DCT

2:25-cv-01204

Xiamen Pvtech Corp Ltd v. Jiaxing Super Lighting Electric Appliance Co Ltd

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-01204, E.D. Tex., 12/10/2025
  • Venue Allegations: Venue is asserted under 28 U.S.C. § 1391(c), which permits a defendant not resident in the United States to be sued in any judicial district.
  • Core Dispute: Plaintiff alleges that Defendant’s LED tube lighting products, sold under various brand names in the U.S., infringe ten patents related to LED lamp construction, safety features, and electrical circuitry.
  • Technical Context: The technology concerns LED tube lighting, which is designed to replace conventional fluorescent tube lighting in commercial and residential fixtures, offering greater energy efficiency and longevity.
  • Key Procedural History: The complaint alleges a history of business disputes, including patent infringement accusations by Defendant against Plaintiff and its customers, Amazon takedown procedures, and failed cross-licensing negotiations. These allegations may be used to support claims of willful infringement. The complaint also notes that one of the patents-in-suit is the subject of a pending reexamination.

Case Timeline

Date Event
2017-07-07 ’474 Patent Priority Date
2017-09-08 ’571 Patent Priority Date
2018-08-17 ’303 Patent Priority Date
2018-12-25 ’571 Patent Issue Date
2019-03-22 ’784 Patent Priority Date
2019-07-09 ’474 Patent Issue Date
2019-10-31 ’352 Patent Priority Date
2019-12-25 ’065 Patent Priority Date
2020-05-05 ’784 Patent Issue Date
2020-06-01 ’671 Patent Priority Date
2020-08-18 ’303 Patent Issue Date
2021-01-19 ’352 Patent Issue Date
2021-01-27 ’150 Patent Priority Date
2021-05-31 ’601 Patent Priority Date
2021-08-03 ’065 Patent Issue Date
2021-09-14 ’671 Patent Issue Date
2021-12-08 ’419 Patent Priority Date
2021-12-28 ’150 Patent Issue Date
2022-08-09 ’601 Patent Issue Date
2022-12-27 ’419 Patent Issue Date
2023-01-01 Super Lighting allegedly initiates APEX process against Plaintiff's customer
2024-10-01 Super Lighting allegedly directly accuses Plaintiff of infringement
2025-05-13 Super Lighting allegedly provides Plaintiff with a draft complaint
2025-05-30 Reexamination of '303 Patent initiated
2025-12-10 Complaint Filing Date

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

U.S. Patent No. 11,209,150 - "Color temperature adjustable lamp socket and color temperature adjustable lamp tube"

Issued December 28, 2021

The Invention Explained

  • Problem Addressed: The patent addresses the lack of adaptability in conventional LED tube lamps, which typically offer only a single, fixed color temperature, leading to inventory management challenges for suppliers and limited options for end-users (Compl. p. 24; ’150 Patent, Abstract).
  • The Patented Solution: The invention provides a lamp tube with a physical "color temperature adjustment member" located on the lamp socket's housing (Compl. p. 24, FIG. 1). This member, such as a slide switch, allows a user to select between different sets of internal light-emitting elements, each corresponding to a different color temperature, thereby changing the light output of the lamp (’150 Patent, Abstract). Figure 4 of the patent shows an embodiment of this adjustable lamp socket (Compl. p. 25).
  • Technical Importance: This approach provides flexibility for both installers and end-users, allowing a single product to meet various lighting needs and reducing the number of distinct product models manufacturers and distributors must stock.

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶45).
  • The complaint incorporates by reference a claim chart (Exhibit 11) that was not provided with the filed document. Therefore, a breakdown of the claim elements cannot be provided.

U.S. Patent No. 11,536,419 - "Lighting device with improved luminous performance"

Issued December 27, 2022

The Invention Explained

  • Problem Addressed: The patent background addresses the challenge of achieving uniform light distribution from LED tube lamps, as variations in circuit design and LED placement can lead to inconsistent brightness or visible "hotspots" (’419 Patent, Abstract).
  • The Patented Solution: The invention proposes a circuit board design with multiple, parallel light paths. Each path is configured in a serpentine or "staggered arrangement" of conductive traces, with light sources distributed across specific portions of these paths (’419 Patent, Abstract). This geometric layout is intended to improve the uniformity of light output across the length of the tube (Compl. p. 27, FIG.).
  • Technical Importance: By creating more uniform luminous performance, the invention aims to improve the aesthetic quality of the light and better replicate the smooth, even light of traditional fluorescent tubes.

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶54).
  • The complaint incorporates by reference a claim chart (Exhibit 12) that was not provided with the filed document. Therefore, a breakdown of the claim elements cannot be provided.

U.S. Patent No. 10,161,571 - "LED tube with safety device"

Issued December 25, 2018

  • Technology Synopsis: The patent describes an LED tube with integrated safety fuses "directly riveted at the conductive needle groups" at the ends of the tube (’571 Patent, Abstract). This configuration is intended to cut current flow and prevent damage or hazards if an unstable voltage or poor electrical contact causes ignition or overheating at the connection point (’571 Patent, Abstract, col. 2:39-54).
  • Asserted Claims: At least claim 1 (Compl. ¶63).
  • Accused Features: The complaint alleges that certain accused lighting products contain the claimed safety device features (Compl. ¶¶ 26, 63).

U.S. Patent No. 10,749,303 - "Lamp device with changeable lamp socket"

Issued August 18, 2020

  • Technology Synopsis: This patent discloses a modular lamp system where adapter covers can be "detachably locked" onto the lamp tube's sockets (’303 Patent, Abstract). This allows a single lamp tube to be fitted with different types of end caps, making it compatible with a wider variety of light fixtures without modification.
  • Asserted Claims: At least claim 1 (Compl. ¶72).
  • Accused Features: The complaint alleges that certain accused lighting products, which are advertised with interchangeable bases, practice the claimed invention (Compl. ¶¶ 26, 72; p. 8). A screenshot from Prolighting.com shows an accused RAB Lighting product advertised with an "Interchangeable Base" (Compl. p. 8).

U.S. Patent No. 10,349,474 - "Lamp tube capable of rectifying and stabilizing voltages"

Issued July 9, 2019

  • Technology Synopsis: The patent describes internal circuitry for an LED lamp tube, including a "polarity conversion module" and a "voltage buck-booster module" (’474 Patent, Abstract). This circuitry is designed to allow the LED tube to operate correctly with different types of external electronic ballasts by rectifying and stabilizing the input voltage (’474 Patent, Abstract).
  • Asserted Claims: At least claim 1 (Compl. ¶81).
  • Accused Features: The complaint alleges that certain accused lighting products contain the claimed voltage-stabilizing circuitry (Compl. ¶¶ 26, 81).

U.S. Patent No. 10,645,784 - "Electric leakage protection electronic rectifier and lamp with electric leakage protection electronic rectifier"

Issued May 5, 2020

  • Technology Synopsis: This patent discloses an electronic rectifier for a lamp that includes a "leakage detecting module" and a "current-limiting control unit" (’784 Patent, Abstract). The circuitry is designed to detect power supply leakage and limit the output current to prevent it from exceeding the lamp's tolerable range, thereby prolonging service life and preventing leakage hazards (’784 Patent, Abstract).
  • Asserted Claims: At least claim 1 (Compl. ¶90).
  • Accused Features: The complaint alleges that certain accused lighting products contain the claimed electric leakage protection features (Compl. ¶¶ 26, 90).

U.S. Patent No. 11,122,671 - "Light tube with anti-electric shock protection function and capable of being supplied with electricity by electrical ballast and alternate-current power supply in working frequency"

Issued September 14, 2021

  • Technology Synopsis: The patent describes circuitry for an LED light tube that allows it to be safely powered by either a direct AC mains supply or an existing electrical ballast (’671 Patent, Abstract). It includes an "anti-electric shock detection control circuit" that uses a "false voltage" generation and reduction mechanism to prevent electric shock during installation (’671 Patent, Abstract).
  • Asserted Claims: At least claim 1 (Compl. ¶99).
  • Accused Features: The complaint alleges that certain accused lighting products contain the claimed anti-electric shock circuitry (Compl. ¶¶ 26, 99).

U.S. Patent No. 10,895,352 - "LED tube capable of being supplied with electricity by electrical ballast and mains supply"

Issued January 19, 2021

  • Technology Synopsis: This patent discloses an LED tube with a "detecting control component" that can recognize whether the input power is from an electrical ballast or a direct mains supply (’352 Patent, Abstract). The circuitry then generates the appropriate DC starting voltage, allowing a single tube to be compatible with both types of power sources (’352 Patent, Abstract).
  • Asserted Claims: At least claim 1 (Compl. ¶108).
  • Accused Features: The complaint alleges that certain accused "Type A/B" lighting products, designed to work with or without a ballast, practice the claimed invention (Compl. ¶¶ 26, 108; p. 14).

U.S. Patent No. 11,408,601 - "Illumination device with couple lamp tubes having temperature and power adjustment functions"

Issued August 9, 2022

  • Technology Synopsis: The patent describes a modular lighting device made of two or more lamp tubes joined by a "coupling assembly" (’601 Patent, Abstract). One tube includes a color temperature adjustment switch, while the other includes a power adjustment terminal, allowing a coupled, elongated lamp to have dual adjustability functions (’601 Patent, Abstract).
  • Asserted Claims: At least claim 1 (Compl. ¶117).
  • Accused Features: The complaint alleges that certain accused lighting products, such as 96-inch (8-foot) lamps sold as two-piece systems, practice the claimed invention (Compl. ¶¶ 26, 117; p. 12). A screenshot from Prolighting.com shows an accused "Keystone 96" 2 Piece T8 LED Lamp" (Compl. p. 12).

U.S. Patent No. 11,083,065 - "Driving circuit device for anti-leakage led tube with dual-end input"

Issued August 3, 2021

  • Technology Synopsis: This patent describes a driving circuit for a dual-end input LED tube featuring an "anti-leakage detection module" (’065 Patent, Abstract). The module detects the current state and controls the output to ensure a loop current does not exceed a rated standard, thereby preventing electrical leakage hazards (’065 Patent, Abstract).
  • Asserted Claims: At least claim 1 (Compl. ¶126).
  • Accused Features: The complaint alleges that certain accused lighting products contain the claimed anti-leakage driving circuit (Compl. ¶¶ 26, 126).

III. The Accused Instrumentality

Product Identification

The complaint accuses a wide range of LED tube lighting products that Defendant Super Lighting allegedly manufactures and supplies to U.S. distributors, who then sell them under various brand names (Compl. ¶¶ 18, 20). These brands include, but are not limited to, RAB Lighting, PLT Solutions, Keystone Technologies, Light Efficient Design, and Green Creative (Compl. ¶¶ 21-25).

Functionality and Market Context

The accused products are LED tube lamps intended as replacements for fluorescent tubes (Compl. ¶1). Key functionalities highlighted in the complaint through product marketing materials include adjustable color temperature (CCT Selectable), adjustable wattage, compatibility with or without an existing ballast (Type A/B or "Ballast Bypass"), and interchangeable end caps (Compl. pp. 8, 11, 14). The complaint alleges that Defendant is the original manufacturer of these products by citing identical technical specifications found in the DesignLights Consortium (DLC) Qualified Products List for products registered to Defendant and the branded distributors (Compl. ¶¶ 19-20). The complaint includes a screenshot of a map showing distributors for RAB Lighting products in the judicial district, indicating their availability for sale (Compl. p. 7).

IV. Analysis of Infringement Allegations

The complaint incorporates by reference claim chart exhibits (Exhibits 11-20) that were not provided with the filed document. The following analysis is based on the narrative infringement allegations in the complaint and the technology described in the patents-in-suit.

  • ’150 Patent Infringement Allegations (Narrative Summary)
    • The complaint alleges that the accused products infringe the ’150 Patent because they include a physical switch or similar mechanism allowing users to adjust the lamp's color temperature (Compl. ¶45). This corresponds to the patent's "color temperature adjustment member." For instance, a screenshot of an accused PLT Solutions product from 1000Bulbs.com shows a tube with markings for five selectable color temperatures (3000K to 6500K) corresponding to a switch on the tube's end cap (Compl. p. 11).
  • ’419 Patent Infringement Allegations (Narrative Summary)
    • The infringement theory for the ’419 Patent is based on the internal circuit construction of the accused products (Compl. ¶54). The complaint alleges, on information and belief, that these products contain the patented "staggered arrangement" of light paths and sources to achieve uniform luminous performance. This allegation is not supported by visual evidence of the products' internal components in the complaint.
  • Identified Points of Contention:
    • Evidentiary Questions: For patents concerning internal circuitry (e.g., ’419, ’474, ’784, ’671, ’352, ’065), a central issue will be whether Plaintiff can produce evidence, such as through product teardowns or discovery, demonstrating that the accused products actually contain the claimed circuit layouts and components. The complaint currently relies on "information and belief" for these allegations (Compl. ¶¶ 54, 81, 90).
    • Scope Questions: For patents concerning external features (e.g., ’150, ’303, ’601), disputes may arise over claim scope. For example, regarding the ’150 Patent, a question is whether the claim term "color temperature adjustment member" is broad enough to read on the various types of CCT selection switches used in the accused products, or if it is limited to a specific structure disclosed in the patent.

V. Key Claim Terms for Construction

  • For the ’150 Patent:

    • The Term: "color temperature adjustment member"
    • Context and Importance: This term appears to be the central novel element of the asserted independent claim. Its construction will determine whether the variety of switches and buttons on the accused products fall within the scope of the patent. Practitioners may focus on this term because the accused products are explicitly marketed as "Color Selectable" (Compl. p. 11).
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent’s abstract describes the element functionally as being "provided for switching the light emitting members to change the color temperature of a light" (’150 Patent, Abstract). This functional language may support a construction that covers any mechanism performing that function.
      • Evidence for a Narrower Interpretation: The patent’s Figure 4 shows a specific physical embodiment of the member as a slide switch (21) on the lamp socket (Compl. p. 25). A defendant may argue that the term should be limited to this or structurally similar switches.

  • For the ’419 Patent:

    • The Term: "staggered arrangement"
    • Context and Importance: This term describes the novel geometric layout of the circuit paths, which is the basis for the "improved luminous performance." The infringement analysis will depend entirely on whether the internal layout of the accused products meets this structural definition.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The abstract describes the arrangement functionally, stating that bending portions "protrude from one side and the other side of a first reference line respectively" (’419 Patent, Abstract). This may support a broad definition covering various serpentine or wave-like circuit patterns.
      • Evidence for a Narrower Interpretation: The specific pattern depicted in the patent's figure, showing a particular repeating geometry, could be used to argue for a narrower construction limited to layouts that are the same as or very similar to the depicted embodiment (Compl. p. 27, FIG.).

VI. Other Allegations

  • Indirect Infringement: For each patent-in-suit, the complaint alleges induced infringement under 35 U.S.C. § 271(b) (e.g., Compl. ¶¶ 44, 53). The allegations are based on the assertion that Defendant, knowing its products infringe, sells them to distributors who in turn sell them to end-users with instructions (e.g., product manuals and marketing materials) that encourage infringing use.
  • Willful Infringement: The complaint alleges that Defendant’s infringement has been willful, seeking enhanced damages under 35 U.S.C. § 284 (e.g., Compl. ¶¶ 47, 49). The basis for this allegation is Defendant's alleged pre-suit knowledge of its infringement, stemming from a history of direct accusations and licensing discussions between the parties prior to the lawsuit's filing (Compl. ¶¶ 35-39).

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

  • A foundational factual question will be one of sourcing and identity: can Plaintiff definitively prove that Defendant, Super Lighting, is the original manufacturer for the array of accused products sold under third-party brand names like RAB Lighting and Keystone Technologies? The complaint’s reliance on the DesignLights Consortium database provides a starting point, but the ultimate resolution of this issue will be critical.
  • A key evidentiary question will be one of internal structure: for the majority of the asserted patents, which claim specific internal circuit layouts and safety components, does the Plaintiff possess or can it obtain evidence to show that the accused products actually practice these claimed internal features? The complaint’s current allegations are based on "information and belief" and may require significant discovery and expert analysis to substantiate.
  • A core legal issue will be one of definitional scope: can terms like "color temperature adjustment member" ('150 Patent) and "staggered arrangement" ('419 Patent) be construed broadly enough to cover the diverse implementations found in the accused products, or will they be limited to the specific embodiments illustrated in the patents? The outcome of claim construction will likely be determinative for several of the infringement counts.