DCT
2:26-cv-00158
Guangzhou Zhongyao Technology Co Ltd v. Arthur Chao Chung Wu
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Guangzhou Zhongyao Technology Co., Ltd. (People's Republic of China)
- Defendant: Arthur Chao-Chung Wu (Nevada, United States)
- Plaintiff’s Counsel: Glacier Law LLP
- Case Identification: 2:26-cv-00158, W.D. Wash., 01/15/2026
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Washington because the Defendant purposefully directed patent enforcement activities into the district by initiating an Amazon patent-infringement proceeding, which foreseeably caused actions by Amazon personnel located in Seattle, leading to the removal of Plaintiff's product listing.
- Core Dispute: Plaintiff seeks a declaratory judgment that its camping string light products do not infringe Defendant's patent related to a convertible light device, and further alleges that the patent is invalid.
- Technical Context: The technology relates to portable, multi-function LED lighting devices designed for camping and other recreational activities, a segment of the consumer electronics market characterized by feature-driven competition.
- Key Procedural History: This action was precipitated by Defendant's extra-judicial enforcement of the patent-in-suit through Amazon's patent-infringement reporting system, which resulted in the removal of Plaintiff's product listing. The complaint also references the prosecution history of a parent patent application, alleging it created a narrow definition for a key claim term.
Case Timeline
| Date | Event |
|---|---|
| 2020-06-15 | U.S. Patent No. 12,281,764 Priority Date |
| 2025-04-22 | U.S. Patent No. 12,281,764 Issues |
| 2026-01-14 | Amazon removes Plaintiff's product listing |
| 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"*
- Patent Identification: U.S. Patent No. 12,281,764, "Convertible light device," issued April 22, 2025 (’764 Patent).
The Invention Explained
- Problem Addressed: The patent background describes a need for improved portable lighting that combines the ability to illuminate a large area with consistent brightness, like string lights, with the portability and self-contained power of traditional lanterns or flashlights, which typically emit light from a single concentrated area (Compl. ¶14; ’764 Patent, col. 1:36-62).
- The Patented Solution: The invention is a "convertible light device" comprising a main housing containing a battery pack and an "elongate flexible light source" (a rope light with multiple LEDs) that is detachably coupled to the housing (’764 Patent, Abstract). The device is designed to operate in two primary configurations: a "rope mode," where the light source extends from the housing to illuminate a wide area, and a "lantern mode," where the light source is configured to wrap around the exterior of the housing to provide more concentrated light (’764 Patent, Abstract; col. 2:3-8). This dual-mode functionality is illustrated in Figures 1A and 1B of the patent (’764 Patent, col. 5:1-4).
- Technical Importance: The claimed invention provides a single, battery-powered device that offers the distinct functionalities of both a wide-area string light and a localized lantern, enhancing versatility for outdoor and recreational use (’764 Patent, col. 1:36-41).
Key Claims at a Glance
- The complaint asserts non-infringement of independent claims 1 and 14 (Compl. ¶¶21, 23).
- Independent Claim 1: A device comprising:
- a housing; and
- a rope light coupled to the housing,
- wherein 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,
- wherein 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 argues that because the independent claims are not infringed, the dependent claims that incorporate their limitations are also not infringed (Compl. ¶24).
III. The Accused Instrumentality
Product Identification
- Plaintiff's "camping string light products" sold on Amazon.com under ASIN B0DGQ3CWS5 (Compl. ¶¶5, 8, 22).
Functionality and Market Context
- The complaint describes the accused products as camping string lights that feature a retractable rope light (Compl. ¶¶8, 21). When the rope light is retracted, it is "wound around an internal hub and stowed within an internal cavity for storage" (Compl. ¶21).
- Plaintiff alleges this internal retraction results in "distributed illumination rather than a concentrated area of light" and that the products lack optical structures such as reflectors or lenses to focus the light (Compl. ¶21). The complaint characterizes this retracted state as a "storage function only," distinct from a functional operating mode (Compl. ¶23).
- The complaint alleges that Amazon is the Plaintiff's primary U.S. sales channel, making the product's listing on the platform critical to its business (Compl. ¶12).
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint.
The complaint presents arguments for a declaration of non-infringement. The following table summarizes the Plaintiff's non-infringement positions with respect to the asserted independent claims.
’764 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| in the lantern mode, the rope light is retracted to define a concentrated area of light | Plaintiff alleges its product's rope light retracts into an internal cavity for storage, producing distributed, unfocused illumination, not a "concentrated area of light." | ¶21 | col. 23:37-39 |
| Claim Element (from Independent Claim 14) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| in the lantern mode, the rope light is retracted within the housing | Plaintiff alleges its product does not operate in the claimed "lantern mode," which it contends the patent specification defines as an external wrap-around configuration for illumination, not an internal configuration for storage. | ¶23 | col. 24:19-20 |
- Identified Points of Contention:
- Scope Questions: A central dispute concerns the definition of "lantern mode." The complaint alleges the patent's specification and prosecution history consistently describe this mode as an external wrap-around configuration that produces concentrated light (Compl. ¶¶19, 32). This raises the question of whether Claim 14's explicit recitation of a mode where the rope light is "retracted within the housing" is supported by the specification or should be limited by the embodiments disclosed.
- Technical Questions: The non-infringement argument for Claim 1 hinges on a functional, result-oriented limitation. This raises the factual question of whether the accused product, when its rope light is stowed internally, actually produces a "concentrated area of light" as required by the claim, or if it produces the "distributed illumination" alleged in the complaint (Compl. ¶21).
V. Key Claim Terms for Construction
- The Term: "lantern mode"
- Context and Importance: The definition of this term is dispositive for both asserted independent claims. Plaintiff's core argument is that its product's internal storage configuration does not constitute the claimed "lantern mode" (Compl. ¶23). Practitioners may focus on this term because its interpretation appears to create tension between the broad language of Claim 14 ("retracted within the housing") and the specific embodiments described in the patent's specification.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The plain language of Claim 14 itself defines a "lantern mode" as a configuration where "the rope light is retracted within the housing" (’764 Patent, col. 24:19-20). A defendant may argue this language is clear and controlling, regardless of the specific examples shown in the figures.
- Evidence for a Narrower Interpretation: The complaint alleges the specification consistently discloses the lantern mode as an external configuration. For example, the Summary section states that "in the lantern mode, the elongate flexible light source is configured to wrap around an exterior of the housing" (’764 Patent, col. 2:4-7; Compl. ¶32). The abstract and Figure 1B also depict this external arrangement (’764 Patent, Abstract; Compl. ¶19). Plaintiff leverages this to argue the term is limited to this disclosed external configuration.
VI. Other Allegations
- Indirect Infringement: The complaint affirmatively pleads that Plaintiff has not induced or contributorily infringed, stating it has not encouraged or instructed any customer to practice the claimed elements and that the accused products are staple articles of commerce with substantial non-infringing uses (Compl. ¶25).
- Invalidity: Plaintiff asserts in Count II that Claims 1 and 14 are invalid on several grounds:
- Lack of Written Description (35 U.S.C. § 112(a)): The complaint alleges that because the specification only describes a "lantern mode" where the rope light wraps around the exterior of the housing, the claims reciting a mode where the light is "retracted within the housing" are invalid for claiming subject matter the inventors did not possess at the time of filing (Compl. ¶¶31-33).
- Obviousness (35 U.S.C. § 103): The complaint alleges the claimed invention would have been obvious to a person of ordinary skill in the art in view of prior art, specifically citing WO Patent Publication No. 2019/156973 ("Jeong") in combination with common knowledge regarding portable lighting devices (Compl. ¶¶35-38).
- Indefiniteness (35 U.S.C. § 112(b)): The complaint alleges the term "lantern mode" lacks reasonable certainty due to what it characterizes as the specification's "inconsistent treatment of internal and external rope-light arrangements" (Compl. ¶44).
VII. Analyst’s Conclusion: Key Questions for the Case
This declaratory judgment action appears poised to center on the interplay between claim language and the supporting disclosure in the patent specification. The resolution of the dispute may depend on the court's answers to the following key questions:
- A core issue will be one of claim construction and written description: Can the term "lantern mode" be broadly construed to encompass the "retracted within the housing" configuration explicitly recited in Claim 14, or will the court limit the term's scope to the external wrap-around embodiment consistently described in the specification, potentially invalidating the claim for lack of written description?
- A key evidentiary question will be one of functional performance: Does the accused product's internal storage configuration, which Plaintiff alleges produces "distributed" light, achieve the functional result of defining a "concentrated area of light" as required by Claim 1? This determination will likely require expert testimony and empirical evidence comparing the light output of the device in its different states.
- A central validity question will be obviousness: Does the cited "Jeong" prior art, combined with the general knowledge of a skilled artisan, disclose the claimed combination of a housing with a convertible rope/string light, such that the asserted claims would have been an obvious design choice?