DCT
6:25-cv-00274
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 (jurisdictions unspecified)
- Plaintiff’s Counsel: AVEK IP, LLC
- Case Identification: 6:25-cv-00274, W.D. Tex., 07/03/2025
- Venue Allegations: Venue is alleged to be proper because Defendants target and conduct business with consumers in the United States, including Texas, through interactive e-commerce stores.
- Core Dispute: Plaintiff alleges that Defendants’ "Vine Lamp" decorative lighting products infringe a patent related to a specific method of constructing and winding the wires of a light string.
- Technical Context: The technology concerns decorative lighting products, specifically flexible light strings designed to emulate the appearance of a vine for aesthetic and holiday decoration.
- Key Procedural History: The complaint identifies the defendants as a "swarm of foreign counterfeiters" operating through various online stores, and asserts that joinder is proper under 35 U.S.C. § 299 because the accused products are the same in all respects relevant to the patent. The patent was assigned to the Plaintiff prior to the filing of the suit.
Case Timeline
| Date | Event |
|---|---|
| 2015-10-14 | ’258 Patent Priority Date |
| 2018-08-01 | ’258 Patent assigned to Plaintiff |
| 2018-09-25 | ’258 Patent Issue Date |
| 2025-07-03 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,082,258 - Vine lamp and production method thereof
- Issued: September 25, 2018.
The Invention Explained
- Problem Addressed: The patent’s background section identifies issues with traditional LED light strings, noting they are often large in volume with relatively thick conducting wires, making them difficult to package and install, and have poor waterproof properties unsuitable 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 components are welded directly onto two parallel wires. A key aspect of the design is how the wire between each light is structured: it is divided into a first, second, and third section. The first and third sections, which flank the light bead, are twisted together. The central "second" sections from multiple light strings are then twisted with each other to form the main "vine" structure. This construction is intended to reduce bulk, increase flexibility, and better expose the light beads (’258 Patent, Abstract; col. 1:61-col. 2:4; FIG. 7).
- Technical Importance: This design aimed to produce a light string that was more waterproof, wear-resistant, and lighter, thereby expanding its use for outdoor decoration and making it more convenient for fixation and installation (’258 Patent, col. 2:5-18).
Key Claims at a Glance
- The complaint asserts the "sole claim" of the patent, which is understood to be the single independent apparatus claim, Claim 1 (Compl. ¶30).
- The 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 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 the sides of each lamp bead are wound with each other, but not with the second conducting wire sections.
- Each second conducting wire section is wound with one or more other second conducting wire sections from another light string.
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are "Vine Lamp products" sold by the Defendants through various e-commerce stores (Compl. ¶3).
Functionality and Market Context
The complaint alleges these are decorative lighting products for indoor and outdoor use (Compl. ¶11). The central allegation of infringement is based on the specific physical construction of the products' wiring. The complaint alleges the accused products solve the "bloated size" issue of traditional lamps by employing the patented design (Compl. ¶12). To illustrate this, the complaint reproduces Figure 7 from the patent, which depicts the claimed arrangement of first (110), second (111), and third (112) conducting wire sections (Compl. ¶12, p. 5). This figure is used to assert that the accused products embody the claimed wire configuration.
IV. Analysis of Infringement Allegations
The complaint does not contain a formal claim chart exhibit but makes narrative infringement allegations by referencing the structure depicted in the patent's figures.
’258 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| wherein each conducting wire between two adjacent light beads is divided into a first conducting wire section, a second conducting wire section and a third conducting wire section in sequence | The accused Vine Lamp products are constructed with distinct wire sections between the lights. | ¶12 | col. 1:61-65 |
| wherein the first conducting wire section and the third conducting wire section on both sides of each lamp bead intersect and are wound with each other and not with the second conducting wire sections | The accused products feature a construction where "a first conducting wire section 110 and a third conducting wire section 112 intersect and are would with each other and not with second conducting wire sections 111." | ¶12 | col. 9:1-4 |
| and wherein each of the second conducting wire sections of 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 | In the accused products, "each of the second conducting wire sections 111 is wound with one or more other second conducting wire sections 111." | ¶12 | col. 9:5-8 |
Identified Points of Contention
- Technical Question: A central factual question is whether the accused products physically embody the specific tripartite wire structure recited in Claim 1. The complaint's primary evidence for this is a reproduction of a patent figure (Compl. ¶12). The case may turn on what evidence, such as product teardowns or expert analysis, is presented to prove that the wires in the accused products are divided and wound in the precise manner claimed—specifically, that the first and third sections are wound together to the exclusion of the second section.
- Scope Question: The complaint alleges infringement of the "sole claim" of the patent (Compl. ¶30). The patent contains both apparatus (Claim 1) and method (Claim 9) independent claims. This raises the question of whether the infringement allegation is strictly limited to the apparatus claim, as the focus on "products" would suggest, or if Plaintiff intends to pursue other claims.
V. Key Claim Terms for Construction
- The Term: "a first conducting wire section, a second conducting wire section and a third conducting wire section in sequence"
- Context and Importance: The infringement analysis hinges entirely on whether the wiring of the accused products can be characterized as having this specific three-part structure between each light bead. The definition of what constitutes these distinct "sections" and their required "sequence" is therefore critical. Practitioners may focus on this term because if the wire is not meaningfully divisible into three distinct sections as claimed, the infringement allegation could fail.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification provides a functional description: "The conducting wire between two adjacent light beads is divided into three sections, which are a first conducting wire section, a second conducting wire section and a third conducting wire section in sequence" (’258 Patent, col. 1:61-65). This language does not explicitly require physical markers or separations, suggesting the sections could be defined conceptually by their different winding patterns.
- Evidence for a Narrower Interpretation: The patent’s figures, particularly Figure 7, provide a clear visual depiction of the three sections with distinct winding patterns (’258 Patent, FIG. 7). A party could argue that the term requires the specific, visually distinguishable structure shown in this embodiment, rather than any arbitrary post-hoc division of a continuous wire.
VI. Other Allegations
- Indirect Infringement: The complaint makes passing reference to indirect infringement and requests injunctive relief against "aiding, abetting, [or] contributing to" infringement (Compl. ¶29; Prayer ¶A(2)). However, the substantive allegations in Count I are for direct infringement under 35 U.S.C. § 271(a) and focus on Defendants' own acts of making, using, selling, and importing the accused products (Compl. ¶27-30).
- Willful Infringement: Willfulness is alleged based on Defendants "knowingly and willfully" offering for sale, selling, and importing infringing products without a license from the Plaintiff (Compl. ¶24-25, ¶29). The complaint further alleges that the defendants are part of a network of infringers who communicate and share tactics for evading intellectual property enforcement, which may be used to support an inference of pre-suit knowledge and willful blindness (Compl. ¶22).
VII. Analyst’s Conclusion: Key Questions for the Case
A central evidentiary question will be one of structural identity: Can the Plaintiff prove, through physical inspection and analysis, that the wiring of the accused products contains the specific tripartite structure recited in Claim 1? The case will likely depend on whether the accused products' wires are demonstrably "divided" into three sections and wound in the precise manner claimed, particularly the negative limitation that the first and third sections are wound "not with the second conducting wire sections."
A key procedural question will be one of enforcement and joinder: The complaint targets a large number of allegedly related online sellers identified on a schedule. A core issue for the court will be whether these disparate entities are properly joined under 35 U.S.C. § 299 and whether any resulting injunction or damages award can be effectively enforced against a diffuse network of foreign operators.