DCT
3:25-cv-01120
Coast Cutlery Co v. Infinity X1 LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Coast Cutlery Co. dba Coast Products (Oregon)
- Defendant: Infinity X1 LLC (Nevada)
- Plaintiff’s Counsel: Schwabe, Williamson & Wyatt, P.C.
- Case Identification: 3:25-cv-01120, D. Or., 06/27/2025
- Venue Allegations: Plaintiff Coast alleges venue is proper in the District of Oregon because Defendant Infinity purposefully directed activities to Oregon by delivering a complaint to Coast’s registered agent in the state, conducts business in Oregon, and because Coast’s action for declaratory judgment arises from these activities.
- Core Dispute: Plaintiff seeks a declaratory judgment that its headlamp products do not infringe Defendant’s patents and that the patents are invalid, and that it has not engaged in false advertising or unfair business practices.
- Technical Context: The dispute centers on multi-function, wearable headlamps, a product category in the outdoor and recreational gear market that combines multiple light sources to enhance user visibility.
- Key Procedural History: This declaratory judgment action was filed after Defendant Infinity filed a patent infringement and false advertising complaint against Plaintiff Coast in the Central District of California on May 20, 2025. Coast alleges that Infinity’s complaint created an actual controversy between the parties. In its complaint, Coast also alleges that Infinity’s patents are invalid in light of several prior art headlamp products, including the MORF R230, StenLight S7, and Benran Cree 3 T6.
Case Timeline
| Date | Event |
|---|---|
| 2020-05-09 | Priority Date for ’311 and ’618 Patents |
| 2023-12-26 | U.S. Patent No. 11,852,311 Issues |
| 2025-01-21 | U.S. Patent No. 12,203,618 Issues |
| 2025-05-20 | Infinity files underlying complaint in C.D. California |
| 2025-05-23 | Infinity’s complaint delivered to Coast’s registered agent in Oregon |
| 2025-06-27 | Coast files this Complaint for Declaratory Judgment |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,852,311 - "Broad View Headlamp," Issued Dec. 26, 2023
The Invention Explained
- Problem Addressed: The patent describes traditional headlamps as being limited, typically providing only a forward-directed spot or flood beam, which requires a user to move their head to illuminate peripheral areas (’311 Patent, col. 1:32-54). It notes that while some "wide-angle" headlamps exist, they often cast a broad, unfocused light and lack the ability to deactivate specific lights to create different lighting effects or to provide focused, downward-directed lighting (’311 Patent, col. 1:55-68).
- The Patented Solution: The invention is a headlamp with multiple, distinct lighting compartments, each containing light sources (e.g., LEDs) and optical elements like reflectors and lenses (’311 Patent, col. 3:5-18). These compartments are designed to provide a combination of forward, peripheral, and downward-directed light, which can be operated individually or together to create a customized, wide field of illumination claimed to be at least 220 degrees (’311 Patent, Abstract; col. 3:18-26).
- Technical Importance: The technology aims to provide a more comprehensive and adaptable hands-free lighting solution that enhances a user’s total situational awareness beyond what was offered by conventional headlamp designs (’311 Patent, col. 2:4-9).
Key Claims at a Glance
- The complaint generally contests infringement of all valid claims but specifically references language from independent claim 1 (Compl. ¶17-18).
- Independent Claim 1 requires:
- A headlamp with a plurality of light sources, including a first light source and a second light source, each with a diode, lens, and reflector to illuminate a respective view area.
- A "lighting control module configured to selectively activate the plurality of light sources according to a plurality of lighting modes."
- The modes must include at least a first lighting mode that activates both the first and second light sources to create a "total combined view area that is wider than either the first view area or the second view area alone."
- The complaint does not explicitly reserve the right to contest dependent claims, but seeks a declaration of non-infringement for "any claim" of the patent (’311 Patent, cl. 1; Compl. ¶A).
U.S. Patent No. 12,203,618 - "Broad View Headlamp," Issued Jan. 21, 2025
The Invention Explained
- Problem Addressed: The technology addresses the same limitations of conventional headlamps as the ’311 Patent, namely their restricted field of view and inflexible lighting options (’618 Patent, col. 1:35-col. 2:4). This patent adds a focus on power management and user-interface automation.
- The Patented Solution: In addition to the multi-source lighting system described in the ’311 Patent, this invention introduces sensor-based automation (’618 Patent, col. 5:36-40). It claims a headlamp with a motion sensor that can detect a lack of motion and, in response, place the headlamp into a "standby mode" to conserve power. The headlamp can then "wake" and resume its prior lighting mode when motion is detected again (’618 Patent, col. 6:10-24).
- Technical Importance: The technology seeks to make advanced, multi-light headlamps more energy-efficient and user-friendly by automating power-saving functions based on user activity (’618 Patent, col. 6:10-24).
Key Claims at a Glance
- The complaint generally contests infringement of all valid claims but specifically references language related to lighting modes, which is a feature of both patents (Compl. ¶22-23).
- Independent Claim 1 requires:
- A headlamp with a plurality of light sources, a motion sensor, a multifunctional switch, and a lighting control module.
- The lighting control module is configured to select a lighting mode, receive motion sensor data, determine a "lack of motion... for a threshold period," and "initiate a standby mode... based on the lack of motion."
- The complaint seeks a broad declaration of non-infringement for "any claim" of the patent (’618 Patent, cl. 1; Compl. ¶A).
III. The Accused Instrumentality
Product Identification
- The complaint refers generally to "certain Coast headlamp products" and "one or more products" sold by Coast (Compl. ¶2, ¶13).
Functionality and Market Context
- The complaint provides minimal technical detail about the operation of the accused headlamps. Instead, it focuses on denying that the products meet specific claim limitations (Compl. ¶18, ¶23). The complaint includes a photograph of product packaging for a "COAST" brand headlamp. This photograph shows the headlamp with multiple visible light emitters and a prominent "TRY" graphic, suggesting the packaging allows a potential customer to test the product's basic functions at the point of sale (Compl. p. 8, ¶40). Coast alleges it is a long-standing company known for producing reliable outdoor and recreational products (Compl. ¶1).
IV. Analysis of Infringement Allegations
’311 Patent Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement. The table below summarizes Coast's denial with respect to the elements of independent claim 1.
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first light source comprising a first light emitting diode, a first lens, and a first reflector...; and a second light source comprising a second light emitting diode, a second lens, and a second reflector... | The complaint does not provide specific allegations regarding this element, as it seeks a declaration of non-infringement. | N/A | col. 7:25-31 |
| a lighting control module configured to selectively activate the plurality of light sources according to a plurality of lighting modes | Coast alleges its headlamps do not "selectively activate the plurality of light sources according to a plurality of lighting modes." | ¶18 | col. 7:32-35 |
| where the plurality of lighting modes comprises at least a first lighting mode that activates the first light source and the second light source to illuminate the first view area and the second view area to create a total combined view area that is wider than either the first view area or the second view area alone. | The complaint does not provide specific allegations regarding this element beyond the general denial of having "lighting modes." | ¶18 | col. 7:36-42 |
- Identified Points of Contention:
- Technical Question: A central factual question is whether the circuitry in Coast's headlamps performs the function of a "lighting control module" that operates according to a "plurality of lighting modes." The dispute may turn on whether simply switching different LEDs on and off constitutes distinct "modes" as claimed.
- Scope Question: The analysis will raise the question of how broadly the term "plurality of lighting modes" can be interpreted. Does it require pre-programmed, named modes (e.g., "spot," "flood," "peripheral"), as described in the specification, or does it cover any device with a switch that can create different combinations of active lights?
’618 Patent Infringement Allegations
The complaint's denial regarding the ’618 Patent is identical to its denial for the ’311 Patent, focusing on "lighting modes" rather than the sensor-based features central to claim 1 of the ’618 Patent.
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a plurality of light sources...; a motion sensor...; a multifunctional switch; and a lighting control module... | The complaint's denial is general and does not specifically address the presence or absence of a motion sensor. | ¶23 | col. 7:22-28 |
| configured to: select a first mode...; receive motion sensor data...; determine a lack of motion...; and initiate a standby mode... based on the lack of motion. | Coast makes the same general allegation as for the '311 Patent, stating its headlamps do not "selectively activate the plurality of light sources according to a plurality of lighting modes." This allegation does not directly address the claimed functions of motion detection or initiating a standby mode. | ¶23 | col. 7:29-36 |
- Identified Points of Contention:
- Technical Question: A primary factual question is whether the accused Coast headlamps contain a motion sensor and control logic that implements a power-saving standby mode as claimed.
- Evidentiary Question: What evidence does the complaint provide that the accused products lack the claimed motion-sensing functionality? The complaint’s denial is generic and focuses on "lighting modes," which may suggest a potential mismatch between Coast's non-infringement theory and the specific limitations of claim 1 of the ’618 Patent.
V. Key Claim Terms for Construction
The Term: "plurality of lighting modes" (’311 Patent, cl. 1)
Context and Importance: This term is central to the non-infringement allegation for both patents. The definition will determine whether the accused products, which presumably allow a user to turn different lights on or off, are performing the claimed function. Practitioners may focus on this term because its construction could resolve the infringement question for both patents simultaneously.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims themselves do not define "modes" with great specificity, which may support an interpretation where any distinct combination of activated lights constitutes a "mode."
- Evidence for a Narrower Interpretation: The specification provides specific examples of lighting modes, such as a "focused beam, i.e., spot beam," a "broad-beamed, i.e., flood beam," and "night vision lighting," which could support a narrower construction requiring distinct, purpose-driven operational states beyond simple on/off combinations for different LEDs (’311 Patent, col. 4:41-47).
The Term: "standby mode" (’618 Patent, cl. 1)
Context and Importance: This term is the core functional element of the ’618 patent's independent claim. Whether Coast’s products infringe will depend on whether they implement a feature that meets the definition of "standby mode."
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term itself might be argued to encompass any low-power or sleep state initiated to save battery.
- Evidence for a Narrower Interpretation: The specification describes a specific sequence for the standby mode, where the control module is "configured to save current state settings and disable all peripherals" and then resume the prior state upon detecting motion (’618 Patent, col. 6:14-24). This language may support a narrower construction requiring this specific save-and-resume functionality, not just a simple power-off or dim state.
VI. Other Allegations
Indirect Infringement
- Coast seeks a declaratory judgment that it has not contributorily or by inducement infringed any claim, but the complaint provides no specific facts supporting this denial beyond its general assertion of non-infringement (Compl. ¶17, ¶22, ¶A).
Willful Infringement
- The complaint does not provide sufficient detail for analysis of any willfulness allegations that may have been present in the underlying complaint filed by Infinity.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "plurality of lighting modes," which is described in the patent with specific functional examples like spot and flood beams, be construed to cover the accused headlamps, which may only feature basic switching between different light sources?
- A key evidentiary question will be one of technical implementation: for the ’618 Patent, the case will likely turn on whether the accused Coast products physically contain a motion sensor and the associated control logic to implement the claimed "standby mode." Coast's current non-infringement pleading does not specifically address this central feature.
- A parallel dispositive issue will be patent validity: the court will have to determine whether the claims of the ’311 and ’618 patents are valid over the prior art headlamps cited by Coast, which allegedly disclose similar multi-light source configurations that predate the patents.