DCT

7:25-cv-06585

Chengdu Shiqiaoshang Technology Co Ltd v. Pathway IP LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 7:25-cv-06585, S.D.N.Y., 08/11/2025
  • Venue Allegations: Venue is asserted based on Defendant’s residence and principal place of business within the Southern District of New York.
  • Core Dispute: Plaintiffs seek a declaratory judgment that their personal video lighting products do not infringe Defendant's patent, and further that the patent-in-suit is invalid and unenforceable.
  • Technical Context: The lawsuit concerns portable LED lighting systems designed to be attached to personal computers to provide enhanced facial illumination for video conferencing.
  • Key Procedural History: This is a declaratory judgment action filed by the Plaintiffs after Defendant’s counsel allegedly indicated an intent to file an infringement suit. The complaint alleges the patent-in-suit expired in 2021 for failure to pay a maintenance fee and was revived in 2024 based on a petition to the USPTO that Plaintiffs claim contained false statements, forming the basis for an inequitable conduct allegation.

Case Timeline

Date Event
2011-03-21 '293 Patent Priority Date
2013-08-06 '293 Patent Issue Date
2021-09-13 Alleged expiration of '293 Patent for non-payment of maintenance fee
2024-07-01 Inventor petition to USPTO to revive '293 Patent
2024-12-01 Alleged assignment of '293 Patent to Defendant (approximate date)
2025-05-02 Defendant files infringement suit against other Amazon sellers
2025-08-11 Complaint Filing Date

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

U.S. Patent No. 8,500,293 - Personal video lighting system (Issued Aug. 6, 2013)

The Invention Explained

  • Problem Addressed: The patent’s background section identifies a need for improved lighting for personal video communication, noting that typical light sources either create "unflattering harsh shadows," "wash out" facial features, or have a poor, bluish color balance. (’293 Patent, col. 1:35-2:34).
  • The Patented Solution: The invention proposes a lighting system with two or more white light-emitting diodes (LEDs) "spaced some distance apart" to provide more balanced, even illumination and reduce shadows. (’293 Patent, Abstract; col. 1:24-34). The system is designed to attach to a personal computer display and uses LEDs with specific color properties to achieve a more favorable appearance for the user on camera. (’293 Patent, col. 5:36-45).
  • Technical Importance: The technology aimed to provide an affordable, consumer-grade solution to improve on-camera appearance as video conferencing became increasingly common for business and social purposes. (’293 Patent, col. 1:43-2:2).

Key Claims at a Glance

  • The complaint challenges independent claims 1, 11, 15, 16, and 18. (Compl. ¶21, 23). Claim 1 is representative.
  • Independent Claim 1:
    • A lighting system for use with a personal computer, comprising a body, one or more light panels,
    • two or more white LED's disposed on said one or more light panels,
    • a flexible support arm connecting said body to said one or more light panels,
    • a means of power,
    • an adjustable pulse width modulation circuit operatively connecting said two or more white LED's to said means of power,
    • wherein said two or more white LED's have a CIE 1931 color chromaticity x coordinate between 0.300 and 0.420 and a CIE 1931 color chromaticity y coordinate between 0.300 and 0.420.
  • The complaint reserves the right to address dependent claims, noting they cannot be infringed if the independent claims are not. (Compl. ¶25).

III. The Accused Instrumentality

Product Identification

  • The "Light Products" are identified as NEEWER-branded products sold on Amazon under ASIN B0DCSHSSFF, specifically the "NEEWER Basic 5" Ring Light for Video Conference Lighting". (Compl. ¶11).

Functionality and Market Context

  • The accused product is a ring light that attaches to a computer monitor using a "rigid clip" and a "rigid ball-head/tilt joint," with an optional rigid mini-tripod for desk use. (Compl. ¶22). The Amazon product page included in the complaint shows a clip-on ring light with a small tripod stand. (Compl. p. 3). The light employs two distinct sets of LEDs—"warm white" and "cool/white"—which can be used separately or together to create different color temperatures. (Compl. ¶23).
  • The complaint asserts the product is "well-established, popular on Amazon, and have been designated as 'Amazon's Choice'," suggesting a significant market presence. (Compl. ¶11).

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement, putting forth at least two distinct arguments.

’293 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged (Non-)Infringing Functionality Complaint Citation Patent Citation
a flexible support arm connecting said body to said one or more light panels The product uses a "rigid clip" and a "rigid ball-head/tilt joint," and does not include a flexible, bendable, "gooseneck-type" arm as described in the patent. ¶22 col. 6:55-60
wherein said two or more white LED's have a CIE 1931 color chromaticity x coordinate between 0.300 and 0.420 and a CIE 1931 color chromaticity y coordinate between 0.300 and 0.420 The product uses two discrete sets of LEDs (warm and cool), which allegedly have chromaticity coordinates that fall outside the claimed range. The complaint argues the claim applies to the LEDs themselves, not a blended beam. ¶23; p. 6 col. 5:36-45

Identified Points of Contention

  • Scope Question: A central dispute may be whether the term "flexible support arm" as used in the patent can be interpreted to cover the accused product's combination of a rigid clip and a ball-head/tilt joint.
  • Technical and Scope Question: The infringement analysis will likely turn on whether the chromaticity limitation applies to the properties of the individual LED components, as the complaint argues, or to the blended light output of the entire device. The complaint provides no evidence that the blended output falls within the claimed range, focusing instead on the properties of the component LEDs.

V. Key Claim Terms for Construction

The Term: "flexible support arm"

  • Context and Importance: This term is critical to the first non-infringement argument. A narrow construction may support the Plaintiffs' position, while a broader one may support a finding of infringement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself does not further define "flexible," which could be argued to mean any support that allows for adjustment of the light's position.
    • Evidence for a Narrower Interpretation: The specification describes a preferred embodiment as a "tubular structure, also commonly known as 'gooseneck' tubing" and lists other examples like a "telescopic arm" and "plastic coated bendable wire," suggesting structures that can be bent and hold their shape. (’293 Patent, col. 6:55-63).

The Term: "white LED's have a CIE 1931 color chromaticity..."

  • Context and Importance: The interpretation of this phrase is the basis for the second non-infringement argument. Practitioners may focus on this term because the dispute is whether the limitation describes the input components or the final output.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party could argue that the purpose of the invention is to control the final illumination quality, so the relevant measurement should be of the light produced by the system, not the individual components. The patent discusses improving the "color balance of the rendered image." (’293 Patent, col. 5:33-34).
    • Evidence for a Narrower Interpretation: The claim language states the "white LED's have" the property, which grammatically points to the components themselves. The specification discusses the properties of "single-chip white LED's" and their spectral output, supporting a focus on the component-level characteristics. (’293 Patent, col. 2:5-13, Fig. 36).

VI. Other Allegations

  • Invalidity: Plaintiffs allege that claims 1-20 are invalid as anticipated or obvious under 35 U.S.C. §§ 102 and 103 in view of several prior art references. (Compl. ¶¶ 29-34). These references allegedly teach key features of the claimed invention, including: defining white LEDs by chromaticity coordinates (ANSI Standard), using a ring-light with an adjustable arm for a webcam (Henry), and using a portable LED light with a flexible, gooseneck-style body and clamp for laptops (Naghi and Nelson). (Compl. ¶¶ 30-33).
  • Unenforceability (Inequitable Conduct): The complaint alleges the ’293 patent is unenforceable due to inequitable conduct before the USPTO. (Compl. ¶¶ 36-46). The core of this allegation is that the inventors intentionally allowed the patent to lapse for non-payment of maintenance fees, and then, nearly three years later, filed a petition to revive the patent based on the "false statement" that the failure to pay was "unintentional." (Compl. ¶¶ 39, 41, 44). The complaint alleges this was done with the intent to deceive the USPTO and was motivated by the Defendant's intent to acquire the patent for litigation. (Compl. ¶¶ 42, 44).

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

  • A core issue will be one of claim construction: can the term "flexible support arm," described in the specification with examples like "gooseneck" tubing, be construed to read on the accused product’s combination of a rigid clip and a ball-head joint?
  • A second key question will be one of technical interpretation: does the claim’s chromaticity limitation apply to the individual LED components, as Plaintiffs contend, or to the blended light output from the device?
  • Beyond infringement, a critical factual question will be the inventors’ intent regarding the patent’s lapse and revival. The case may turn on whether Plaintiffs can prove that the inventors' sworn statement to the USPTO—that the non-payment of maintenance fees was "unintentional"—was a deliberate misrepresentation made with deceptive intent, which could render the entire patent unenforceable.