DCT
2:26-cv-00159
Shenzhen Lepeng Supply Chain Co Ltd v. Arthur Chao Chung Wu
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Shenzhen Lepeng Supply Chain Co., Ltd. (People's Republic of China)
- Defendant: Arthur Chao-Chung Wu (United States)
- Plaintiff’s Counsel: Glacier Law LLP
- Case Identification: 2:26-cv-00159, W.D. Wash., 01/15/2026
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Washington because the defendant directed patent enforcement activities into the district, specifically by initiating an Amazon patent-enforcement proceeding that 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 Defendant’s patent related to a convertible light device, and further alleges the patent is invalid.
- Technical Context: The dispute centers on portable, battery-powered lighting devices capable of converting between a wide-area "rope light" configuration and a concentrated "lantern" configuration for camping and other outdoor activities.
- Key Procedural History: The action was precipitated by Defendant's enforcement of the patent-in-suit through Amazon's intellectual property reporting system, which resulted in the removal of Plaintiff's product listings. The complaint notes that the patent-in-suit is a continuation of a prior patent whose prosecution history allegedly tied the key "lantern mode" concept to an exterior wrap-around configuration.
Case Timeline
| Date | Event |
|---|---|
| 2020-06-15 | Earliest Priority Date ('764 Patent) |
| 2025-04-22 | U.S. Patent No. 12,281,764 Issues |
| 2026-01-14 | Amazon Notifies Plaintiff of Product Listing Removal |
| 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's background section identifies a need for improved portable lighting. It notes that existing portable lights either emit from a single concentrated area or, in the case of battery-powered string lights, are often decorative and not bright enough for practical use, while brighter string lights typically require an external power source (’764 Patent, col. 1:44-62).
- The Patented Solution: The invention is a self-contained, convertible light device with a housing, an internal battery pack, and an "elongate flexible light source" (i.e., a rope light). The device is designed to operate in two primary modes: a "rope mode," where the light source extends from the housing to illuminate a large area, and a "lantern mode," where the light source is wrapped around the housing's exterior to provide concentrated light (’764 Patent, Abstract; col. 2:3-9; Figs. 1A-1B).
- Technical Importance: The claimed invention seeks to combine the broad, consistent illumination of a string light with the focused, area lighting of a lantern into a single, portable, battery-powered device (’764 Patent, col. 1:57-62).
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.
- In the lantern mode, the rope light is retracted to define a concentrated area of light.
- 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.
- In the lantern mode, the rope light is retracted within the housing.
- 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" sold on Amazon.com under ASINs B0DGQ3CWS5 and B0D5HTW1NB (the "Accused Products") (Compl. ¶¶8, 22).
Functionality and Market Context
- The complaint describes the Accused Products as featuring a rope light that, when retracted, is "wound around an internal hub and stowed within an internal cavity for storage" (Compl. ¶21).
- It is alleged that when the rope light is retracted in this manner, it continues to emit light along its length, resulting in "distributed illumination" rather than a concentrated light source (Compl. ¶¶21-22).
- Plaintiff alleges that Amazon is its primary sales channel in the United States and that the removal of its listings has caused significant harm to its business (Compl. ¶¶11-12).
- No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
’764 Patent Infringement Allegations (Claim 1)
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a device comprising: a housing; and a rope light coupled to the housing | The Accused Products are described as having these components. | ¶8 | col. 2:63-64 |
| wherein the device is configured to convert between a rope mode and a lantern mode | The complaint does not contest this element directly but disputes the definition of "lantern mode" as applied to the Accused Products. | ¶23 | col. 23:33-35 |
| wherein in the lantern mode, the rope light is retracted to define a concentrated area of light | Plaintiff alleges its products retract the rope light into an internal cavity for storage, resulting in "distributed illumination" and not a "concentrated area of light." It further alleges the products lack optical structures to focus light. | ¶¶21-22 | col. 23:36-38 |
| and wherein in the rope mode, the rope light extends from the housing. | The complaint implies the Accused Products have an extended rope mode but does not provide specific details. | ¶¶8, 21 | col. 23:39-40 |
’764 Patent Infringement Allegations (Claim 14)
| Claim Element (from Independent Claim 14) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a device comprising: a housing; and a rope light coupled to the housing | The Accused Products are described as having these components. | ¶8 | col. 2:63-64 |
| wherein the device is configured to convert between a rope mode and a lantern mode | Plaintiff argues that the internal retraction in its products is for storage only and does not constitute the functional "lantern mode" described in the patent specification. | ¶23 | col. 24:26-28 |
| wherein in the lantern mode, the rope light is retracted within the housing | While the Accused Products retract the rope light internally, Plaintiff alleges this is a storage configuration, not the claimed functional "lantern mode." | ¶23 | col. 24:29-30 |
| and wherein in the rope mode, the rope light extends from the housing. | The complaint implies the Accused Products have an extended rope mode but does not provide specific details. | ¶¶8, 21 | col. 24:31-32 |
Identified Points of Contention
- Scope Questions: The central dispute concerns the scope of the term "lantern mode." The complaint raises the question of whether this term is limited to the external wrap-around configuration shown in the patent's figures and allegedly described during prosecution, or if it can also read on the internal storage configuration of the Accused Products (Compl. ¶¶19, 23, 32). A related question is whether "retracted within the housing" for storage purposes satisfies a functional claim limitation tied to a specific "mode" of operation (Compl. ¶23).
- Technical Questions: A key factual question is whether the Accused Products' internal stowage of an illuminated rope light creates a "concentrated area of light" as required by Claim 1. The complaint alleges it produces "distributed illumination" and lacks focusing optics, suggesting a potential mismatch in technical operation (Compl. ¶¶21-22).
V. Key Claim Terms for Construction
The Term: "lantern mode"
- Context and Importance: This term is the focal point of the non-infringement argument. The definition will determine whether the Accused Products' internal storage configuration can be considered to practice the claimed invention. Practitioners may focus on this term because the complaint alleges a divergence between the specification's embodiments and the literal claim language (Compl. ¶¶19, 31-33).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The plain language of Claim 14 explicitly recites a lantern mode where "the rope light is retracted within the housing" (’764 Patent, col. 24:29-30). This language could be argued to support a definition that is not limited to external wrapping.
- Evidence for a Narrower Interpretation: The complaint alleges the specification consistently describes the "lantern mode" as an external configuration where the light source is "configured to wrap around an exterior of the housing" (’764 Patent, col. 2:4-7; Fig. 1B; Compl. ¶¶19, 32). The complaint also points to prosecution history that allegedly tied the term to this external configuration (Compl. ¶¶19, 34).
The Term: "a concentrated area of light"
- Context and Importance: This term in Claim 1 is presented as a functional result of retraction. Its construction is critical because the plaintiff alleges its products create the opposite effect: "distributed illumination" (Compl. ¶¶21-22). The case may turn on what degree of light convergence is required to meet this limitation.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not appear to provide a specific quantitative definition of "concentrated," which may allow for a range of interpretations based on the plain and ordinary meaning of the term.
- Evidence for a Narrower Interpretation: The patent’s background distinguishes the invention from prior art that emits light "from a single concentrated area" but notes the invention provides "more consistent light emission" than such devices (’764 Patent, col. 1:46-53). Figure 1B illustrates the lantern mode as providing general, localized illumination from the housing's exterior, which could be argued to support a definition that requires more than incidental light emission from an internally stowed rope.
VI. Other Allegations
Indirect Infringement
- This is a declaratory judgment action. The plaintiff preemptively denies indirect infringement, stating it has not encouraged, instructed, or intended for any customer to practice the claimed invention, and that the Accused Products are staple articles of commerce with substantial non-infringing uses (Compl. ¶25).
Willful Infringement
- The complaint does not allege willful infringement by the Defendant. Rather, in its prayer for relief, it seeks enhanced damages based on the "willful and exceptional nature of the case," which appears to relate to the defendant's allegedly improper enforcement actions via Amazon, not patent infringement itself (Compl. p. 11, ¶D).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: Is the term "lantern mode," as used in the claims, limited to the externally-wrapped configuration consistently described and illustrated in the patent’s specification, or does the claim language reciting internal retraction broaden its scope to cover the Accused Products' storage configuration? The complaint's invocation of prosecution history suggests this may be a central claim construction and validity (written description) dispute.
- A second key issue will be one of functional performance: Does retracting an illuminated rope light into a housing, as the Accused Products allegedly do for storage, necessarily create "a concentrated area of light" as required by Claim 1? This raises an evidentiary question about the actual optical output of the Accused Products versus the functional requirements of the claim.
- A third question relates to validity: The complaint raises a significant written description challenge, questioning whether the inventors possessed an invention where the "lantern mode" is achieved by retracting the rope light within the housing at the time of filing, given that the specification allegedly only discloses an external wrap-around embodiment for that mode (Compl. ¶¶31-33).