HK Gelite Intelligent Technology Ltd v. Jolux Lighting LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: HK Gelite Intelligent Technology Ltd. (China)
  • Defendant: Jolux Lighting LLC (Wyoming) and Fujian YDJ Light Co., Ltd. (China)
  • Plaintiff’s Counsel: THE GIKKAS LAW FIRM, P.C.
• Case Identification: 2:26-cv-01399, C.D. Cal., 02/10/2026
• Venue Allegations: Plaintiff HK Gelite alleges venue is proper because Defendants directed their patent enforcement campaign into the district by filing an infringement complaint with Amazon.com, which operates fulfillment centers within the district where the accused products are stored and shipped.
• Core Dispute: Plaintiff seeks a declaratory judgment that its lamp products do not infringe Defendant's patent for a multi-stage adjustable telescopic lamp, following Defendants' use of Amazon's intellectual property complaint process to have Plaintiff's products removed from the platform.
• Technical Context: The dispute centers on mechanical adjustment features for lighting products, specifically those designed to be retrofitted into suspended or recessed fixtures of varying depths and requiring adjustable illumination angles.
• Key Procedural History: The complaint states that Defendants initiated an enforcement action through the Amazon Patent Evaluation Program (APEX), leading to the deactivation of Plaintiff’s product listings and the quarantine of its inventory. Plaintiff alleges its attempts to resolve the dispute were rebuffed.

Case Timeline

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

U.S. Patent No. 12,455,066 - “MULTI-STAGE ADJUSTABLE TELESCOPIC LAMP”

• Patent Identification: U.S. Patent No. 12,455,066, titled “MULTI-STAGE ADJUSTABLE TELESCOPIC LAMP,” issued on October 28, 2025.

The Invention Explained

• Problem Addressed: The patent’s background section identifies shortcomings in existing telescopic lamps, noting they are often insufficient for replacing lights in deep suspended fixtures due to a limited adjustment range and that their fixed irradiation angles fail to meet user needs (’066 Patent, col. 1:24-34).
• The Patented Solution: The invention discloses a lamp with a three-stage telescopic structure, formed by three nested and slidingly engaged "telescopic sleeves," to provide a greater range of length adjustment (’066 Patent, col. 1:40-43; ’066 Patent, col. 5:1-12). To address the problem of fixed angles, the invention includes a "rotatable component" that connects the lamp body to an outer frame, allowing the lamp to be tilted to adjust the angle of illumination (’066 Patent, col. 1:59-62; ’066 Patent, abstract).
• Technical Importance: The claimed combination of extended telescopic reach and angular adjustability is presented as a solution for improving the versatility and applicability of retrofit lamps in a wider variety of architectural lighting scenarios (’066 Patent, col. 2:37-43).

Key Claims at a Glance

• The complaint seeks a declaratory judgment of non-infringement as to Claims 1-9 (Compl. ¶¶23-24).
• Independent Claim 1, a representative claim, requires, among other elements:
  • A screw base, a first telescopic sleeve, a second telescopic sleeve, a third telescopic sleeve, a fixed component, an outer frame, a lighting unit, and a lamp body
  • The three telescopic sleeves being "slidingly sleeved" with one another
  • A fixed component for limiting the stretch length of the telescopic light
  • An outer frame connected to the lamp body "by means of a rotatable component"
  • A top of the outer frame connected to a bottom of the third telescopic sleeve
• The complaint does not explicitly reserve the right to assert dependent claims, as it is a complaint for declaratory judgment of non-infringement.

III. The Accused Instrumentality

Product Identification

• The complaint identifies the accused products by their Amazon Standard Identification Numbers (ASINs): B0F48HP748, B0DQLCBP79, B0F7XWY6HV, and B0F7XVQDN1 (Compl. ¶10).

Functionality and Market Context

• The complaint describes the products as "lamp products" sold on the Amazon storefront (Compl. ¶¶8, 21). The pleading focuses on what the products allegedly lack rather than their specific functionalities. It asserts that certain products "lack three telescopic sleeves" and that all accused products "lack a rotatable component" (Compl. ¶¶23-24). These products are alleged to account for a "significant portion of Plaintiff's business" (Compl. ¶10). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment that the Plaintiff's products do not infringe the ’066 Patent. The core of its non-infringement theory is that the Accused Products are missing at least two required elements of the asserted claims. The complaint states that non-infringement charts were provided to Amazon, but these charts were not attached as exhibits (Compl. ¶11).

’066 Patent Infringement Allegations

• Identified Points of Contention:
  • Factual Questions: The primary dispute appears to be factual: do the Accused Products physically contain the structures required by the claims? The case will likely require discovery and expert testimony to determine if the products possess (1) a three-sleeve telescopic mechanism and (2) a component that allows for rotation between the lamp body and an outer frame.
  • Scope Questions: Should the accused products contain mechanisms that allow for some length or angle adjustment, a key question will be whether those mechanisms fall within the scope of the claim terms "telescopic sleeve" and "rotatable component" as defined by the patent.

V. Key Claim Terms for Construction

• The Term: "rotatable component"

• Context and Importance: This term is critical because Plaintiff alleges its complete absence in all Accused Products (Compl. ¶24). The patent holders will likely argue for a broad interpretation covering any mechanism that allows angular adjustment, while the Plaintiff will argue for a narrower definition that its products do not meet.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification describes the function of the rotatable component as allowing the lamp body "to be deflected within the outer frame, which can change illumination angles" (’066 Patent, col. 5:19-22). This functional language could support an interpretation that covers any means for achieving this result.
  • Evidence for a Narrower Interpretation: The patent discloses specific structures for the "rotatable component," such as one comprising an "annular flange" and "annular groove" (’066 Patent, col. 2:18-20) or another comprising "rotation shafts disposed on both sides of a center cavity of the outer frame" (’066 Patent, col. 2:23-26; ’066 Patent, claim 8). Plaintiff may argue these embodiments limit the term's scope to these specific mechanical implementations.

• The Term: "telescopic sleeve"

• Context and Importance: Plaintiff's non-infringement argument for two of its products rests on them lacking the required "three telescopic sleeves" (Compl. ¶23). The definition of what constitutes a distinct "sleeve" will be central to this analysis.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent repeatedly describes the sleeves in functional terms, stating that the first is "slidingly sleeved with the second" and the second is "slidingly sleeved with the third" (’066 Patent, col. 5:1-4). This could support construing any nested, sliding cylindrical parts as "telescopic sleeves."
  • Evidence for a Narrower Interpretation: The patent figures depict three visually distinct, concentric cylindrical tubes (’066 Patent, Fig. 2; ’066 Patent, Fig. 5). An argument could be made that the term requires separate and discrete components corresponding to these depictions, potentially excluding integrated or two-part adjustment mechanisms.

VI. Other Allegations

• Indirect Infringement: The complaint seeks a judgment that Plaintiff has not infringed "directly or indirectly" (Compl., p. 11, Prayer A). It does not, however, detail any specific allegations of indirect infringement made by the Defendants. The complaint asserts that Defendants "know or should have known that the Accused Products do not infringe" (Compl. ¶28), framing Defendants' enforcement actions as improper.
• Willful Infringement: This section is not applicable, as the complaint is for a declaratory judgment of non-infringement, and thus there is no allegation of willful infringement against the Plaintiff.

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

This declaratory judgment action appears to hinge on a straightforward, fact-intensive non-infringement defense. The central questions for the court will likely be:

• A primary question of factual existence: Does discovery and inspection of the Accused Products confirm Plaintiff’s assertion that they lack a "rotatable component" and, in some cases, the "three telescopic sleeves" required by the asserted claims? The outcome may depend heavily on simple evidentiary proof.
• A secondary question of definitional scope: If the Accused Products contain any mechanism for adjusting length or angle, the core legal issue will become one of claim construction. Can the term "rotatable component," as described in the specification, be construed broadly to cover the accused mechanisms, or is its meaning limited by the specific embodiments disclosed in the patent?