls for fan speed and lighting (’524 Patent, col. 2:16-25).
- The Patented Solution: The invention is a generalized control system or "enhancement module" that applies the power-fluctuation control method to a broader class of electrical devices ('524 Patent, Abstract). A key feature is the introduction of a control message that corresponds to a "fixed Reset electrical operational state," which forces the device into a predetermined state regardless of its current setting, thereby enabling synchronization across multiple devices ('524 Patent, col. 15:46-53).
- Technical Importance: The invention aims to provide a unified, simple control scheme for various household devices using only existing wall switches, extending beyond lighting applications (Compl. ¶29; '524 Patent, col. 2:45-51).
Key Claims at a Glance
- The complaint asserts at least independent claims 1 and 13 (Compl. ¶¶129-130).
- Essential elements of claim 1 include:
- An electrical device with at least two different operational states.
- Circuitry to detect a first sequence of power fluctuations defining a "First user message" that changes the operational state.
- Circuitry to detect a different, second sequence of power fluctuations defining a "Second user message" that corresponds to and implements a "fixed Reset electrical operational state."
- A memory circuit to store and retain the current state during power-off periods.
III. The Accused Instrumentality
Product Identification
The "Slochi" lighting series (e.g., model CL40A-8-WT) and the "Amico" lighting products (e.g., model RD11-04-09-UC5-DN-WH) (Compl. ¶¶35, 66).
Functionality and Market Context
The complaint alleges the accused products are self-contained lighting systems that enable users to select from multiple lighting states, such as different color temperatures (e.g., warm white, neutral, daylight), by toggling a standard wall switch (Compl. ¶¶36, 47). The products allegedly use internal electronics to detect "brief off/on sequences" as control commands and incorporate onboard memory to recall the most recent setting when powered back on (Compl. ¶¶42-43). A marketing image provided in the complaint for an accused product shows five selectable color temperatures and depicts user control via an "EASY CONTROL SWITCH" (Compl. p. 15). The complaint characterizes the products as "low-cost imitations" sold on e-commerce platforms like Amazon.com that were created by deliberately reverse-engineering Plaintiff's technology (Compl. ¶¶10, 33-34).
IV. Analysis of Infringement Allegations
'477 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a light-emitting device comprising a plurality of individual light-emitting sub-elements...having three or more different lighting states...differentiated by color temperature...brightness, or a combination thereof | The accused products are LED fixtures with multiple LED sub-elements that provide multiple states distinguished by color temperature (e.g., warm, neutral, daylight) and/or brightness levels. | ¶¶72, 74-75 | col. 8:56-64 |
| a circuit configured to detect a sequence of one or more momentary fluctuations of power...defining a First user control message...comprises a sequence...from the On state, to the Off state, and then back to the On state | The accused products contain on-board circuitry that detects a first sequence of power toggles, alleged to be an "on-off-on" sequence, as a control message to change the lighting state. | ¶76 | col. 8:7-17 |
| a circuit configured to detect a sequence of one or more momentary fluctuations of power, different from the sequence of the First user control message, defining a Second user control message | The accused products contain circuitry that detects a second, different sequence of power toggles, alleged to be an "off-on-off" sequence, associated with a different state change. | ¶77 | col. 8:17-21 |
| a memory circuit configured to store multiple lighting states and to retain the current state during periods of power off for recall upon power restoration | The accused products include memory circuitry configured to store their multiple lighting states and retain the last-used state during power-off periods for recall at the next power-on. | ¶78 | col. 8:22-26 |
- Identified Points of Contention:
- Scope Questions: A central question may be whether a consumer's typical interaction with a light switch can reliably generate the two distinct "sequences" of power fluctuations (On-Off-On vs. Off-On-Off) required by claim 1.
- Technical Questions: The analysis may focus on the specific timing and logic implemented in the accused products' control circuitry. What evidence demonstrates that the circuitry distinguishes between two different types of user-generated power toggles to trigger two different functions, as opposed to treating all quick toggles as a single type of "cycle" command? A provided marketing image depicts selectable color temperatures in various room settings, supporting the allegation of multiple distinguishable states (Compl. p. 16).
'524 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| An electrical device...having at least two different electrical operational states | The accused lighting products have multiple operational states, such as different selectable color temperatures. | ¶¶67, 129 | col. 15:37-39 |
| a) circuitry configured to detect a sequence of one or more momentary fluctuations of power defining a First user message, said First message corresponding to a change in electrical operational state | The accused products detect a sequence of power fluctuations from a wall switch to change from one lighting state to another. | ¶129(a) | col. 15:40-45 |
| b) circuitry configured to detect a different sequence of one or more momentary fluctuations of power defining a second user message...defining a fixed Reset electrical operational state...implementing a change from the current state...to the fixed reset state | The accused products detect a second, different sequence of power fluctuations that corresponds to and defines a fixed reset state, causing the device to change to that reset state regardless of its current state. | ¶129(b) | col. 15:46-53 |
| c) a memory circuit...configured to store the current electrical operational state...during periods of power off | The accused products use a memory circuit to store the current lighting state and retain that state when power is off. | ¶129(c) | col. 15:53-59 |
- Identified Points of Contention:
- Scope Questions: The dispute may center on the meaning of a "fixed Reset electrical operational state." Does merely cycling back to a default "State 1" qualify, or must the function be a non-sequential jump to a predetermined state from any other state in the sequence?
- Technical Questions: What evidence does the complaint provide that the accused products implement a function that is distinct from a standard "cycle" command and that forces the device into a "fixed Reset state" from any other state? This functional distinction is central to differentiating the alleged infringement of the '524 patent from that of the '477 patent.
V. Key Claim Terms for Construction
For the '477 Patent: "momentary fluctuations of power"
- Context and Importance: This term defines the core user input mechanism. Its construction will determine which user actions qualify as control "messages" and is therefore critical to the infringement analysis for both asserted patents.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification refers generally to a "momentary toggle of the light switch to off" ('477 Patent, col. 2:37-38) and "brief power off pulses" ('477 Patent, col. 4:32), which could suggest the term covers any brief interruption of power initiated by a user.
- Evidence for a Narrower Interpretation: An embodiment described in the specification defines specific durations, distinguishing between a "short power off pulse between 100 and 500 milliseconds" and a "long power off pulse between 500 and 1000 milliseconds" ('477 Patent, col. 4:52-56). A party could argue these examples limit the scope of "momentary."
For the '524 Patent: "fixed Reset electrical operational state"
- Context and Importance: This term is a key limitation in claim 1 of the '524 Patent, distinguishing it from a simple cyclical system. Infringement depends on whether the accused products implement a function that forces a return to a specific, predetermined state rather than merely advancing to the next state in a sequence.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim requires implementing a change "from the current electrical operational state, regardless of which electrical operational state that may be, to the fixed Reset electrical operational state" ('524 Patent, col. 15:50-53). This language suggests a global reset function that overrides the device's current position in its operational cycle.
- Evidence for a Narrower Interpretation: A defendant may argue that a system that simply cycles back to its initial power-on state after reaching the end of its sequence does not meet this limitation. The prosecution history and specification may be used to argue that "Reset" implies a specific, non-cyclical command that is distinct from the primary state-advancement command.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement for both patents. It alleges inducement is based on Defendants providing user instructions and marketing materials on platforms like Amazon that encourage infringing use (Compl. ¶¶91, 149). It alleges contributory infringement on the basis that the accused products are not staple articles of commerce and are especially made for the infringing purpose, as their core advertised functionality is the patented multi-state control (Compl. ¶¶102-103, 137-138).
- Willful Infringement: The complaint alleges willful infringement based on constructive notice since the patents issued and continued infringement after the filing of the complaint (Compl. ¶¶84-85). It further supports this allegation by claiming Defendants deliberately reverse-engineered and copied Plaintiff's commercial products (Compl. ¶¶33, 39-40, 145).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core evidentiary question will be one of technical implementation: Does the circuitry in the accused products detect and differentiate between two distinct types of user-generated power interruptions to trigger functionally separate commands (e.g., "cycle to next state" versus "reset to fixed state"), as required by the combination of the asserted claims?
- A central issue of claim scope will be whether the '524 Patent's "fixed Reset...state" limitation can be interpreted to cover a device that simply cycles back to its initial state, or if it requires a distinct, non-sequential reset function. The ability to prove the accused products practice this specific reset function will be critical for the '524 Patent infringement theory.
- A key factual dispute will involve evidence of copying: The allegations of deliberate reverse-engineering, if substantiated through discovery, could significantly influence the analysis of non-obviousness, willfulness, and potentially the application of the doctrine of equivalents.