DCT
2:25-cv-02264
Suqian Zhenye Electronics Technology Co Ltd v. Hong Kong Xingtai Intl Trade Co Ltd
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Suqian Zhenye Electronics Technology Co., Ltd. d/b/a XINZHE (People's Republic of China)
- Defendant: Hong Kong Xingtai International Trade Co Limited (Hong Kong, China)
- Plaintiff’s Counsel: Glacier Law LLP
- Case Identification: 2:25-cv-02264, W.D. Wash., 11/13/2025
- Venue Allegations: Venue is based on Defendant's patent enforcement activities directed at Plaintiff through Amazon's "Patent Evaluation Express" program, which involves communications to Amazon personnel located in 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 at issue involves self-contained, solar-powered decorative light strings, a common product category in the consumer electronics and home goods markets.
- Key Procedural History: The complaint states that this lawsuit was precipitated by Defendant's infringement accusations made through Amazon's "Patent Evaluation Express" (APEX) process, which threatened the removal of Plaintiff's product listings from the e-commerce platform.
Case Timeline
| Date | Event |
|---|---|
| 2008-07-14 | ’545 Patent Priority 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"
- Patent Identification: U.S. Patent No. 7,819,545, "Outdoor Solar Decorative Lights," issued October 26, 2010 (’545 Patent).
The Invention Explained
- Problem Addressed: The patent's background section identifies the safety hazards and inconvenience associated with traditional, plug-in outdoor decorative lights, such as the risk of electrical shorts from exposure to weather and the tripping hazard posed by extension cords (’545 Patent, col. 1:35-49).
- The Patented Solution: The invention proposes a self-contained outdoor lighting system that operates without needing an external electrical outlet. It comprises a string of lights electrically connected to a solar collector, which contains solar panels, a housing, and an internal rechargeable battery. A key feature is a switch that automatically turns the lights on at dusk and off at sunrise, obviating the need for manual operation or external timers (’545 Patent, Abstract; col. 2:24-39). The system is described with the solar collector mounted on a roof to capture sunlight (’545 Patent, col. 2:39-41).
- Technical Importance: This approach aimed to provide a safer, more convenient, and potentially more cost-effective method for outdoor decoration by eliminating reliance on residential electrical grids and cumbersome extension cords (’545 Patent, col. 2:46-54).
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 includes the following essential elements:
- A flexible, elongated light string with an electrical wire.
- A plurality of evenly spaced sockets and light bulbs mounted on the string.
- A solar collector electrically connected to the string, which includes a housing and at least one solar panel.
- A rechargeable battery contained within the housing.
- A regulator switch interconnected to the battery and the light string for automatically switching the bulbs on and off.
- The switch is functionally defined as 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
- Plaintiff’s "outdoor solar decorative light products," sold under various Amazon Standard Identification Numbers (ASINs), including B0FF1V2HWL and B0FF1TXMSF (Compl. ¶¶ 11, 23).
Functionality and Market Context
- The complaint alleges that the Accused Products utilize a "control architecture (including photosensor/IC logic and user controls)" that responds to "instantaneous ambient-light conditions" (Compl. ¶23). This functionality is alleged to differ from the patent's claims because it permits illumination during daylight hours in low-light or panel-covered situations, rather than maintaining a continuously open circuit from sunrise to sunset (Compl. ¶23).
- The products are sold on Amazon.com, which the complaint identifies as the Plaintiff's "primary sales channel in the United States," making the threat of delisting a significant commercial risk (Compl. ¶14).
- No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement. The following table summarizes the Plaintiff's primary arguments for why its product does not meet the limitations of claim 1.
- ’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 photosensor/IC logic and user controls, not a single "regulator switch." | ¶23 | col. 6:18-21 |
| 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 logic operates on "instantaneous ambient-light conditions" and can permit illumination during daylight low-light or panel-covered scenarios. | ¶23 | col. 6:21-24 |
| 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 does not remain open continuously "from sunrise to sunset" and only close "upon sunset," as its state is determined by immediate light levels. | ¶23 | col. 6:24-26 |
- Identified Points of Contention:
- Scope Questions: A central dispute may concern the interpretation of the phrase "disposed to the open state from sunrise to sunset." The question is whether this language requires a continuous, uninterrupted open circuit for the entire duration of daylight, or if it can be interpreted more broadly to describe the general operating principle while allowing for momentary exceptions based on ambient conditions.
- Technical Questions: The case raises the question of whether a modern, logic-based "control architecture" that reacts to instantaneous light levels is technically and legally distinct from the claimed "regulator switch" that operates based on the broad temporal periods of "sunrise to sunset." The complaint suggests a fundamental mismatch in the way the respective technologies function and achieve their results (Compl. ¶¶ 23-24).
V. Key Claim Terms for Construction
The Term: "regulator switch"
- Context and Importance: This term is at the core of the non-infringement argument. Plaintiff contends that its product's "control architecture" is not the claimed "regulator switch" (Compl. ¶23). The construction of this term will likely determine whether modern photosensor and integrated circuit-based controllers fall within the claim's scope.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification refers to an "on/off current regulator switch 66" that functions "through the detection or non-detection of ambient light" (’545 Patent, col. 5:14-17). A party could argue this language broadly covers any switching mechanism that regulates current based on light.
- Evidence for a Narrower Interpretation: The claim itself strictly defines the switch's function: it must be "disposed to the open state from sunrise to sunset" and go to the "closed state upon sunset" (’545 Patent, col. 6:21-26). This specific, temporal behavior, illustrated in the flowchart of Figure 7, could be argued to exclude controllers that permit illumination during daytime low-light events, as the complaint alleges the accused product does (Compl. ¶23).
The Term: "disposed to the open state from sunrise to sunset"
- Context and Importance: This temporal limitation is the primary basis for Plaintiff's argument that its product operates differently (Compl. ¶23). Its construction will be critical to assessing literal infringement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: One could argue this phrase describes the intended, default behavior during daylight hours, not a rigid command that prohibits any deviation under unusual light conditions.
- Evidence for a Narrower Interpretation: The specification states that "the switch 66 is maintained in an open state during periods of daylight (detection of light between sunrise and sunset adjusted seasonally)" (’545 Patent, col. 5:17-20). The use of "maintained" suggests a continuous, uninterrupted state, supporting a literal interpretation that would favor the Plaintiff's non-infringement position.
VI. Other Allegations
- Indirect Infringement: The complaint preemptively denies any indirect infringement, asserting that Plaintiff has not encouraged or instructed customers to use the product in an infringing manner and that the product is a staple article of commerce with substantial non-infringing uses (Compl. ¶¶ 25-26).
- Willful Infringement: The complaint does not allege willful infringement by the Defendant in the traditional sense. Instead, in its prayer for relief, Plaintiff characterizes Defendant's patent enforcement actions as improper and requests that the case be found "exceptional" to recover attorney fees and potentially enhanced damages, framing the enforcement itself as a willful or improper act (Compl., Prayer for Relief ¶¶ D-E).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of technological evolution and claim scope: can the term "regulator switch," which is described in the patent with a specific "sunrise to sunset" operational logic, be construed to cover a modern "control architecture" that operates based on instantaneous ambient light levels and permits daytime operation in low-light conditions?
- A second key question will be one of validity in view of prior art: given the numerous prior art references cited in the complaint that allegedly disclose solar panels, rechargeable batteries, light strings, and light-sensing circuits, did the specific automatic switching function claimed in the ’545 Patent represent a non-obvious advance over what was already known in the field of solar decorative lighting? (Compl. ¶¶ 34-38).