Shangyou Jiayi Lighting Product Co Ltd v. Partnerships Unincorp Associations

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Shangyou Jiayi Lighting Product Co., Ltd. (China)
  • Defendant: The Partnerships and Unincorporated Associations Identified on Schedule A (Jurisdiction(s) unknown, alleged to operate from China or other foreign jurisdictions)
  • Plaintiff’s Counsel: AVEK IP, LLC
• Case Identification: 4:25-cv-01416, E.D. Tex., 12/19/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendants target U.S. consumers, including those in Texas, through interactive e-commerce websites, accept payment in U.S. currency, and have allegedly sold infringing products to Texas residents.
• Core Dispute: Plaintiff alleges that Defendants’ "Vine Lamp products" infringe a patent related to the structure and construction of decorative light strings designed to resemble vines.
• Technical Context: The technology relates to decorative LED lighting, specifically light strings constructed to be flexible, weather-resistant, and aesthetically similar to natural vines for indoor and outdoor use.
• Key Procedural History: The complaint does not reference prior litigation, administrative patent challenges, or licensing history related to the patent-in-suit. The case is filed against numerous unidentified entities, and the complaint includes arguments justifying their joinder as defendants in a single action.

**Case Timeline**

Date	Event
2014-01-01 (approx.)	Plaintiff began marketing and selling its lighting products in the United States
2015-10-14	’258 Patent Priority Date
2018-09-25	’258 Patent Issue Date
2025-12-19	Complaint Filing Date

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

U.S. Patent No. 10,082,258 - *"Vine lamp and production method thereof"*

The Invention Explained

• Problem Addressed: The patent’s background section describes conventional decorative LED light strings as being bulky due to large lamp bulbs and sockets, having thick wiring, and possessing poor waterproofing, which limits their application, particularly for outdoor use (’258 Patent, col. 1:20-33).
• The Patented Solution: The invention is a "vine lamp" constructed from multiple "light strings." In each string, light-emitting chips are welded directly onto exposed sections of two parallel conducting wires, and this connection is then sealed within a transparent encapsulation layer to form a "lamp bead" (’258 Patent, Abstract). The key structural innovation lies in how the wires are arranged and intertwined. The wire segment between any two lamp beads is divided into three sections. The first and third sections, which are immediately adjacent to the lamp beads, are twisted together. The middle (second) section remains separate, allowing it to be twisted with the middle sections from other light strings to form a thicker, vine-like trunk (’258 Patent, col. 8:56-65; Fig. 7).
• Technical Importance: This design purports to create a more compact, flexible, and weather-resistant light string that can be easily shaped and wound around objects, while allowing multiple strings to be combined into a cohesive, multi-light decorative element (’258 Patent, col. 3:1-7; col. 6:63-65).

Key Claims at a Glance

• The complaint asserts the "sole claim" of the patent, which is independent claim 1 (Compl. ¶30).
• Essential elements of independent claim 1 include:
  • A plurality of light strings, each with light emitting components and two conducting wires.
  • A transparent encapsulation layer wrapped around the light emitting component and exposed wire sections to form a "lamp bead."
  • Each conducting wire between two adjacent lamp beads is divided into a first, second, and third conducting wire section in sequence.
  • The first and third conducting wire sections on both sides of each lamp bead "intersect and are wound with each other and not with the second conducting wire sections."
  • Each of the second conducting wire sections from the plurality of light strings is "wound with one or more other second conducting wire sections of another one of the plurality of light strings."
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are "Vine Lamp products" sold by the Defendants through various online e-commerce stores (Compl. ¶¶3, 4).

Functionality and Market Context

The complaint describes the accused products as decorative lighting designed for indoor and outdoor use (Compl. ¶11). It alleges that all accused products are "substantially identical" to an exemplary product purchased and analyzed by the Plaintiff (Compl. ¶8). The complaint further alleges that the unique patented design is a key feature valued by consumers (Compl. ¶12). To illustrate the patented design allegedly embodied in the accused products, the complaint reproduces Figure 7 from the ’258 Patent (Compl. p. 5). This figure depicts the distinct wire sections, showing how the first (110) and third (112) sections are wound together near the lamp bead, while the second sections (111) remain separate for combination with other strings (Compl. p. 5).

IV. Analysis of Infringement Allegations

The complaint references a claim chart in an exhibit styled "Schedule A-1," which was not provided with the filed complaint (Compl. ¶8). In lieu of a chart, the infringement theory is summarized below.

The complaint’s infringement theory rests on the allegation that the Defendants are making, using, selling, or importing "Vine Lamp products" that practice every element of claim 1 of the ’258 Patent (Compl. ¶¶3, 30). The Plaintiff states it has "purchased each and every one of the Infringing Products offered by Defendants" and that analysis confirmed they were "identical in all material aspects" and infringe the patent (Compl. ¶¶8, 12). The core of the allegation is that the accused products embody the specific, two-tiered wire-winding structure claimed in the patent: a first type of winding of wire sections immediately flanking each light source, and a second type of winding that combines the central wire sections of multiple light strings together to form the main "vine" (Compl. ¶12; ’258 Patent, cl. 1).

• Identified Points of Contention:
  • Scope Questions: A central question for the court may be how to construe the structural limitations of claim 1. For example, the analysis may focus on whether the accused products’ wire configurations meet the specific requirements that the first and third sections are "wound with each other and not with the second conducting wire sections," and that the second sections are separately "wound with" second sections from other strings.
  • Technical Questions: While the complaint alleges the products are "identical," a factual question for discovery will be whether the physical construction of each Defendant’s product literally matches the patent’s claims. The complaint does not provide photographic evidence of an accused product, raising the question of what evidence will be presented to demonstrate that the accused lamps are assembled with the specific three-section wire division and distinct winding patterns required by the claim.

V. Key Claim Terms for Construction

• The Term: "intersect and are wound with each other and not with the second conducting wire sections"

  • Context and Importance: This phrase describes the specific formation of the smaller "stems" that hold the lamp beads, distinguishing them from the main vine trunk. The infringement analysis for every accused product will depend on whether its construction meets this precise structural arrangement. Practitioners may focus on this term because it appears to be a primary point of novelty.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party could argue that "intersect and are wound" does not require a specific number of twists or a formal, machine-made wind, but can encompass any general intertwining of the wires adjacent to the lamp bead that keeps them together.
    • Evidence for a Narrower Interpretation: The patent’s figures, particularly Figure 7, depict a distinct, intentional twisting of sections 110 and 112, separate from the long, untwisted section 111 (’258 Patent, Fig. 7). The specification’s description of the lamp bead being "fully exposed" by this winding may support a narrower construction requiring a structure that achieves that specific functional outcome (’258 Patent, col. 2:21-24).

• The Term: "wound with one or more other second conducting wire sections of another one of the plurality of light strings"

  • Context and Importance: This term defines how the main "vine" is assembled from multiple individual light strings. It is critical for distinguishing the patented structure from a simple bundle of parallel or randomly tangled light strings.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party might argue that "wound with" is a general term that could describe wires that are twisted, bundled, or otherwise run together to form a single larger cable.
    • Evidence for a Narrower Interpretation: The patent repeatedly uses the term "winding" in the context of using a "numerical control filament winder" to produce the lamp, suggesting an intentional and structured intertwining process (’258 Patent, col. 4:1-4, col. 4:46-48). This may support a construction that requires more than incidental bundling.

VI. Other Allegations

• Indirect Infringement: The complaint makes a general allegation of indirect infringement (Compl. ¶29) and requests an injunction against aiding and abetting infringement (Prayer ¶A(2)). However, it does not plead specific facts to support the knowledge and intent elements required for a claim of induced infringement, such as referencing user manuals or advertising that instructs on an infringing use.
• Willful Infringement: The complaint alleges that Defendants' infringement is and has been "willful" and that they have acted "knowingly" (Compl. ¶¶24, 25, 29). The complaint does not specify whether this allegation is based on pre-suit knowledge (e.g., from a cease-and-desist letter) or arises from the act of infringement itself.

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

• A core issue will be one of structural correspondence: does the physical construction of the accused products sold by numerous online vendors precisely meet the dual-winding architecture of Claim 1, which requires a specific winding of wires adjacent to each lamp bead that is structurally distinct from the winding of wires used to combine multiple light strings into a larger "vine"?
• A primary procedural question, which the complaint anticipates, will be proper joinder: are the products sold by the numerous, anonymously-operated defendant storefronts sufficiently identical to be considered the "same accused product" under 35 U.S.C. § 299, or will factual distinctions between products necessitate severing the defendants?
• A key evidentiary question will be one of proof: given the allegation that the defendants are a "swarm of foreign counterfeiters" operating through ephemeral online stores, what evidence can the Plaintiff present to link specific infringing sales to each named defendant entity and demonstrate that the products sold contain the specific internal wire structure claimed by the patent?