DCT

2:25-cv-01045

Lombard v. Lumen Labs HK Ltd

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-01045, E.D. Tex., 10/17/2025
  • Venue Allegations: Venue is alleged to be proper because the Defendant is a foreign entity not resident in the United States.
  • Core Dispute: Plaintiff alleges that Defendant’s line of lighted bicycle helmets infringes seven U.S. patents related to integrated and attachable helmet lighting systems.
  • Technical Context: The technology involves lighting systems for personal safety helmets, a field driven by the need to enhance user visibility and safety, particularly for cyclists and users of personal mobility devices.
  • Key Procedural History: The complaint alleges that Plaintiff provided Defendant with written notice of infringement on multiple occasions, beginning on June 1, 2022, which may be relevant to allegations of willful infringement.

Case Timeline

Date Event
2006-10-03 Earliest Priority Date for '333, '336, '261, '045, '444 Patents
2013-12-17 U.S. Patent No. 8,608,333 Issues
2015-06-09 Earliest Priority Date for '864 and '387 Patents
2018-07-24 U.S. Patent No. 10,030,864 Issues
2018-08-07 U.S. Patent No. 10,039,336 Issues
2022-04-05 U.S. Patent No. 11,291,261 Issues
2022-06-01 Plaintiff sends first written notice letter to Defendant
2022-07-08 Plaintiff sends second written notice letter to Defendant
2023-08-08 U.S. Patent No. 11,717,045 Issues
2024-01-09 U.S. Patent No. 11,867,387 Issues
2024-03-20 Plaintiff sends third written notice letter to Defendant
2025-05-27 U.S. Patent No. 12,310,444 Issues
2025-10-17 Complaint Filed

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

U.S. Patent No. 8,608,333 - Helmet Lighting System

The Invention Explained

  • Problem Addressed: Existing helmet lighting systems are described as generally being for recreational use and not sufficiently integrated or durable for more demanding environments (U.S. Patent No. 10,039,336, col. 1:11-17).
  • The Patented Solution: The invention, as detailed in related patents within the same family, is a helmet with an integrated lighting system. It comprises a "first layer" (such as the helmet's structural shell) and a "second layer" fixedly attached to it. This construction creates a sealed area between the layers that encapsulates the light-emitting means, controller, and wiring, protecting them from the elements ('336 Patent, Abstract; Fig. 3).
  • Technical Importance: This layered construction method provides a means to create a waterproof, durable, and fully integrated lighting system within the helmet structure itself, moving beyond simple external attachments ('336 Patent, col. 4:1-4).

Key Claims at a Glance

  • The complaint asserts infringement of independent claim 1 (Compl. ¶14). While the claim language is not reproduced in the complaint, related patents in the same family describe the core invention as a system comprising:
    • A first layer
    • Light emitting means mounted to the first layer
    • Controller means for the light emitting means
    • Wiring means linking the components
    • A second layer fixably attached to the first layer, providing an area between the layers for the components
    • Power means attached to the second layer
    • Operating means linked to the controller

U.S. Patent No. 10,039,336 - Helmet Lighting System

The Invention Explained

  • Problem Addressed: The patent background notes that existing lighting systems are not always suitable for demanding environments like water or fire, can be heavy or bulky, and may have short operational times ('864 Patent, col. 1:11-18).
  • The Patented Solution: The '336 Patent describes a helmet lighting system integrated into the helmet structure. The system features a first layer (e.g., a helmet shell), light sources, a controller, and wiring. A second layer is attached to the first, creating a protected space between the two layers that houses the electronic components, thereby shielding them from environmental exposure ('336 Patent, Abstract; col. 2:48-63).
  • Technical Importance: The invention provides a method for integrating electronic lighting components directly into the structure of a helmet in a manner that is durable and waterproof ('336 Patent, col. 4:1-4).

Key Claims at a Glance

  • The complaint asserts infringement of independent claim 1 (Compl. ¶27).
  • The essential elements of independent claim 1 include:
    • A helmet including a lighting system integrated into said helmet
    • a first layer
    • light emitting means mounted to said first layer
    • controller means mounted to said first layer for controlling said light emitting means
    • wiring means for linking said light emitting means to said controller means
    • a second layer fixably attached to said first layer thereby providing an area between said first and second layer for said components
    • power means fixably attached to said second layer for powering said components
    • operating means functionally linked to said controller means for operating said controller means
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 11,291,261 - Helmet Lighting System

Technology Synopsis

Belonging to the same family as the '333 and '336 patents, this patent discloses a helmet with an integrated lighting system featuring a layered construction. A first layer (shell) and a second layer create an encapsulated space to house and protect the electronic components, such as LEDs and controllers ('261 Patent, Abstract).

Asserted Claims

The complaint asserts infringement of independent claim 9 (Compl. ¶40).

Accused Features

The Lumos Kickstart, Lumos Ultra, Lumos Ultra E-Bike, and Lumos Nyxel products are accused of infringement (Compl. ¶40, ¶43-45).

U.S. Patent No. 11,717,045 - Helmet Lighting System

Technology Synopsis

As a member of the '333 patent family, this patent covers a helmet with a built-in lighting system. The core technology involves a multi-layer structure where a space between a first and second layer is used to house and protect the lighting electronics from the environment ('045 Patent, Abstract).

Asserted Claims

The complaint asserts infringement of independent claim 1 (Compl. ¶54).

Accused Features

The Lumos Kickstart, Lumos Ultra, Lumos Ultra E-Bike, and Lumos Nyxel products are accused of infringement (Compl. ¶54, ¶57-59).

U.S. Patent No. 12,310,444 - Helmet Lighting System

Technology Synopsis

This patent, also in the '333 family, describes a helmet with an integrated lighting system. The invention is characterized by its layered construction, which creates a protective, waterproof cavity between a first and second layer for the system's electronic components ('444 Patent, Abstract).

Asserted Claims

The complaint asserts infringement of independent claim 1 (Compl. ¶68).

Accused Features

The Lumos Ultra, Lumos Ultra E-Bike, and Lumos Nyxel products are accused of infringement (Compl. ¶68-70).

U.S. Patent No. 10,030,864 - Helmets with Lighting and Lighting Systems for Helmets

Technology Synopsis

This patent addresses the need for robust lighting on helmets for demanding environments ('864 Patent, col. 1:28-32). The patented solution is a lighting system comprising encapsulated, waterproof light "pods" and/or "strips" that are configured to be attached to an underlying helmet, offering a modular or aftermarket approach ('864 Patent, Abstract; col. 2:32-44).

Asserted Claims

The complaint asserts infringement of independent claim 1 (Compl. ¶79).

Accused Features

The Lumos Ultra and Lumos Ultra E-Bike products are accused of infringement (Compl. ¶79-80).

U.S. Patent No. 11,867,387 - Helmets with Lighting and Lighting Systems for Helmets

Technology Synopsis

Continuing the technology of the '864 patent, this patent discloses lighting systems for helmets composed of discrete, encapsulated lighting modules (pods or strips). These modules are designed to be waterproof and attachable to an underlying helmet shell ('387 Patent, Abstract).

Asserted Claims

The complaint asserts infringement of independent claim 6 (Compl. ¶89).

Accused Features

The Lumos Ultra, Lumos Ultra E-Bike, and Lumos Nyxel products are accused of infringement (Compl. ¶89-91).

III. The Accused Instrumentality

Product Identification

The accused products are the Lumos Kickstart, Lumos Ultra, Lumos Ultra E-Bike, and Lumos Nyxel models of lighted helmets (Compl. ¶6).

Functionality and Market Context

The complaint alleges these are helmets incorporating lighting systems offered for sale and sold in the United States through Defendant's interactive website and online marketplaces such as Amazon.com (Compl. ¶6, ¶9). The complaint further alleges that Defendant instructs customers to use these products when riding bicycles or e-bikes, indicating their primary market is personal mobility and cyclist safety (Compl. ¶15, ¶19).

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references, but does not include, claim chart exhibits that allegedly map elements of the asserted claims to the accused products. The following summarizes the infringement allegations as presented in the body of the complaint.

  • '333 Patent Infringement Allegations
    The complaint alleges that the Lumos Kickstart, Lumos Ultra, and Lumos Ultra E-Bike products directly infringe one or more claims of the '333 Patent, including at least claim 1 (Compl. ¶14, ¶17-18). The complaint incorporates by reference Exhibits 1, 2, and 3 as providing "exemplary, non-limiting demonstration[s]" of this infringement, but does not provide specific element-by-element details in its narrative text (Compl. ¶14, ¶17-18). The core of the infringement theory appears to be that the construction and operation of these accused helmets embody the patented integrated lighting system.

  • '336 Patent Infringement Allegations
    Similarly, the complaint alleges that the Lumos Kickstart, Lumos Ultra, and Lumos Ultra E-Bike products directly infringe one or more claims of the '336 Patent, including at least claim 1 (Compl. ¶27, ¶30-31). The complaint references Exhibits 4, 5, and 6 as demonstrating how these products infringe, but the narrative portion of the complaint does not contain a detailed breakdown of the infringement theory on a limitation-by-limitation basis (Compl. ¶27, ¶30-31). The allegation rests on the contention that the accused products contain the claimed integrated, layered helmet lighting system.

  • Identified Points of Contention:

    • Structural Questions: A central question for the '333 patent family ('333, '336, '261, '045, '444 patents) will be one of structural correspondence. The court may need to determine if the manufacturing process and physical construction of the accused helmets meet the specific claim limitations of a "first layer" and a "second layer fixably attached" to create an "area between" that encapsulates the lighting components.
    • Scope Questions: For the '864 patent family ('864 and '387 patents), which claim systems of attachable "pods" and "strips," a question of scope may arise. The analysis may explore whether claims directed to a lighting system configured for attachment can read on products sold as fully pre-assembled, integrated helmets.

V. Key Claim Terms for Construction

  • The Term: "a second layer fixably attached to said first layer thereby providing an area between said first and second layer" (from claim 1 of the '336 Patent)
  • Context and Importance: This phrase defines the core structural relationship that creates the encapsulated, protected space for the electronic components. The outcome of the infringement analysis for the '333 patent family will likely depend heavily on how "fixably attached" and the resulting "area between" are construed and applied to the physical structure of the accused helmets.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification of the related '261 Patent describes sealing the perimeter of the inner and outer shells with a urethane adhesive (U.S. Patent No. 11,291,261, col. 11:6-12; col. 12:5-9). This may support an interpretation where "fixably attached" is not limited to a specific mechanical or thermal bonding process but can include chemical bonding with a sealant.
    • Evidence for a Narrower Interpretation: The detailed description in the related '261 Patent describes a manufacturing process involving the vacuum forming of a distinct "outer shell" and a separate "inside shell" (U.S. Patent No. 11,291,261, col. 10:12-34; col. 11:20-25). This may support a narrower construction requiring two discrete, shell-like layers, as opposed to, for example, potting electronics onto a single shell and covering them with an epoxy layer.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement across all asserted patents. The basis for this allegation is that Defendant provides webpages and presumably other materials that instruct customers on how to use the accused products in an infringing manner (e.g., "instructing its customers to use the products when riding bicycles") (Compl. ¶15, ¶28, ¶41, ¶55, ¶71, ¶81, ¶92).
  • Willful Infringement: The complaint alleges willful infringement based on pre-suit knowledge. It states that Plaintiff provided Defendant with written notice of the '333, '336, and '261 patents as early as June 1, 2022, and sent subsequent notices regarding other patents-in-suit (Compl. ¶10, ¶15-16). The complaint also alleges ongoing infringement after the filing of the complaint as a basis for willfulness (Compl. ¶19, ¶32, ¶46).

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

  • A core issue will be one of structural correspondence: Do the accused Lumos helmets, which are sold as integrated products, embody the specific two-layer, encapsulated structure ("first layer," "second layer," "area between") claimed across the '333 patent family, or is there a fundamental difference in their construction?
  • A secondary issue will be one of definitional scope: Can the claims of the '864 patent family, which describe a lighting system of attachable "pods" and "strips," be construed to cover fully integrated helmets sold as a single unit, or are those claims limited in scope to aftermarket or modular kits?
  • A key evidentiary question will be one of knowledge and intent: What evidence will be presented to establish that Defendant had the requisite knowledge of the patents and intent to induce infringement, particularly in light of the pre-suit notice letters alleged in the complaint?