DCT

2:26-cv-00045

DS Advanced Enterprisesss Ltd v. Home Depot Inc

Log In
Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-00045, S.D. Ohio, 01/14/2026
  • Venue Allegations: Plaintiff alleges venue is proper in the Southern District of Ohio based on Defendant operating at least 70 retail stores and multiple distribution centers within the state, including in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s "3-in-1 Universal Installation" recessed lighting products infringe two patents related to versatile mounting systems for light fixtures.
  • Technical Context: The technology addresses lighting fixtures with adaptable hardware, enabling installation in multiple scenarios (e.g., into existing recessed housings, in new construction without a housing, or to a junction box) from a single product kit.
  • Key Procedural History: The complaint alleges that the inventor presented the technology, then the subject of a patent application, to Home Depot representatives in April and August 2019. It also notes that Home Depot was accused of infringing the ’118 Patent in a separate 2023 litigation. Plaintiff allegedly sent a demand letter regarding the ’783 Patent in July 2025.

Case Timeline

Date Event
2018-05-18 ’118 Patent Priority Date
2019-04-02 Plaintiff allegedly gave first presentation to Home Depot on technology related to the ’118 Patent application
2019-08-27 Plaintiff allegedly gave second presentation to Home Depot on technology related to the ’118 Patent application
2019-08-28 Plaintiff's inventor corresponded with Home Depot buyer via email
2021-07-06 ’118 Patent Issue Date
2021-08-27 ’783 Patent Priority Date
2023-XX-XX Home Depot U.S.A., Inc. was accused of infringing the ’118 Patent in separate litigation
2024-03-14 Creation date alleged for one of the Accused Product manuals
2024-03-18 Creation date alleged for one of the Accused Product manuals
2024-04-24 Energy Star certification date alleged for Accused Products
2024-05-07 Market availability date alleged for Accused Products
2025-07-15 ’783 Patent Issue Date
2025-07-18 Plaintiff sent demand letter to Home Depot regarding the ’783 Patent
2026-01-14 Complaint Filing Date

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

U.S. Patent No. 12,359,783 - *System and Apparatus to Attach a Light Fixture to One of a Ceiling, a Recessed Lighting Fixture Housing, or an Outlet Box or a Junction Box,* issued July 15, 2025 (’783 Patent)

The Invention Explained

  • Problem Addressed: The patent’s background section describes the inefficiency faced by consumers and electricians who have to purchase different light fixtures for new construction installations, retrofit installations into existing recessed housings, and electrical outlet box installations (Compl. ¶¶38-40; ’783 Patent, col. 1:35-44). This practice increases the inventory that distributors must carry (Compl. ¶42; ’783 Patent, col. 1:45-52).
  • The Patented Solution: The invention is a single lighting fixture apparatus that includes multiple, distinct sets of mounting hardware, allowing it to be installed in at least three different scenarios: with a first set of clips for an existing recessed housing, a second set of clips for new construction where no housing is present, and a third set of mounting attachments for an existing electrical junction box (’783 Patent, col. 2:5-24, Abstract). This versatility is intended to reduce the number of distinct products a distributor needs to stock (’783 Patent, col. 3:6-14).
  • Technical Importance: The claimed multi-scenario capability allows a single stock-keeping unit (SKU) to serve markets that previously required three separate products, reducing inventory costs and complexity for suppliers and installers (Compl. ¶¶43-44).

Key Claims at a Glance

  • The complaint asserts independent claims 1 (apparatus) and 9 (system) (Compl. ¶80).
  • Essential elements of independent claim 1 include:
    • A light source attachable to and detachable from a mounting surface in at least three different scenarios
    • A body to which the light source is attached
    • A plurality of first clips connectable to the body for attaching the light source when an existing recessed lighting fixture housing is available
    • A plurality of second clips, different from the first clips, connectable to the body for attaching the light fixture when a recessed housing is not present
    • One or more mounting attachments connectable to the body for attaching the light fixture when an existing outlet or junction box is present
    • A junction box connectable to the body for containing wiring
  • The complaint states infringement of "each and every claim," thereby reserving the right to assert dependent claims (Compl. ¶77).

U.S. Patent No. 11,054,118 - *Apparatus to Detachably Attach LED Light Fixture to Ceiling or Recessed Lighting Fixture Housing,* issued July 6, 2021 (’118 Patent)

The Invention Explained

  • Problem Addressed: The patent’s background section identifies the need for consumers and electricians to buy different types of LED recessed light fixtures for new construction versus retrofit installations, which requires distributors to carry a larger inventory (’118 Patent, col. 1:20-33).
  • The Patented Solution: The invention is a single LED light fixture apparatus equipped with two distinct types of mounting hardware: a set of "retrofit clips" designed to create a friction fit inside an existing recessed housing, and a set of "new construction clips" held by "connecting posts" designed to squeeze the ceiling material when no housing is present (’118 Patent, Abstract; col. 2:7-10). The key is that the same fixture body can be configured for either application, reducing inventory needs (’118 Patent, col. 2:10-13).
  • Technical Importance: The invention provides a dual-purpose solution that allows a single product to serve both the retrofit and new construction recessed lighting markets, thereby saving warehouse space and reducing costs for distributors (Compl. ¶43; ’118 Patent, col. 2:10-13).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶95).
  • Essential elements of independent claim 1 include:
    • A plurality of retrofit clips adaptable to attach to a body by screwing them into screw holes
    • A plurality of new construction clips
    • A plurality of connecting posts to hold the new construction clips
    • A metal housing embodying the fixture
    • A junction box and a twist connector for wiring
    • The claim specifies that the retrofit clips are used to "make a friction fit inside the recessed lighting fixture housing," while the new construction clips are "attached to the connecting posts if the recessed lighting fixture housing is not present"
  • The complaint reserves the right to assert all claims (Compl. ¶95).

III. The Accused Instrumentality

Product Identification

  • Home Depot SKU#1011028804 (Model: NJ03a4IN3in1-W) and SKU#1011028805 (Model: NJ03a6IN3in1-W), collectively the "Accused Products" (Compl. ¶7).

Functionality and Market Context

  • The Accused Products are marketed as "3-in-1 Universal Installation" integrated LED recessed lights (Compl. ¶79). A screenshot from Defendant's website shows the product name "Commercial Electric 3-in-1 Universal Installation 5/6 in. White Integrated LED Recessed Light" (Compl. p. 11). The complaint alleges that the product instruction manuals describe three distinct installation methods, labeled "A," "B," and "C" (Compl. ¶¶81-82). These methods allegedly include using "Spring Clips" for an existing recessed housing, "spring-loaded clips" for "Canless" installations (i.e., new construction), and "screws and a mounting plate" for an existing junction box (Compl. ¶¶85-87). The products are sold by The Home Depot, which the complaint identifies as the world's largest home improvement retailer (Compl. ¶8).

IV. Analysis of Infringement Allegations

’783 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a light source attachable to, and detachable from, a mounting surface in at least three different scenarios The Accused Products are described in their manuals as "3-in-1 Universal Installation Recessed Light[s]" with three installation methods labeled "A", "B", and "C". ¶¶79-82 col. 13:30-33
a body to which the light source is attached The Accused Products include an LED light source integrated into the fixture body. ¶83 col. 13:34-35
a plurality of first clips connectable to the body for attaching the light source to the mounting surface when...an existing recessed lighting fixture housing is available The manuals allegedly instruct users on "Using Spring Clips" for installation of the Accused Products in an "existing recessed housing". ¶85 col. 13:39-44
a plurality of second clips...connectable to the body for attaching the light fixture...when...a recessed lighting fixture housing is not present The manuals allegedly instruct users to use "spring-loaded clips" during installation of the Accused Products in "Canless" installations. ¶86 col. 13:45-51
one or more mounting attachments connectable to the body for attaching the light fixture...when...an existing outlet box or existing junction box is present The manuals allegedly instruct users to use "screws and a mounting plate" for installation to an existing "junction box of the ceiling." ¶87 col. 13:52-58
a junction box that is connectable to the body The manuals allegedly include diagrams showing a junction box is included with each Accused Product. ¶88 col. 13:61-65

Identified Points of Contention

  • Scope Questions: A central question may be whether the hardware provided with the Accused Product constitutes three distinct structures as recited in the claim (i.e., "first clips," "second clips," and "mounting attachments"). The analysis may focus on whether the "Spring Clips" and "spring-loaded clips" alleged in the complaint are structurally different as required by the claim language "that is different than the plurality of first clips."
  • Technical Questions: The infringement theory relies on the product being a complete kit enabling three installation types. A key factual question will be what specific hardware is included in the box with the Accused Product as sold. The complaint's screenshot from Defendant's Canadian website appears to show the same "3-in-1" product, suggesting continued sales of the allegedly infringing configuration (Compl. p. 13).

’118 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a plurality of retrofit clips (102) adaptable to attach with a body of the LED light fixture by screwing them into a plurality of screw holes (110) The manuals allegedly direct users to use "clips" for installation in an "existing recessed housing". ¶97 col. 6:12-15
a plurality of new construction clips (104) The manuals allegedly direct users to use "spring-loaded clips" for a "canless" installation at a ceiling. ¶98 col. 6:15-16
a plurality of connecting posts (106) to hold the new construction clips (104) The manuals allegedly show each "spring-loaded clip" is attached to an upright piece of metal on the product's enclosure. ¶99 col. 6:16-18
a metal housing (108) to embody a complete fixture (112) The Accused Product is alleged to have a "metal enclosure for the LEDs." ¶99, ¶106 col. 6:18-19
a junction box (116) to hold a plurality of connection wirings... The Accused Products are sold with junction boxes. ¶100 col. 6:19-22
a twist connector (118) to attach the output wires... The Accused Products are sold with wire connectors for attaching wires from the LED driver to input wires. ¶102, ¶104 col. 6:22-25
wherein the retrofit clips (102) make a friction fit inside the recessed lighting fixture housing... This functionality is alleged by the instruction to use the "clips" for installation in an existing recessed housing. ¶97 col. 6:25-29
wherein the new construction clips (104) are attached to the connecting posts (106) if the recessed lighting fixture housing is not present This functionality is alleged by the instruction to use "spring-loaded clips" for a "canless" installation. ¶98 col. 6:29-32

Identified Points of Contention

  • Scope Questions: The definition of "connecting posts" will be significant. The question is whether the "piece of metal that is upright" as alleged in the complaint (Compl. ¶99) meets the structural requirements of the claimed "connecting posts."
  • Technical Questions: Claim 1 requires the "retrofit clips" to be attached "by screwing them into a plurality of screw holes." The complaint's allegations focus on the user instructions for different scenarios (Compl. ¶¶97-98) but do not specify how the clips themselves attach to the fixture body. This potential mismatch between the claim's specific attachment mechanism and the allegations could be a point of dispute.

V. Key Claim Terms for Construction

For the ’783 Patent

  • The Term: "at least three different scenarios"
  • Context and Importance: This phrase is central to the patent's claim of novelty and utility. The scope of "scenarios" will determine whether the accused "3-in-1" product falls within the claims. Practitioners may focus on this term because the infringement allegation hinges on mapping the product's three advertised installation methods to the three distinct scenarios recited in the claims.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The Summary of the Invention and Abstract describe the scenarios functionally as retrofit, new construction, and outlet box installation, suggesting any apparatus capable of these three functions could be covered (’783 Patent, col. 2:5-24).
    • Evidence for a Narrower Interpretation: Claim 1 structurally links each scenario to a different type of hardware: "first clips" for the first scenario, "second clips" for the second, and "mounting attachments" for the third. This may support an interpretation that requires three structurally distinct and separate sets of hardware to be present (’783 Patent, col. 13:30-60).

For the ’118 Patent

  • The Term: "connecting posts"
  • Context and Importance: The complaint alleges infringement of this element by identifying an "upright" piece of metal on the accused product. Whether this structure meets the definition of "connecting posts" is critical to the infringement analysis for the "new construction" configuration.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language is functional: "a plurality of connecting posts (106) to hold the new construction clips (104)" (’118 Patent, col. 6:16-18). This could support an interpretation where any integral or separate structure that performs the function of holding the clips qualifies.
    • Evidence for a Narrower Interpretation: The patent figures, such as Fig. 2a and Fig. 4, depict the "connecting posts" (106) as distinct, discrete structures to which the new construction clips are attached. This could support a narrower definition requiring a separate component distinct from both the main housing and the clips themselves (’118 Patent, col. 3:49-51).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement. The basis for this allegation is that Home Depot provides installation manuals with the Accused Products that allegedly instruct and encourage users to perform the patented methods of installing the fixture in multiple different scenarios (Compl. ¶¶63, 81-87, 97-98).
  • Willful Infringement: Willfulness is alleged based on pre-suit knowledge. For the ’118 Patent, the complaint alleges the inventor made presentations to Home Depot product managers in April and August 2019 regarding the technology while it was the subject of a patent application (Compl. ¶¶46-50). For the ’783 Patent, knowledge is alleged based on a demand letter sent to Home Depot on July 18, 2025 (Compl. ¶66). The complaint also alleges that Home Depot continued selling the products despite knowledge from prior litigation involving the ’118 Patent (Compl. ¶¶61-62).

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

  • A core issue will be one of definitional mapping: Do the hardware components included with the Accused Products—described in the complaint as "Spring Clips," "spring-loaded clips," and an "upright piece of metal"—structurally correspond to the distinct claimed elements of "first clips," "second clips," and "connecting posts" as defined by the patents? The outcome may depend heavily on claim construction.
  • A second central question will be one of kit completeness and capability: As sold, does the single package for the "3-in-1" Accused Product contain all the necessary and structurally distinct hardware to enable a user to perform all three installation scenarios recited in the ’783 Patent? The viability of the infringement allegation rests on the product being a complete, multi-scenario system out of the box.