DCT
2:26-cv-00157
Guangzhou Liyuan Technology Co Ltd v. Arthur Chao Chung Wu
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Guangzhou Liyuan Technology Co., Ltd. d/b/a OGERY-Camping (People's Republic of China)
- Defendant: Arthur Chao-Chung Wu (United States)
- Plaintiff’s Counsel: Glacier Law LLP
- Case Identification: 2:26-cv-00157, W.D. Wash., 01/15/2026
- Venue Allegations: Plaintiff asserts venue is proper in the Western District of Washington because the Defendant directed patent enforcement activities into the district by initiating a proceeding against Plaintiff's Amazon listings, which foreseeably resulted in actions by Amazon personnel located in Seattle.
- Core Dispute: Plaintiff seeks a declaratory judgment that its camping string light products do not infringe, and that the claims are invalid, following Defendant’s patent infringement report to Amazon that resulted in the removal of Plaintiff's product listings.
- Technical Context: The technology concerns portable, battery-powered lighting devices that can be converted between an extended "rope light" for broad illumination and a compact "lantern" for localized light.
- Key Procedural History: The action was precipitated by Defendant's enforcement of the patent-in-suit through Amazon's intellectual property reporting mechanism, leading to the removal of Plaintiff's product listings. The complaint alleges that the patent-in-suit is a continuation of a prior patent and that its prosecution history limits the scope of the key term "lantern mode" to an external wrap-around configuration, a central point of its non-infringement and invalidity arguments.
Case Timeline
| Date | Event |
|---|---|
| 2020-06-15 | ’764 Patent Priority Date |
| 2024-09-20 | ’764 Patent Application Filing Date |
| 2025-04-22 | ’764 Patent Issue Date |
| 2026-01-14 | Amazon removes Plaintiff's product listings based on Defendant's report |
| 2026-01-15 | Complaint for Declaratory Judgment Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,281,764 - *"Convertible light device"*
The Invention Explained
- Problem Addressed: The patent background describes a need for improved portable lighting that can emit consistently bright light over a large area, which is a limitation of conventional lanterns that produce concentrated light and decorative string lights that are not bright enough for practical use (Compl. ¶14; ’764 Patent, col. 1:36-62).
- The Patented Solution: The invention is a "convertible light device" featuring a main housing with a battery pack and an "elongate flexible light source" (a rope light). This light source can be unwound and extended from the housing to function as a string light ("rope mode") or wrapped around the housing's exterior to function as a lantern ("lantern mode"), providing versatility between area and localized illumination (’764 Patent, Abstract; Fig. 1A-1B).
- Technical Importance: This approach combines the wide-area coverage of a string light with the portability and focused output of a lantern into a single, battery-powered device, addressing a gap in the portable lighting market (Compl. ¶14; ’764 Patent, col. 1:45-62).
Key Claims at a Glance
- The complaint identifies independent claims 1 and 14 as being at issue (Compl. ¶21, 23).
- Independent Claim 1:
- A device comprising a housing and a rope light coupled to the housing
- The device is configured to convert between a rope mode and a lantern mode
- Wherein in the lantern mode, the rope light is retracted to define a concentrated area of light
- And wherein in the rope mode, the rope light extends from the housing
- Independent Claim 14:
- A device comprising a housing and a rope light coupled to the housing
- The device is configured to convert between a rope mode and a lantern mode
- Wherein in the lantern mode, the rope light is retracted within the housing
- And wherein in the rope mode, the rope light extends from the housing
- The complaint also notes that dependent claims are not infringed because the independent claims are not infringed (Compl. ¶24).
III. The Accused Instrumentality
Product Identification
- Plaintiff’s "camping string light products," identified by Amazon Standard Identification Numbers (ASINs) B0F4KVR6TN, B0DGQ3CWS5, B0FGJ4S77X, B0F53ZTYFZ, B0DGPZ76G3, and B0D5HTW1NB (Compl. ¶22-23).
Functionality and Market Context
- The Accused Products are portable lights with a retractable rope light (Compl. ¶21). The complaint alleges that when the rope light is retracted, it is "wound around an internal hub and stowed within an internal cavity for storage" (Compl. ¶21). In this retracted state, the rope light emits "distributed illumination" rather than concentrated light, and this retraction serves only a storage function (Compl. ¶21, 23). Amazon is described as the Plaintiff's "primary sales channel in the United States" for these products (Compl. ¶12). 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 arguments for why its Accused Products do not meet the limitations of the asserted claims.
’764 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| wherein in the lantern mode, the rope light is retracted to define a concentrated area of light | The rope light is retracted into an internal cavity for storage, not to operate in a "lantern mode." This retraction results in "distributed illumination," not a "concentrated area of light." | ¶21 | col. 23:35-37 |
’764 Patent Infringement Allegations
| Claim Element (from Independent Claim 14) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| wherein in the lantern mode, the rope light is retracted within the housing | The Accused Products do not operate in a functional "lantern mode" as described in the patent. The internal retraction of the rope light is alleged to be for storage only, not for a specific mode of illumination. | ¶23 | col. 24:17-18 |
- Identified Points of Contention:
- Scope Questions: The primary dispute concerns the definition of "lantern mode." Does this term describe a functional state of providing concentrated illumination (as Plaintiff argues and the patent's embodiment in Figure 1B suggests), or can it encompass any configuration where the rope light is retracted, including for mere storage inside the housing (as Claim 14's text might suggest)?
- Technical Questions: A key factual question is whether the "distributed illumination" that results from stowing the lit rope light inside the accused product's housing could be considered a "concentrated area of light" under Claim 1. The complaint alleges the Accused Products lack optical structures like reflectors or lenses that would create such a concentrated effect (Compl. ¶21).
V. Key Claim Terms for Construction
The Term: "lantern mode"
Context and Importance: The definition of "lantern mode" is central to both infringement and validity. Plaintiff argues its products do not operate in the claimed "lantern mode" because their internal retraction is for storage, not the specific illumination function disclosed in the patent (Compl. ¶23). Practitioners may focus on this term because its construction will likely determine whether an internal-stowage configuration falls within the claim scope.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The plain language of Claim 14 recites a lantern mode where "the rope light is retracted within the housing" (’764 Patent, col. 24:17-18). This language, on its face, may be argued to cover the internal storage configuration of the Accused Products.
- Evidence for a Narrower Interpretation: The patent's abstract, summary, and figures consistently describe and depict the "lantern mode" as a configuration where the light source "is configured to wrap around an exterior of the housing" (’764 Patent, Abstract; col. 2:5-6; Fig. 1B). Plaintiff also alleges that the prosecution history of a parent application confirms this narrower, external-wrap definition (Compl. ¶19, 32).
The Term: "retracted to define a concentrated area of light"
Context and Importance: This limitation in Claim 1 introduces a functional requirement. Plaintiff's non-infringement argument hinges on its assertion that the Accused Products produce "distributed illumination" rather than a "concentrated area of light" when the rope is retracted (Compl. ¶21). The outcome of the case may turn on whether the light output from the stowed rope light meets this functional criterion.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not appear to provide an explicit definition of "concentrated area of light," which may allow for a broader, ordinary-meaning interpretation that could encompass light emitted from within the housing.
- Evidence for a Narrower Interpretation: The specification contrasts the invention with string lights that emit light over a "greater area," suggesting "concentrated" implies a localized, lantern-like emission, as depicted in Figure 1B where the light emanates from the compact, wrapped configuration on the housing's exterior (’764 Patent, col. 1:49-54; Fig. 1B).
VI. Other Allegations
- Indirect Infringement: The complaint preemptively denies any indirect infringement, stating Plaintiff has not encouraged or instructed customers to infringe and that the Accused Products are "staple articles of commerce with substantial non-infringing uses" (Compl. ¶25).
- Invalidity: Plaintiff alleges that claims 1 and 14 are invalid under 35 U.S.C. § 112(a) for lack of written description, arguing that the specification only discloses an external wrap-around "lantern mode" and does not support the broader claim language covering internal retraction (Compl. ¶31-33). It further alleges invalidity under § 103 (obviousness) in view of prior art, such as WO 2019/156973 A1 ("Jeong") (Compl. ¶35-36).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: Is the term "lantern mode" defined by the specific externally-wrapped structure and concentrated light function disclosed in the specification, as Plaintiff argues, or does the plain language of Claim 14 ("retracted within the housing") broaden its meaning to include internal storage configurations?
- A second central issue will be one of claim validity and scope: Did the patentee, by claiming a "lantern mode" involving internal retraction, impermissibly broaden the claims beyond the invention described in the specification, potentially rendering the claims invalid for lack of written description?
- A key evidentiary question will be one of functional performance: Assuming the Accused Product's storage state is deemed a "lantern mode," does the resulting internal glow "define a concentrated area of light" as required by Claim 1, or is there a fundamental mismatch in the optical result produced?