Hatch Baby Inc v. Ilovehue LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Hatch Baby, Inc. (Delaware)
  • Defendant: Ilovehue, LLC (Wyoming); Mason Rupper (California)
  • Plaintiff’s Counsel: Brooks Kushman P.C.
• Case Identification: Hatch Baby, Inc. v. Ilovehue, LLC and Mason Rupper, 2:26-cv-01370, C.D. Cal., 02/10/2026
• Venue Allegations: Plaintiff alleges venue is proper because Defendant Ilovehue, LLC, maintains its primary place of operation in Los Angeles and Defendant Mason Rupper resides in the district, where a substantial part of the alleged infringing activities occurred.
• Core Dispute: Plaintiff alleges that Defendant’s multi-function alarm clock infringes a design patent and a utility patent related to sleep-aid devices, in addition to trade dress and trademark infringement.
• Technical Context: The technology relates to integrated consumer electronic devices designed to improve sleep routines by combining features such as a sunrise alarm, sound machine, and programmable lighting.
• Key Procedural History: The complaint details pre-suit correspondence in December 2025, wherein Plaintiff’s counsel allegedly notified Defendants of their infringing activity, and Defendants denied infringement. This history may be used to support allegations of willful infringement.

I. Case Timeline

II. Technology and Patent(s)-in-Suit Analysis

I. U.S. Design Patent No. D1,060,799 - "NIGHTLIGHT"

• Patent Identification: D1,060,799, issued February 4, 2025 (’799 Patent).

I. The Invention Explained

As a design patent, the ’799 Patent protects the ornamental appearance of the nightlight article shown in its figures, not its functional or structural features D1,060,799 Patent, claim The claimed design consists of a device with a smooth, semi-arched silhouette that rises from a flat base D1,060,799 Patent, FIGS. 1, 6 The profile is tapered, with the front face being larger than the rear, and it includes specific ornamental features for buttons on its top curved surface and a switch on its side D1,060,799 Patent, FIGS. 2, 4, 5

II. Key Claims at a Glance

A design patent contains a single claim. The claim of the ’799 Patent covers the ornamental design for a nightlight as shown and described in its seven figures D1,060,799 Patent, claim

II. U.S. Patent No. 12,193,833 - "MULTI-FUNCTION DEVICE FOR IMPROVING SLEEP AND METHOD OF OPERATION THEREOF"

• Patent Identification: 12,193,833, issued January 14, 2025 (’833 Patent).

I. The Invention Explained

• Problem Addressed: The patent’s background section identifies the inconvenience and ineffectiveness of using multiple, separate devices for sleep training (e.g., nightlights, sound machines, alarm clocks), which often require manual operation in the dark, can be visually or audially disruptive, and take up significant space ’833 Patent, col. 1:12-28
• The Patented Solution: The invention is an integrated, multi-function device that combines these features into a single unit that can be controlled remotely and run automated sleep-related programs ’833 Patent, col. 1:33-42 A key technical aspect is its internal optical architecture, which uses an internal reflector to direct light from upward-facing LEDs toward a front textile panel, creating a softened, diffused light effect that mimics a sunrise or sunset ’833 Patent, abstract ’833 Patent, col. 1:57-64
• Technical Importance: This integrated design simplifies a user's sleep routine and provides a more aesthetically cohesive product compared to using multiple disparate devices, addressing a need in the consumer wellness and smart home markets ’833 Patent, col. 1:33-38

II. Key Claims at a Glance

The complaint asserts at least independent claim 10 ’833 Patent, col. 26:9-24 Compl. ¶92 The essential elements of claim 10 are:

• An outer housing and a front panel.
• A printed circuit board (PCB) configured to store a sleep-related program.
• A plurality of LEDs housed within the outer housing that face vertically upward.
• An internal reflector, shaped as a compound curve and coupled to the front panel, configured to reflect light from the LEDs toward the front panel.
• A main LED dimmer coupled to the internal reflector and positioned over the LEDs, configured to soften the light before it reaches the reflector.
• The complaint alleges infringement of at least claim 10 but does not foreclose assertion of other claims Compl. ¶92

III. The Accused Instrumentality

I. Product Identification

The accused instrumentality is an alarm clock referred to in the complaint as the "Infringing Product" and marketed by Defendants as the "ilovehue Rise" Compl. ¶¶25, 49, 52 It is allegedly sold through Defendants' websites on ilovehue.store and Shopify.com Compl. ¶26

II. Functionality and Market Context

The accused product is a multi-function alarm clock that appears to offer combined light and sound features similar to Plaintiff's Hatch Restore products Compl. ¶¶47-48 The complaint alleges that Defendants market the product as a direct, lower-cost alternative to Hatch's products, citing social media advertisements that explicitly compare the products and their prices Compl. ¶¶52-53 A screenshot of a social media advertisement allegedly shows the defendant directly comparing its product to Hatch's, stating, "Hi, I'm the ilovehue Rise and no, I don't cost $160" Compl. ¶52, p. 15 Furthermore, the complaint alleges Defendants' website uses the phrase "House of Rest" to categorize the product, which Plaintiff contends infringes its "REST®" trademark Compl. ¶55, p. 16

IV. Analysis of Infringement Allegations

I. D1,060,799 Infringement Allegations

The complaint alleges that the accused product infringes the ’799 Patent because its ornamental design is substantially the same as the patented design, such that an ordinary observer would be deceived Compl. ¶74 To support this, the complaint provides a side-by-side visual comparison of figures from the ’799 Patent with photographs of the accused product Compl. ¶75, pp. 19-20 This visual evidence highlights the similarity in the overall semi-arched shape, flat base, tapered profile, and general appearance between the patented design and the accused product.

• Identified Points of Contention: The core question for design patent infringement is whether an ordinary observer, familiar with the prior art, would believe the accused product is the same as the patented design. The analysis will focus on the overall visual impression. Defendants may argue that differences in button placement, surface texture, or specific proportions are significant enough to distinguish the products in the mind of an ordinary observer.

II. 12,193,833 Infringement Allegations

The complaint alleges that the accused product satisfies all limitations of at least claim 10 of the ’833 Patent Compl. ¶92 The complaint states that a claim chart comparing claim 10 to the accused product is attached as Exhibit 8; however, this exhibit was not included with the filed complaint Compl. ¶92 The narrative infringement theory suggests that the accused product incorporates the same internal architecture claimed in the ’833 Patent, including upward-facing LEDs, a distinct internal reflector with a compound curve that directs light, and a physical dimmer component that softens the light before reflection ’833 Patent, col. 26:9-24

• Identified Points of Contention: Since the complaint lacks a teardown or other direct evidence of the accused product's internal construction, a primary dispute will be evidentiary. The key questions are factual: does the accused product actually contain an internal structure with vertically oriented LEDs, a distinct component functioning as an "internal reflector" with a "compound curve," and a separate "main LED dimmer" positioned over the LEDs? The litigation will likely require discovery and expert analysis to determine if the accused product’s internal optical system operates in the manner required by the claim language.

V. Key Claim Terms for Construction

For the ’833 Patent, the construction of several terms in independent claim 10 may be dispositive.

• The Term: "internal reflector"

• Context and Importance: This term is central to the claimed optical system. Whether the accused product contains a structure that meets the definition of an "internal reflector" will be a key point of contention. Practitioners may focus on this term because Defendants could argue that any light-reflecting surface in their product is merely an integral part of the housing and not a distinct "reflector" component as claimed.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim defines the term by its function: "configured to reflect light generated by the plurality of LEDs towards the front textile" ’833 Patent, col. 26:17-19 This functional language could support an interpretation where any internal surface that performs this role qualifies.
  • Evidence for a Narrower Interpretation: The figures depict the reflector as a discrete component (e.g., element 138 in FIG. 1) ’833 Patent, FIG. 1 The specification describes it as having a "compound curve shape" and features like "shelves to accommodate the main LED dimmer" ’833 Patent, col. 10:52-53 ’833 Patent, col. 10:64-66 This could support a narrower construction requiring a separate component with specific geometric properties.

• The Term: "main LED dimmer"

• Context and Importance: This term describes another critical component of the claimed light-softening mechanism. Its construction is important because the accused product may achieve a dimming or diffusing effect through other means (e.g., software-controlled LEDs, a diffusing front panel) without using a component that meets this definition.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim defines the dimmer by its function: "configured to soften light generated by the plurality of LEDs before the light reaches the internal reflector" ’833 Patent, col. 26:22-24 This may support construing any physical element that performs this pre-reflection softening function as a "dimmer."
  • Evidence for a Narrower Interpretation: The specification describes the dimmer as a physical component "positioned vertically over the main LED board" and potentially made of "clear plastic" with "surface features or textures configured to diffuse light" ’833 Patent, col. 9:30-31 ’833 Patent, col. 9:38-46 This language could support a narrower definition requiring a distinct, textured plastic shield placed between the LEDs and the reflector.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendants induce infringement of the ’833 Patent by knowingly encouraging and instructing customers to use the accused product in an infringing manner Compl. ¶91
• Willful Infringement: Willfulness is alleged for both patents. For the ’799 Patent, the allegation is based on Defendants’ alleged continued sales after receiving pre-suit notice of infringement from Plaintiff's counsel in December 2025 Compl. ¶¶68-71, 77 For the ’833 Patent, the allegation is based on knowledge of infringement at least from the filing of the complaint Compl. ¶91 The prayer for relief requests treble damages based on willful infringement Compl. ¶2.6

VII. Analyst’s Conclusion: Key Questions for the Case

• A central issue for the design patent claim will be one of visual identity: will an ordinary observer, taking into account the prior art, find the overall ornamental appearance of the accused "ilovehue Rise" to be substantially the same as the design claimed in the ’799 Patent, despite any minor differences in button configuration or materials?
• For the utility patent claim, the case will likely turn on claim construction and evidentiary proof: does the accused product's internal architecture contain distinct components that meet the definitions of an "internal reflector" and a "main LED dimmer" as required by claim 10, or does it achieve a similar lighting effect through a fundamentally different mechanical and optical arrangement?
• Underlying both infringement counts is a question of intent: does the evidence of alleged direct copying, including advertisements that explicitly reference Hatch's products and pricing, support a finding of willful infringement and potentially impact damages or a finding of an exceptional case?