DCT
2:25-cv-02262
Shenzhen Hongxinshun Technology Co Ltd v. Hong Kong Xingtai Intl Trade Co Ltd
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Shenzhen Hongxinshun Technology Co., Ltd. (China)
- Defendant: Hong Kong Xingtai International Trade Co Limited (Hong Kong)
- Plaintiff’s Counsel: Glacier Law LLP
- Case Identification: 2:25-cv-02262, W.D. Wash., 11/13/2025
- Venue Allegations: Venue is based on Defendant’s patent enforcement activities, specifically initiating an Amazon "Patent Evaluation Express" proceeding and sending enforcement communications to Amazon personnel located within the Western District of Washington.
- Core Dispute: Plaintiff seeks a declaratory judgment that its outdoor solar decorative light products do not infringe Defendant's patent related to solar-powered lighting systems, and/or that the patent is invalid.
- Technical Context: The technology concerns self-contained, solar-powered decorative light strings that automatically operate based on ambient light, a product category prevalent in consumer markets for holiday and landscape lighting.
- Key Procedural History: The action was precipitated by Defendant's enforcement of the patent-in-suit through Amazon's "Patent Evaluation Express" (APEX) program, which created a threat that Plaintiff's product listings would be removed from the e-commerce platform.
Case Timeline
| Date | Event |
|---|---|
| 2008-07-14 | ’545 Patent Priority Date (Filing Date) |
| 2010-10-26 | ’545 Patent Issue Date |
| 2025-10-30 | Defendant allegedly reports Plaintiff's products to Amazon for infringement |
| 2025-11-13 | Complaint for Declaratory Judgment filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,819,545 - "Outdoor Solar Decorative Lights"
The Invention Explained
- Problem Addressed: The patent describes the problems associated with traditional, plug-in outdoor decorative lights, including the "very real danger of electrical shorts and shocks" and tripping hazards created by extension cords exposed to outdoor weather conditions (Compl. ¶15; ’545 Patent, col. 1:35-49).
- The Patented Solution: The invention is a self-contained, outdoor solar-powered decorative lighting system that eliminates the need for external electrical power (Compl. ¶16; ’545 Patent, Abstract). The system comprises a string of lights electrically connected to a solar collector containing solar panels and a rechargeable battery. A central feature is an automatic switch that senses ambient light to turn the lights on at dusk and off at sunrise, providing automated operation without manual intervention (’545 Patent, col. 2:31-39; Fig. 7).
- Technical Importance: The described solution offers homeowners enhanced safety, convenience, and ease of installation for outdoor decorations by obviating the need for cumbersome and potentially hazardous extension cords (’545 Patent, col. 2:46-49).
Key Claims at a Glance
- The complaint asserts non-infringement of independent claim 1 and dependent claims 2-3 (Compl. ¶¶ 21, 26).
- Independent Claim 1 of the ’545 Patent recites these essential elements:
- A flexible, elongated light string with an electrical wire and evenly spaced sockets for light bulbs.
- A solar collector connected to the light string, which includes a housing and at least one solar panel.
- A rechargeable battery contained within the housing.
- A "regulator switch" that is electrically interconnected to the battery and light string.
- The regulator switch automatically switches the bulbs on and off, specifically being "disposed to the open state from sunrise to sunset" and "automatically going to the closed state upon sunset."
III. The Accused Instrumentality
Product Identification
The complaint identifies the "Accused Product" as Plaintiff's "outdoor solar decorative light products," sold under various Amazon Standard Identification Numbers (ASINs) including B0FF1V2HWL and others (Compl. ¶¶ 1, 11).
Functionality and Market Context
The complaint alleges the Accused Product utilizes a "control architecture (including photosensor/IC logic and user controls)" that operates based on "instantaneous ambient-light conditions" (Compl. ¶23). This functionality is distinct from the patent's claimed operation, as it allegedly "permits illumination under daylight low-light or panel-covered scenarios" (Compl. ¶23). The products are sold on Amazon, which the Plaintiff describes as its "primary sales channel in the United States," making the threatened removal of its listings a significant commercial harm (Compl. ¶14).
No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint is for a declaratory judgment of non-infringement. The central allegations focus on why the Accused Product does not meet the limitations of Claim 1 of the ’545 Patent.
’545 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a regulator switch electrically interconnected to the battery and the light string for automatically switching the light bulbs on and off | The Accused Product uses a "control architecture" with a photosensor and IC logic, not a single "regulator switch." | ¶23 | col. 6:20-23 |
| whereby the switch is disposed to the open state from sunrise to sunset thereby preventing the light bulbs from lighting | The Accused Product's control system operates on instantaneous ambient light and can illuminate during daylight hours in low-light conditions or when the solar panel is covered, and therefore is not continuously in an "open state from sunrise to sunset." | ¶23 | col. 6:23-26 |
| and the switch automatically going to the closed state upon sunset thereby closing the circuit and causing the light bulbs to light. | The Accused Product’s circuit closes based on immediate low-light conditions, not strictly "upon sunset," which the complaint argues is a materially different operation. | ¶23 | col. 6:26-29 |
- Identified Points of Contention:
- Scope Questions: A primary dispute may concern whether the claim term "a regulator switch" can be interpreted to cover the Accused Product’s distributed "control architecture (including photosensor/IC logic and user controls)," or if it is limited to a discrete, singular component (Compl. ¶23).
- Technical Questions: The core technical question is whether the Accused Product's ability to activate during daylight hours (e.g., if a user covers the solar panel) means it fails to meet the claim's temporal limitation of being "disposed to the open state from sunrise to sunset." The Plaintiff alleges this difference in operation is material and avoids infringement both literally and under the doctrine of equivalents (Compl. ¶¶ 23-24).
V. Key Claim Terms for Construction
The Term: "a regulator switch"
Context and Importance
This term is central to the non-infringement argument, as the Plaintiff alleges its multi-component "control architecture" is not "a regulator switch" (Compl. ¶23). The construction of this term—whether it requires a single, discrete component or can encompass a logic-based system—may be dispositive.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The patent specification describes the function of the switch in broad terms, and the flowchart in Figure 7 depicts a functional block for detecting ambient light, which could support an interpretation covering any circuitry that achieves this result (’545 Patent, Fig. 7).
- Evidence for a Narrower Interpretation: The patent refers to "An on/off current regulator switch 66" in the singular, and the claim language recites "a regulator switch," which may support an argument that the claim requires a single, identifiable component rather than a distributed control system (’545 Patent, col. 5:14-15; col. 6:20).
The Term: "disposed to the open state from sunrise to sunset"
Context and Importance
Plaintiff's primary non-infringement theory rests on this temporal limitation, arguing its products can turn on during the day in low-light situations and thus do not maintain an "open state" for the entire specified period (Compl. ¶23).
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The patent’s overall objective is to "come on automatically at dusk and turn off automatically at dawn," suggesting the phrase could be interpreted to mean "during normal daylight hours" rather than a literal, uninterrupted state that could be defeated by artificial conditions like covering a sensor (’545 Patent, col. 2:65-67).
- Evidence for a Narrower Interpretation: The claim language is specific and absolute. The specification states the switch "is maintained in an open state during periods of daylight," which could support a strict interpretation requiring the circuit to remain open continuously throughout the entire period between sunrise and sunset, irrespective of transient lighting conditions (’545 Patent, col. 5:16-18).
VI. Other Allegations
- Indirect Infringement: The complaint preemptively denies any basis for indirect infringement, alleging that the Accused Product is a "staple article of commerce suitable for substantial non-infringing uses" and that its associated materials do not encourage or instruct any infringing activity (Compl. ¶¶ 25-26).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim scope and temporal limitation: Can the phrase "disposed to the open state from sunrise to sunset" be construed to cover a product that responds to instantaneous ambient light levels and can be activated during daylight hours, or does this functionality place the accused product outside the literal scope of the claim?
- A related question will be one of technical and functional difference: Does the accused product's operation based on immediate light conditions, as opposed to a strict day/night cycle, represent a "materially different function-way-result" that would preclude a finding of infringement under the doctrine of equivalents, as the Plaintiff argues?
- Finally, the case presents a significant validity question: Do the numerous prior art references cited in the complaint, which allegedly disclose solar-powered lights with automatic ambient light sensors, render the specific switching logic of the ’545 Patent obvious to a person of ordinary skill in the art at the time of the invention?