DCT
2:25-cv-02265
Shenzhen Chunyan Technology Co Ltd v. Hong Kong Xingtai Intl Trade Co Ltd
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Shenzhen Chunyan 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-02265, W.D. Wash., 11/13/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant purposefully directed patent-enforcement activities into the district by initiating an Amazon "Patent Evaluation Express" proceeding and sending enforcement communications to Amazon personnel located in Seattle, 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 involves solar-powered decorative light strings that use a solar collector, a rechargeable battery, and control circuitry to automatically illuminate at night.
- Key Procedural History: The action was precipitated by Defendant’s accusation of infringement against Plaintiff's product listings on Amazon.com, made through Amazon’s "Patent Evaluation Express" (APEX) program, which threatened removal of the listings.
Case Timeline
| Date | Event |
|---|---|
| 2008-07-14 | ’545 Patent Priority Date |
| 2010-10-26 | ’545 Patent Issue Date |
| 2025-10-30 | Defendant initiated patent enforcement action on Amazon |
| 2025-11-13 | Complaint for Declaratory Judgment filed |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. 7,819,545, Outdoor Solar Decorative Lights, issued October 26, 2010.
I. The Invention Explained
- Problem Addressed: The patent's background describes the problems associated with conventional outdoor decorative lights, which require being plugged into an electrical outlet. These problems include the risk of electrical shorts and shocks from exposure to weather, as well as the tripping hazard posed by extension cords. (’545 Patent, col. 1:36-49).
- The Patented Solution: The invention is a self-contained, solar-powered decorative lighting system. It comprises a string of lights electrically connected to a solar collector that houses solar panels and a rechargeable battery. (’545 Patent, col. 2:25-35). A key component is an automatic switch that regulates power from the battery, turning the lights on at dusk and off at dawn, thereby eliminating the need for manual operation or external power sources. (’545 Patent, col. 2:64-67; Fig. 7).
- Technical Importance: The described solution offers a safer and more convenient alternative to traditional electric light strings for outdoor decoration by removing reliance on household electrical currents and extension cords. (’545 Patent, col. 2:16-24).
II. 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 requires:
- A flexible, elongated light string with an electrical wire and evenly spaced sockets with light bulbs.
- A solar collector electrically connected to the light string, which includes a housing and at least one solar panel.
- A rechargeable battery contained within the housing and connected to the solar panel.
- A regulator switch electrically interconnected to the battery and the light string for automatically switching the light bulbs on and off.
- The switch is disposed to the open state from sunrise to sunset, preventing the bulbs from lighting.
- The switch automatically goes to the closed state upon sunset, causing the bulbs to light.
III. The Accused Instrumentality
I. Product Identification
- The complaint identifies the accused products as Plaintiff's "outdoor solar decorative light products" or "Decorative Lights." (Compl. ¶23).
II. Functionality and Market Context
- The complaint alleges that the accused products feature a control architecture, including a photosensor and integrated circuit logic, that operates based on "instantaneous ambient-light conditions." (Compl. ¶23). This functionality allegedly permits the lights to illuminate during daylight hours in low-light scenarios, such as when the solar panel is covered. (Compl. ¶23).
- The complaint states that the Amazon marketplace is Plaintiff's primary sales channel in the United States, and Defendant's enforcement actions threaten to remove its product listings. (Compl. ¶14).
IV. Analysis of Infringement Allegations
I. Claim Chart Summary
- The following table summarizes the Plaintiff's (declaratory judgment plaintiff) asserted non-infringing functionality against the elements of Claim 1.
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a flexible, elongated light string; an electrical wire extending through the light string...a plurality of sockets mounted on the light string and spaced evenly therealong; a plurality of light bulbs mounted to the sockets... | The complaint does not contest that the accused product includes a light string with sockets and bulbs. | ¶22 | col. 6:3-9 |
| a solar collector electrically connected to the light string and including a bottom side and an upper side; the solar collector including a housing and at least one solar panel supported in the housing... | The complaint does not contest that the accused product includes a solar collector with a housing and solar panel. | ¶22 | col. 6:10-14 |
| a rechargeable battery contained within the housing and electrically connected to the solar panel... | The complaint does not contest that the accused product includes a rechargeable battery within the housing. | ¶22 | col. 6:15-18 |
| a regulator switch... for automatically switching the light bulbs on and off whereby the switch is disposed to the open state from sunrise to sunset... and the switch automatically going to the closed state upon sunset... | The Accused Product's control architecture operates on instantaneous ambient-light conditions, rather than maintaining an open state continuously "from sunrise to sunset" and closing only "upon sunset." It can illuminate during the day if the panel is covered. | ¶23 | col. 6:19-26 |
No probative visual evidence provided in complaint.
II. Identified Points of Contention
- Scope Questions: A central dispute will be the interpretation of the claim phrases "from sunrise to sunset" and "upon sunset." The question for the court will be whether this language requires a switch that operates based on a continuous, day-long period, or if it can be read more broadly to cover any light-sensing switch that generally activates at night and deactivates during the day.
- Technical Questions: The complaint raises the question of whether there is a fundamental operational difference between the claimed "regulator switch" and the accused product's control system. Does the accused product's "photosensor/IC logic" (Compl. ¶23) function merely as a light-level threshold switch, as alleged, or does it incorporate timers or other logic that approximates the claimed "sunrise to sunset" behavior?
V. Key Claim Terms for Construction
- The Term: "a regulator switch... disposed to the open state from sunrise to sunset... and... automatically going to the closed state upon sunset"
- Context and Importance: This term is the crux of the non-infringement argument. Plaintiff contends its product, which can illuminate in daylight low-light conditions, does not meet this temporal limitation. (Compl. ¶¶ 23-24). The case will likely turn on whether the accused product's instantaneous light-sensing mechanism falls outside the scope of this claim language.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Practitioners may argue that the specification's reference to the switch operating through "the detection or non-detection of ambient light" suggests the core mechanism is simple light sensing, and the "sunrise to sunset" language is merely illustrative of the typical operating environment. (’545 Patent, col. 5:16-18).
- Evidence for a Narrower Interpretation: The claim language itself provides express temporal boundaries. This is reinforced by the specification, which states "the switch 66 is maintained in an open state during periods of daylight (detection of light between sunrise and sunset adjusted seasonally), and the switch 66 is disposed to the closed state... immediately upon sunset and extending to the next sunrise." (’545 Patent, col. 5:16-22). This language may support a narrower construction requiring operation tied to the entire daylight cycle, not just instantaneous light levels.
VI. Other Allegations
- Indirect Infringement: The complaint preemptively denies indirect infringement, alleging that its product is a "staple article of commerce suitable for substantial non-infringing uses" and that its user materials do not encourage or instruct any infringing practice. (Compl. ¶¶ 25-26).
- Willful Infringement: The complaint does not contain an allegation of willful infringement against the Plaintiff. The Plaintiff's prayer for relief seeks enhanced damages for Defendant's "improper acts" related to its enforcement conduct, not for willful patent infringement. (Compl., Prayer for Relief ¶E).
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this declaratory judgment action appears to hinge on two primary questions:
- A core issue will be one of claim construction: Must the phrase "disposed to the open state from sunrise to sunset" be interpreted literally to require a circuit that remains open for the entire duration of daylight, or can it encompass a circuit that simply reacts to the presence or absence of sufficient ambient light?
- A key evidentiary question will be one of technical operation: Does the accused product's control system, which allegedly operates on "instantaneous ambient-light conditions," function in a manner materially different from the specific temporal behavior described and claimed in the ’545 Patent?