DCT

1:25-cv-01543

Ming D&Y Inc v. Shenzhen Yima Technology Co Ltd

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-01543, E.D. Va., 09/16/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign corporation not resident in the United States.
  • Core Dispute: Plaintiff alleges that Defendant’s LED dog collar infringes a patent related to efficiently transmitting light from an LED through a flexible polymeric element.
  • Technical Context: The technology at issue addresses illuminated flexible articles, such as safety bands or pet collars, designed for high visibility with efficient use of battery power.
  • Key Procedural History: The complaint alleges that Defendant previously filed a Declaratory Judgment Action in Texas concerning the patent-in-suit, which Plaintiff claims evidences Defendant's knowledge of the patent. Plaintiff also asserts that the patent was subject to a delayed maintenance fee payment which has since been rectified.

Case Timeline

Date Event
2015-02-04 ’325 Patent Priority Date
2016-11-08 ’325 Patent Issue Date
2020-12-10 Accused Product First Available on Amazon.com
2025-09-16 Complaint Filing Date

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

U.S. Patent No. 9,488,325 - “Light Transmission”

(Issued November 8, 2016; ’325 Patent)

The Invention Explained

  • Problem Addressed: The patent describes a need for portable, flexible light-transmitting devices (e.g., safety collars, bracelets) that offer improved light transmission efficiency, adaptability to different lengths, and lower cost compared to prior art designs (’325 Patent, col. 1:7-17).
  • The Patented Solution: The invention discloses a device composed of a self-contained electronics module and a separate flexible light transmitting element. The core of the solution is the specific physical interface: one or more LEDs are positioned "immediately adjacent but not embedded in" the end(s) of the flexible element, ensuring that light is efficiently transmitted into the element without the manufacturing complexity of embedding the light source (’325 Patent, Abstract; col. 1:24-30). This module is mounted within a housing which connects to the ends of the flexible element, allowing for a standardized light source to be used with light guides of various lengths (’325 Patent, col. 4:61-64).
  • Technical Importance: The design's separation of the electronics module from the light-transmitting element simplifies manufacturing and allows for greater product adaptability (’325 Patent, col. 1:18-24).

Key Claims at a Glance

  • The complaint asserts independent claim 8 and dependent claim 9 (’325 Patent, col. 8:7-60; Compl. ¶7).
  • Independent Claim 8 requires:
    • A flexible elongated light transmitting element with first and second ends.
    • First and second LEDs positioned "immediately adjacent" to the respective first and second ends of the element.
    • At least one rechargeable battery.
    • "Positioning elements" that place the LEDs "immediately adjacent but not embedded in" the element ends.
    • These positioning elements comprise a housing connected to the element ends via "flexible thermoplastic material end caps."
    • A printed circuit board (PCB) with circuitry and an electrical switch, where the PCB mounts the LEDs, battery, and switch into an "integral module."
    • A requirement that the LEDs "essentially touch" the ends of the light transmitting element.
    • A USB port on the PCB for recharging the battery.
  • The complaint reserves the right to assert other claims after discovery (Compl. ¶7).

III. The Accused Instrumentality

Product Identification

  • The "2-Pack LED Dog. Col." sold by Defendant under the brand name "NOVKIN" on amazon.com (Compl. ¶6).

Functionality and Market Context

  • The complaint identifies the accused instrumentality as an LED dog collar sold in the United States through amazon.com (Compl. ¶6). The complaint does not provide sufficient detail for analysis of the product's specific technical construction or operational features.

IV. Analysis of Infringement Allegations

The complaint alleges that the Accused LED Collar infringes at least claims 8 and 9 of the ’325 Patent, but it does not provide an element-by-element breakdown of its infringement theory or include a claim chart (Compl. ¶7). No probative visual evidence provided in complaint.

Identified Points of Contention

  • Scope Questions: The dispute may center on the construction of the phrase "immediately adjacent but not embedded in," which the specification defines as "less than two centimeters away from it, and preferably essentially touches it" (’325 Patent, col. 2:40-44). A key question will be whether the accused product’s physical arrangement of its LEDs relative to its light guide falls within the scope of this definition.
  • Technical Questions: The complaint does not contain facts describing the internal construction of the accused collar. A central factual question for the court will be whether the product contains the specific combination of structural elements recited in claim 8, including a housing, separate "flexible thermoplastic material end caps," an "integral module" containing the PCB, battery, and switch, and a USB port for recharging.

V. Key Claim Terms for Construction

The Term: "immediately adjacent but not embedded in"

  • Context and Importance: This term defines the central spatial relationship between the light source and the light guide, which the patent presents as a key point of novelty. The infringement analysis will depend heavily on the physical distance and configuration of these components in the accused product.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification provides an explicit definition: "less than two centimeters away from it, and preferably essentially touches it" (’325 Patent, col. 2:40-44). Plaintiff may argue this creates a clear, measurable boundary for the claim's scope.
    • Evidence for a Narrower Interpretation: The patent's figures and description of embodiments consistently show the LED directly aligned with and abutting the end of the light-transmitting element (’325 Patent, Fig. 2; col. 4:56-60). Defendant may argue that these examples limit the scope to a configuration where the components are in direct or near-direct contact.

The Term: "positioning elements"

  • Context and Importance: This term recites the overall structure that holds the lighting components and connects to the flexible collar band. Claim 8 further defines these elements as comprising a "housing" and "flexible thermoplastic material end caps." Infringement will require the accused product to possess this specific multi-part construction.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: Plaintiff may argue that any structure that functions to position the LEDs and includes components that can be identified as a "housing" and "end caps" meets the limitation, even if not identical to the patent's figures.
    • Evidence for a Narrower Interpretation: Defendant may contend that the claim requires the specific structural arrangement shown in the patent, where the housing, module, and flexible end caps are distinct, cooperating components (’325 Patent, Fig. 2). A product with a more integrated or unitary construction might be argued to fall outside this scope.

VI. Other Allegations

Indirect Infringement

  • The complaint makes a conclusory allegation of induced infringement but does not plead specific facts, such as references to user manuals or advertisements, that would show Defendant encouraged infringing acts (Compl. ¶8).

Willful Infringement

  • The complaint alleges willful infringement on the basis that Defendant continued to sell the accused product after receiving "notifications of infringement" from Plaintiff (Compl. ¶¶8-9). It further points to a Declaratory Judgment Action filed by Defendant as evidence of pre-suit knowledge of the patent (Compl. ¶9).

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

  • A core issue will be one of definitional scope: can the phrase "immediately adjacent but not embedded in," as defined and illustrated in the patent, be construed to read on the specific physical construction of the accused LED collar?
  • A central challenge will be one of evidentiary proof: as the complaint lacks specific technical allegations, the case will depend on Plaintiff’s ability to demonstrate through discovery that the accused product's internal components—specifically its housing, end caps, and electronics module—map onto the particular combination of structural elements required by claim 8.