Shenzhen Benxiang Photoelectric Co Ltd v. Kappa Agtech LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Shenzhen Benxiang Photoelectric Co., Ltd. and Chuanli Sun (People's Republic of China)
  • Defendant: Kappa Agtech, LLC (Virginia)
  • Plaintiff’s Counsel: Glacier Law LLP
• Case Identification: 2:25-cv-02034, W.D. Wash., 10/20/2025
• Venue Allegations: Plaintiffs allege venue is proper in the Western District of Washington because Defendant directed patent enforcement activities at Amazon personnel located in Seattle, leading to the removal of Plaintiffs' product listings.
• Core Dispute: Plaintiffs, sellers of horticultural lights, seek a declaratory judgment that their products do not infringe Defendant's three patents and/or that the patents are invalid.
• Technical Context: The dispute centers on integrated lighting and ventilation systems for high-density indoor horticulture, a field where managing heat and airflow is critical for crop yield and equipment longevity.
• Key Procedural History: This declaratory judgment action follows a prior lawsuit filed by Defendant KAPPA AGTECH in the Eastern District of Virginia. In that case, KAPPA obtained a temporary restraining order (TRO) that resulted in the removal of Plaintiffs' products from Amazon. KAPPA subsequently dismissed the Virginia suit without prejudice and offered Plaintiffs a license, which precipitated the filing of this action. Plaintiffs also raise invalidity challenges based on two prior art references, "Aykroyd" and "Krijn."

Case Timeline

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

U.S. Patent No. 11,226,090 - "Device and Apparatus for Horticultural Lighting and Ventilation"

The Invention Explained

• Problem Addressed: In high-density indoor horticulture, placing powerful LED lights very close to plants is efficient but generates damaging heat, while placing them far away is inefficient. Inadequate ventilation can harm both the plants and the LED hardware itself from overheating and humidity (’090 Patent, col. 1:40-55).
• The Patented Solution: The invention proposes an integrated device comprising a hollow tube with LEDs attached to its outer surface. A source of forced air, such as a fan, pushes air into the tube, which then exits through a series of holes along the tube's surface. This arrangement simultaneously provides ventilation directly to the plant canopy and cools the LEDs, allowing them to be placed closer to the crops for greater efficiency (’090 Patent, col. 2:54-col. 3:11; Fig. 1-2).
• Technical Importance: This integrated approach aims to solve the coupled problems of lighting efficiency and thermal management in a single unit, which is critical for the economic viability of controlled environment agriculture (’090 Patent, col. 2:40-47).

Key Claims at a Glance

• The complaint asserts non-infringement of independent claim 1 (Compl. ¶28).
• Claim 1 Elements:
  • A device for illuminating plants and circulating air, comprising: a hollow body,
  • wherein the hollow body comprises at least one opening,
  • wherein the opening(s) is/are connected to at least one source of forced air,
  • wherein a surface of the hollow body comprises a plurality of holes,
  • wherein at least some of the forced air supplied to the hollow body through the opening(s) exits the hollow body through one or more of the holes,
  • wherein a plurality of light emitting diodes (herein "LEDs") are attached to an outside surface of the hollow body,
  • wherein the LEDs provide a specified level of photosynthetically active radiation,
  • and wherein holes are positioned relative to the LEDs such that exiting air flows substantially parallel to the light from the LEDs.

U.S. Patent No. 12,092,306 - "Device and Apparatus for Horticultural Lighting and Ventilation"

The Invention Explained

• Problem Addressed: As a continuation of the application leading to the ’090 Patent, the ’306 Patent addresses the same technical challenge: the need for efficient, close-proximity lighting in high-density horticulture without causing heat damage to plants or the lighting equipment (’306 Patent, col. 1:51-61).
• The Patented Solution: The solution described is functionally identical to that of the ’090 Patent: a hollow body with exterior LEDs and surface holes through which forced air is expelled for combined plant ventilation and LED cooling (’306 Patent, col. 2:55-col. 3:25).
• Technical Importance: The patent perpetuates the technical goal of integrating ventilation and illumination to improve the efficiency and control of microclimates in indoor farming operations (’306 Patent, col. 2:55-58).

Key Claims at a Glance

• The complaint asserts non-infringement of independent claim 1 (Compl. ¶47).
• Claim 1 Elements:
  • A device for illuminating plants and circulating air, comprising: a hollow body,
  • wherein the hollow body comprises at least one opening,
  • wherein the opening(s) is/are connected to at least one source of forced air,
  • wherein a surface of the hollow body comprises a plurality of holes,
  • wherein at least some of the forced air is drawn from the hollow body through the opening(s) enters the hollow body through one or more of the holes,
  • wherein a plurality of LEDs are attached to an outside surface of the hollow body,
  • wherein the LEDs provide a specified level of photosynthetically active radiation,
  • and wherein holes are positioned relative to the LEDs such that entering air flows substantially parallel to the light from the LEDs.

U.S. Patent No. 12,338,986 - "Device and Apparatus for Horticultural Lighting and Ventilation"

Technology Synopsis

This patent, also in the same family, discloses a device that combines LED lighting and ventilation in a single unit. It claims a hollow body with an upper portion containing fans that pull air from outside and push it through holes located on a lower portion where LEDs are mounted, thereby circulating air to plants (Compl. ¶65; ’986 Patent, Claim 1).

Asserted Claims

The complaint asserts non-infringement of independent claim 1 (Compl. ¶66).

Accused Features

The complaint alleges that Plaintiffs' "Grow Lights" do not infringe because they are "lighting-only" devices that lack the claimed integrated air circulation capability and require separate, external fans for air movement (Compl. ¶65).

III. The Accused Instrumentality

Product Identification

• Plaintiffs' "Grow Lights" products, also referred to as the "Accused Product" (Compl. ¶25).

Functionality and Market Context

• The complaint characterizes the Accused Product as a "lighting-only device for plants, lacking any integrated air circulation capability" (Compl. ¶27, ¶46, ¶65). It is alleged to require separate external fans for plant ventilation (Compl. ¶27, ¶46, ¶65).
• Technically, the complaint alleges the product uses an internal fan to passively draw ambient air through openings, with the air becoming "forced" only after it is inside the housing and acted upon by the fan (Compl. ¶29, ¶48, ¶67).
• The complaint notes that the Amazon marketplace is Plaintiffs' "primary sales channel" in the United States, making the threat of product removal due to patent enforcement a significant commercial concern (Compl. ¶13).
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

U.S. Patent No. 11,226,090 Infringement Allegations

Identified Points of Contention

• Scope Questions: The dispute may turn on the interpretation of "connected to." The complaint suggests this requires a direct physical linkage or seal, raising the question of whether a functional connection where a fan draws air through a nearby, but not physically attached, opening meets the claim limitation.
• Technical Questions: A central issue is the sequence and location of the "forced air" source. The complaint frames a distinction between air that is already "forced" when it enters the device (as allegedly required by the patent) and ambient air that is drawn in and only subsequently forced by an internal fan (as allegedly occurs in the accused product). The factual evidence will need to establish whether this operational difference exists and if it is legally significant under the claim language.

U.S. Patent No. 12,092,306 Infringement Allegations

Identified Points of Contention

• The points of contention for the ’306 Patent are identical to those for the ’090 Patent, as described above. The infringement analysis for both patents will likely rise and fall on the same claim construction and factual questions regarding the meaning of "connected to" and the nature of the "source of forced air."

V. Key Claim Terms for Construction

The Term: "connected to"

• Context and Importance: This term is central to Plaintiffs' non-infringement theory. Plaintiffs argue their product's fan is housed with a "clear gap" from the air intake openings, and thus is not "connected to" them in the manner required by the claims (Compl. ¶28, ¶47, ¶66). The viability of this defense depends on whether the court construes "connected to" to require a direct, sealed physical linkage or if it can also cover a functional or proximate relationship.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term itself is not explicitly defined. A defendant could argue that in mechanical arts, "connected to" can mean functionally coupled, and that a fan positioned to draw air through an opening is functionally connected to it.
  • Evidence for a Narrower Interpretation: The specification discloses embodiments where the "source of forced air may be a fan directly affixed to the device, or may be connected through ducting to a central source" (’090 Patent, col. 2:62-64). Plaintiffs may argue these examples of being "affixed" or connected via "ducting" imply a requirement for a direct physical linkage.

The Term: "source of forced air"

• Context and Importance: The complaint distinguishes between a "source" that provides pre-pressurized air to the device's openings and a fan internal to the device that creates forced air from passively drawn ambient air (Compl. ¶29, ¶48, ¶67). The case may depend on whether the claimed "source" must be external to the "hollow body" or if an internal fan assembly can constitute the "source."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claims do not specify that the "source" must be external to the "hollow body." Figure 2 of the patents depicts a "duct fan 6" placed "into the open end of the tube," which could be interpreted as a source that is at least partially internal to the device (’090 Patent, Fig. 2; col. 2:26-29).
  • Evidence for a Narrower Interpretation: The specification's reference to connection "through ducting to a central source of forced air such as an air handling unit" suggests an external source is contemplated (’090 Patent, col. 2:63-64). Plaintiffs will likely argue this context limits the "source" to a component that supplies already-pressurized air to the device, rather than a fan that is integral to it.

VI. Other Allegations

The complaint does not provide sufficient detail for analysis of indirect or willful infringement.

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

This declaratory judgment action appears poised to center on fundamental questions of claim scope and technical operation. The resolution of the non-infringement claims will likely depend on the court's answers to the following:

• A core issue will be one of definitional scope: Does the term "connected to," as used in the patents, require a direct and sealed physical linkage between the air openings and the fan, as Plaintiffs contend, or can it be satisfied by a functional arrangement where a fan is positioned to draw air through a nearby opening?
• A related and critical question is one of operational sequence: Must the "source of forced air" be a component that supplies pressurized air to the hollow body's openings, or can the claim be read to cover a device where an internal fan pulls ambient air through the openings and then forces it through the ventilation holes?
• Finally, while not analyzed in detail here, the parallel invalidity challenges based on the Aykroyd and Krijn references will present a separate track for the litigation. The ultimate outcome may depend not only on the infringement analysis but also on whether Plaintiffs can demonstrate that the asserted claims were not novel or were obvious in light of the prior art.