DCT
3:25-cv-01281
Infinity X1 LLC v. Coast Cutlery Co
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Infinity X1 LLC (Nevada)
- Defendant: COAST CUTLERY CO. dba COAST PRODUCTS (Oregon)
- Plaintiff’s Counsel: Jeffer Mangels Butler & Mitchell LLP
- Case Identification: 3:25-cv-01281, C.D. Cal., 05/20/2025
- Venue Allegations: Plaintiff alleges venue is proper based on Defendant’s sales of infringing products within the district, the presence of customers in the district, and harm suffered by Plaintiff within the district.
- Core Dispute: Plaintiff alleges that Defendant’s rechargeable headlamp infringes patents related to multi-source, multi-mode headlamp technology, and further alleges that Defendant falsely advertises a specific lighting capability that the accused product does not possess.
- Technical Context: The dispute is in the field of personal illumination devices, where headlamps with multiple LEDs and versatile lighting modes are marketed for consumer, outdoor, and professional use.
- Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history involving the patents-in-suit. The asserted patents share a common priority application and specification, with U.S. Patent No. 12,203,618 being a continuation of the application that issued as U.S. Patent No. 11,852,311.
Case Timeline
| Date | Event |
|---|---|
| 2020-05-09 | Priority Date for ’311 and ’618 Patents |
| 2023-12-26 | U.S. Patent No. 11,852,311 Issued |
| 2025-01-21 | U.S. Patent No. 12,203,618 Issued |
| 2025-05-20 | Complaint Filed |
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's background describes limitations of conventional headlamps, which typically provide only forward-facing spot or flood beams, requiring the user to move their head to illuminate peripheral areas. It also notes that existing wide-angle headlamps often lack the ability to provide focused, directed light or to combine different lighting effects (’311 Patent, col. 1:33-2:4).
- The Patented Solution: The invention is a headlamp with multiple light sources housed in separate compartments, including forward-directed and peripheral lights. A lighting control module allows these distinct light sources to be activated individually or in combination, creating a total illuminated view area that can extend to at least 220 degrees, covering the user's far peripheral vision (’311 Patent, Abstract; col. 3:5-24).
- Technical Importance: This design aims to offer a single, hands-free device capable of providing comprehensive illumination that is adaptable to various environments without requiring constant head repositioning (’311 Patent, col. 2:5-11).
Key Claims at a Glance
- The complaint asserts independent claim 1 and dependent claims 6 and 7 (Compl. ¶45).
- Independent Claim 1 requires:
- A plurality of light sources, including a first light source and a second light source configured to illuminate first and second view areas, respectively.
- A lighting control module to selectively activate the light sources according to multiple lighting modes.
- At least one 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."
U.S. Patent No. 12,203,618 - “BROAD VIEW HEADLAMP” (Issued Jan. 21, 2025)
The Invention Explained
- Problem Addressed: The patent identifies the same problem as its parent ’311 Patent: the limited field of view and lack of lighting versatility in traditional headlamps (’618 Patent, col. 1:33-2:4).
- The Patented Solution: The invention is structurally and functionally similar to that described in the ’311 Patent, featuring a headlamp with multiple, independently controllable light sources to provide wide and versatile illumination. The claims of the ’618 patent specify combinations of particular light types, such as a focused spot beam, a broad-beamed flood beam, and a night vision light source (’618 Patent, col. 8:35-47).
- Technical Importance: The technology provides a framework for a single headlamp to replace multiple specialized lighting tools by integrating different beam types (e.g., spot, flood, peripheral) that can be combined for specific tasks (’618 Patent, col. 2:5-11).
Key Claims at a Glance
- The complaint asserts independent claim 11 and dependent claims 12 and 13 (Compl. ¶60).
- Independent Claim 11 requires:
- A first light source and a second light source configured to illuminate first and second view areas in fixed directions.
- A lighting control module to selectively activate the light sources.
- A first lighting mode that activates both sources to create a "total combined view area that is wider than either the first view area or the second view area alone."
III. The Accused Instrumentality
Product Identification
- The Coast CH1000R Rechargeable Headlamp (Itm./Art. No. 1806407) (Compl. ¶23).
Functionality and Market Context
- The complaint alleges the Coast CH1000R is a multi-light, multi-mode headlamp featuring a spot light mode, a flood light mode, a wide angle mode using lights on the side of the headlamp, and a red light mode (Compl. ¶21). The complaint includes a photograph of the accused product identifying a "Spot light source" and a "Flood light source" as two distinct forward-directed emitters (Compl. ¶64).
- Plaintiff alleges that it and Defendant are direct competitors who both sell their respective headlamp products through Costco retail stores (Compl. ¶¶19, 22, 32).
IV. Analysis of Infringement Allegations
’311 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a plurality of light sources, comprising: a first light source... and a second light source... | The accused headlamp includes at least two distinct light sources, identified in a photograph as "First light source" and "Second light source." | ¶46 | col. 3:5-8 |
| a lighting control module configured to selectively activate the plurality of light sources according to a plurality of lighting modes | The accused headlamp includes a lighting control module that allows a user to select different lighting modes. | ¶47 | col. 4:40-44 |
| 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 create a total combined view area that is wider than either the first view area or the second view area alone | The accused headlamp allegedly includes a lighting mode that activates both the first and second light sources simultaneously to illuminate a combined area wider than either source provides individually. | ¶48 | col. 3:40-50 |
- Identified Points of Contention:
- Factual Question: The complaint contains a potential tension between its infringement allegations and its false advertising allegations. The infringement count alleges the accused device has a mode that combines two light sources to create a wider beam (Compl. ¶48). The false advertising count, however, alleges that the device cannot simultaneously engage its wide-angle side lights with its forward-facing spot/flood lights (Compl. ¶26). A central question will be whether the accused device enables any combination of its light sources (e.g., spot plus flood) that meets the "wider combined view area" limitation, even if a different combination (e.g., peripheral plus forward) is not possible.
’618 Patent Infringement Allegations
| Claim Element (from Independent Claim 11) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first light source configured to illuminate a first view area... and a second light source configured to illuminate a second view area... | The accused headlamp includes two forward-directed light sources, identified in a photograph as a "Spot light source" and a "Flood light source." | ¶61, ¶64 | col. 7:18-24 |
| a lighting control module configured to selectively activate the first light source and the second light source according to a plurality of lighting modes | The accused headlamp is alleged to possess a lighting control module for activating its light sources in various modes. | ¶62 | col. 4:40-44 |
| the plurality of lighting modes comprises a first lighting mode that activates the first light source and the second light source... to create a total combined view area that is wider than either the first view area or the second view area alone | The complaint alleges the device has a mode that activates both the spot and flood sources to create a total view area wider than either source alone. An image from the product packaging is presented as suggesting this capability (Compl. p. 6). | ¶63 | col. 7:25-33 |
- Identified Points of Contention:
- Scope Question: As independent claim 11 of the ’618 patent is substantively identical to claim 1 of the ’311 patent, the same factual question regarding the device's actual operational capabilities applies. The analysis for the asserted dependent claims (12 and 13), which add requirements for specific spot/flood and night vision modes, will depend on evidence of the accused product's full feature set.
V. Key Claim Terms for Construction
The Term: "a total combined view area that is wider than either the first view area or the second view area alone"
- Context and Importance: This limitation is the functional core of both asserted independent claims. The infringement dispute for both patents may hinge on whether the accused product's operation meets this requirement and how the term "wider" is construed.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The plain language does not specify a required degree of widening. Plaintiff may argue that any measurable increase in the width of the illuminated area when two sources are combined satisfies the claim. The specification's goal of illuminating a "total view area... of at least 220 degrees" could support an interpretation that focuses on the expansive result of combining lights (’311 Patent, col. 3:21-24).
- Evidence for a Narrower Interpretation: Defendant may argue that, in the context of the patent's stated purpose of overcoming the limitations of narrow beams, the term "wider" implies a functionally significant and perceptible increase in the field of view, not a trivial overlap of two similar beams.
The Term: "light source"
- Context and Importance: The claims require a "plurality" of light sources. The complaint identifies two physically separate LED and reflector assemblies on the accused product as distinct sources (Compl. ¶46). Practitioners may focus on this term if the accused product's internal construction could be argued to constitute a single, integrated lighting system rather than multiple discrete "sources."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes a housing with "multiple lighting compartments," with each compartment housing "one or more light source[s]," suggesting that physically separate emitters or assemblies constitute distinct sources (’311 Patent, col. 3:5-8).
- Evidence for a Narrower Interpretation: A party could argue that a "light source" refers to the fundamental emitter (e.g., an LED die) and that multiple emitters on a single board or within a single optical assembly might be construed as a single source.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement. Inducement is based on allegations that Defendant markets and promotes the infringing use of the device (Compl. ¶¶51, 66). Contributory infringement is based on allegations that the accused headlamp is a material component of the patented invention, is not a staple article of commerce, and is especially made for an infringing use (Compl. ¶¶52, 67).
- Willful Infringement: Plaintiff alleges on information and belief that Defendant "knew of the... Patent, or should have known," and continued its accused activities, thereby constituting willful infringement warranting enhanced damages (Compl. ¶¶57, 72).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central evidentiary question will be one of operational fact: does the accused Coast CH1000R headlamp actually feature a mode that combines two of its light sources (such as spot and flood) to produce a beam that is demonstrably "wider" than either source provides alone? The resolution of this technical question appears to be dispositive for the infringement claims.
- The case presents a core issue of pleading consistency: how will the Plaintiff reconcile its allegation that the accused product infringes by enabling a "wider combined view area" mode with its parallel claim that Defendant falsely advertises a simultaneous-use functionality that the product allegedly lacks? The defense may leverage this apparent tension to challenge one or both theories of liability.
- A key legal question will be one of claim scope: can the phrase "wider than either... alone," in the context of a patent focused on achieving broad peripheral vision, be met by any marginal increase in beam width from combining two forward-facing lights, or does it require a more substantial expansion of the illuminated field?