Pro Lite Inc v. Green Light Innovations Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Pro-Lite, Inc. (California)
  • Defendant: Green Light Innovations, Inc. (Missouri)
  • Plaintiff's Counsel: Mandour & Associates, APC
• Case Identification: 2:26-cv-03159, C.D. Cal., 03/24/2026
• Venue Allegations: Plaintiff alleges venue is proper because Defendant conducts business in the district, sells products to residents of the district, and has engaged in enforcement activities pertaining to the patent-in-suit within the district.
• Core Dispute: Plaintiff seeks a declaratory judgment that its LED signage products do not infringe Defendant's patent related to illuminated signs and that the patent is invalid.
• Technical Context: The dispute concerns LED-based illuminated signs designed to display messages (e.g., "OPEN") with multiple distinct, colored sections, such as colored text and a differently colored border.
• Key Procedural History: The action was prompted by Defendant's complaints to Amazon.com, Inc., alleging that Plaintiff's products infringed the patent-in-suit, which resulted in Amazon suspending sales of Plaintiff's products. The complaint also raises an invalidity challenge based on alleged public use of an accused product prior to the patent's priority date.

Case Timeline

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

U.S. Patent No. 9,153,150 - Lighting Assembly Having Enhanced Visual Appearance

• Patent Identification: U.S. Patent No. 9,153,150, issued October 6, 2015 (the "'150 Patent").

The Invention Explained

• Problem Addressed: The patent addresses the problem of "undesired lighting effects" that occur when different colored light sources, such as LEDs, are used in the same illuminated sign '150 Patent, col. 1:26-30 Specifically, light from one colored section can "interfere or 'bleed'" into an adjacent section of a different color, diminishing the sign's visual clarity and appeal '150 Patent, col. 1:28-30
• The Patented Solution: The invention is a lighting assembly with at least two different light sources and corresponding translucent covers (e.g., one for the text, one for the border) housed within an assembly '150 Patent, abstract The key feature is a "light barrier" physically disposed between the different covers, which is "configured to prevent interference" between the light sources, thereby ensuring that each colored section remains visually distinct '150 Patent, abstract '150 Patent, col. 6:4-8 Figures 2 and 3 illustrate the separate covers and the housing structure that includes these barriers '150 Patent, Fig. 2 '150 Patent, Fig. 3
• Technical Importance: The described solution aims to allow cost-effective LEDs to replicate the sharp, multi-colored look of traditional neon signs without the associated light bleed problems.

Key Claims at a Glance

• The complaint alleges non-infringement of "one or more of the claims" of the '150 Patent without specifying which claims were asserted by the Defendant Compl. ¶11 Independent claim 1 is representative of the core invention.
• Independent Claim 1:
  • a housing assembly;
  • a first light source located within the housing assembly;
  • a second light source located within the housing assembly;
  • a first cover positioned relative to the first light source so that the first light source is able to illuminate the first cover;
  • a second cover positioned separately from the first cover and relative to the second light source so that the second light source is able to illuminate the second cover; and
  • a light barrier disposed between the first and second covers, the light barrier being configured to prevent interference between the first light source and the second light source.

III. The Accused Instrumentality

Product Identification

• The complaint identifies "signage with LED lighting" sold by Plaintiff Pro-Lite on Amazon.com under several Amazon Standard Identification Numbers (ASINs), including BOC31SP22Z and B07C5J9CGP, among others (the "Accused Products") Compl. ¶10

Functionality and Market Context

• The Accused Products are illuminated signs, and the complaint includes a photograph of a representative product: an "OPEN" sign with illuminated lettering and a surrounding illuminated border Compl. Ex. B The complaint alleges that one of the Accused Products has been in public use since at least October 20, 2009 Compl. ¶13 The dispute arose after Defendant's infringement complaints to Amazon led to the suspension of sales of the Accused Products Compl. ¶11 The complaint provides a photograph, dated October 20, 2009, of an illuminated 'OPEN' sign at what appears to be a trade show booth, which Plaintiff identifies as one of the Accused Products in public use Compl. ¶14 Compl. Ex. B

IV. Analysis of Infringement Allegations

This is a declaratory judgment action for non-infringement. The following chart summarizes the infringement theory that Plaintiff Pro-Lite seeks to rebut, based on the elements of Claim 1 of the '150 Patent. The complaint's specific non-infringement argument focuses on the "light barrier" element.

'150 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: The complaint raises a critical claim construction question: Does the claimed "light barrier" have to be a component that is "distinct and separate from the 'housing assembly'"? Compl. ¶12 Plaintiff's core non-infringement argument rests on the premise that its products do not have such a separate barrier Compl. ¶12 This suggests the dispositive issue may be whether an internal wall that is molded as a single piece with the housing (i.e., is "integral" to it) can satisfy the "light barrier" limitation, which is listed separately from the "housing assembly" limitation in the claim.
• Technical Questions: A related factual question for the court will be to examine the physical construction of the Accused Products to determine if any structure performs the function of a light barrier and, if so, whether that structure is part of what would be considered the "housing assembly."

V. Key Claim Terms for Construction

• The Term: "light barrier"
• Context and Importance: This term is the foundation of Plaintiff's non-infringement argument Compl. ¶12 The definition of whether a "light barrier" can be integral with the "housing assembly" or must be a structurally separate element will likely be determinative of infringement.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent specification appears to support a broader definition, explicitly stating that "the light barriers 318, 320, 322 are integrally formed as part of the housing compartment 114" '150 Patent, col. 4:7-9 Defendant may argue this passage demonstrates that the inventor contemplated the barrier and housing being a single, unitary piece.
  • Evidence for a Narrower Interpretation: Plaintiff argues the claim language itself implies separation by listing "a housing assembly" and "a light barrier" as distinct elements in Claim 1 '150 Patent, col. 13:19 '150 Patent, col. 13:28 Plaintiff may argue that under the doctrine of claim differentiation, these separately listed elements must be interpreted as structurally distinct entities.

VI. Other Allegations

The complaint is a declaratory judgment action filed by the accused infringer and thus does not contain allegations of infringement against the defendant.

• Invalidity: Plaintiff asserts that the '150 Patent is invalid under 35 U.S.C. §§ 101, 102, 103, and 112 Compl. ¶8 Compl. ¶21 The complaint specifically alleges that an Accused Product "has been in public use since at least as early as October 20, 2009," which anticipates the claims of the '150 Patent pursuant to 35 U.S.C. § 102 Compl. ¶13 The patent's earliest priority date is June 14, 2013.

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

• A core issue will be one of claim construction: Does the term "light barrier," listed as a separate element from the "housing assembly" in Claim 1, require a structurally distinct component, or can it be construed to cover a barrier that is "integrally formed" as part of the housing, as described in the patent's specification? The answer may resolve the central infringement dispute.
• A second key issue will be one of invalidity based on prior public use: Can Plaintiff provide sufficient evidence to prove that its own product was in public use or on sale before the patent's June 14, 2013 priority date, and if so, does that prior art product contain all the elements of the asserted claims, thereby rendering the '150 Patent invalid?