Leedarson America Inc v. DS Advanced Enterprisesss Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Leedarson America, Inc. (Georgia), Leedarson Lighting Co., Ltd. (China), and Leedarson IoT Technology (Thailand) Co., Ltd. (Thailand)
  • Defendant: DS Advanced Enterprises, Ltd. (Canada)
  • Plaintiff's Counsel: Steptoe LLP
• Case Identification: 1:26-cv-01777, N.D. Ga., 04/02/2026
• Venue Allegations: Plaintiff asserts venue is proper in the Northern District of Georgia because Plaintiff Leedarson America has its principal place of business in the district, Defendant has previously enforced its patent rights in the district, and a substantial part of the events giving rise to the dispute occurred in the district.
• Core Dispute: Plaintiff seeks a declaratory judgment that its lighting products do not infringe Defendant's patents related to versatile mounting mechanisms for lighting fixtures, and that those patents are invalid.
• Technical Context: The technology concerns lighting fixture hardware designed to be compatible with multiple installation scenarios, such as retrofitting into existing recessed housings, new construction installations, and mounting to electrical outlet boxes.
• Key Procedural History: This declaratory judgment action follows the lawsuit DS Advanced Enterprises (DSAE) v. The Home Depot in the Southern District of Ohio, which accuses Home Depot of infringing the same patents by selling products manufactured by Plaintiff Leedarson. DSAE has also previously litigated one of the patents-in-suit, U.S. Patent No. 11054118, in this district.

Case Timeline

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

U.S. Patent No. 12,359,783 - "System and apparatus to attach a light fixture to one of a ceiling, a recessed lighting fixture housing, or an outlet box or a junction box"

Issued July 15, 2025

The Invention Explained

• Problem Addressed: The patent's background describes the inefficiency and increased cost for lighting distributors and installers who must stock and manage different types of light fixtures for different installation environments, namely new construction, retrofit, and electrical outlet box installations ʼ783 Patent, col. 1:37-52
• The Patented Solution: The invention is a single, adaptable light fixture apparatus that can be installed in three distinct scenarios. It includes a first set of clips for mounting in an existing recessed housing, a second, different set of clips for mounting directly to a ceiling in a new construction scenario, and a third set of mounting attachments for connecting to a standard outlet or junction box ʼ783 Patent, abstract ʼ783 Patent, claim 1 This consolidation of functionality into one product aims to reduce inventory requirements ʼ783 Patent, col. 3:7-14
• Technical Importance: The invention addresses a logistical and commercial problem in the lighting industry by creating a universal fixture that reduces the need for application-specific products.

Key Claims at a Glance

• The complaint contests infringement of the patent's claims generally, with specific language quoted from what appears to be independent claim 1 Compl. ¶21
• Essential elements of independent claim 1 include:
  • A light source attachable in "at least three different scenarios."
  • A "plurality of first clips" for a first scenario (attaching to an existing recessed lighting fixture housing).
  • A "plurality of second clips," different from the first, for a second scenario (attaching where a recessed housing is not present).
  • "one or more mounting attachments" for a third scenario (attaching to an existing outlet or junction box).
  • A "junction box that is connectable to the body" and can be used with either the first or second clips.

U.S. Patent No. 11,054,118 - "Apparatus to detachably attach LED light fixture to ceiling or recessed lighting fixture housing"

Issued July 6, 2021

The Invention Explained

• Problem Addressed: The patent identifies the problem of consumers and electricians needing to purchase different types of LED recessed light fixtures for "new construction installations" versus "retrofit installations," which increases inventory for distributors ʼ118 Patent, col. 1:21-31
• The Patented Solution: The patent discloses a single lighting apparatus with two distinct types of mounting hardware: a set of "retrofit clips" designed to create a friction fit inside an existing recessed housing, and a set of "new construction clips," held by "connecting posts," designed to secure the fixture directly to a ceiling material like drywall ʼ118 Patent, abstract '118 Patent, col. 4:21-27 This dual-mode functionality allows one product to serve two common installation needs.
• Technical Importance: The invention provides a commercial advantage by allowing lighting retailers and distributors to carry a single stock-keeping unit (SKU) for two distinct applications.

Key Claims at a Glance

• The complaint specifically denies infringement of limitations found in independent claim 1 Compl. ¶31
• Essential elements of independent claim 1 include:
  • A "plurality of retrofit clips (102)" adaptable to attach to the fixture's body.
  • A "plurality of new construction clips (104)."
  • A "plurality of connecting posts (106) to hold the new construction clips."
  • A "metal housing (108)" and a "junction box (116)."
  • A "twist connector (118)."
  • The claim further requires that the retrofit clips create a "friction fit" inside a recessed housing, while the new construction clips are attached to the connecting posts when no housing is present.

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused products as Home Depot SKU#1011028804 (Model: NJ03a4IN3in1-W) and SKU#1011028805 (Model: NJ03a6IN3in1-W) Compl. ¶2

Functionality and Market Context

• The products are described as "lighting products and fixtures" manufactured and/or sold by Leedarson Compl. ¶2
• The complaint does not provide specific technical details about the structure or operation of the accused products' mounting mechanisms, focusing instead on conclusory denials of infringement Compl. ¶21 Compl. ¶31

IV. Analysis of Infringement Allegations

The complaint does not provide a claim chart or sufficient detail regarding the functionality of the accused products to construct a comparative table. Instead, it presents a narrative theory of non-infringement for each patent.

'783 Patent Non-Infringement Allegations

Leedarson alleges that its products do not infringe the '783 Patent because they do not practice key limitations of the claims Compl. ¶21 The central assertion is that the accused products do not constitute an apparatus that is attachable in "at least three different scenarios" using the three distinct types of attachment hardware recited in the claims: (1) a plurality of first clips for recessed housings, (2) a different plurality of second clips for new construction, and (3) separate mounting attachments for an outlet box Compl. ¶21 Leedarson's pleading suggests its products lack this tripartite adaptability.

'118 Patent Non-Infringement Allegations

Leedarson's theory of non-infringement for the '118 Patent is that the accused products lack the specific combination of components required by the claims Compl. ¶31 The complaint alleges the products do not include, among other elements, "a plurality of retrofit clips," "a plurality of new construction clips," and "a plurality of connecting posts to hold the new construction clips" as claimed Compl. ¶31 This suggests a structural and functional difference between the mounting hardware on the accused products and the dual-clip system described in the patent.

No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: A primary issue for the '783 Patent will be whether the accused product's mounting system, whatever its configuration, can be construed as meeting the limitations for all "three different scenarios" required by the claim. For the '118 Patent, the dispute may turn on whether the components of the accused product can be properly characterized as the distinct "retrofit clips" and "new construction clips" as those terms are used in the patent.
• Technical Questions: What is the actual structure and method of operation of the accused products' mounting hardware? The case will require factual development to determine if that hardware includes the specific combination of first clips, second clips, and mounting attachments ('783 Patent) or the combination of retrofit clips, new construction clips, and connecting posts ('118 Patent) recited in the respective independent claims.

V. Key Claim Terms for Construction

"at least three different scenarios" ('783 Patent)

• Context and Importance: This phrase is the central premise of the '783 Patent's claimed invention, defining its universal applicability. The outcome of the non-infringement analysis will likely depend on whether the accused product is found to be "attachable" in these three distinct ways, making the definition of "scenarios" critical.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party might argue that the term should be interpreted functionally, where any product that can be made to attach in the three situations meets the limitation, regardless of whether it is sold with all necessary parts or requires user modification. The specification's focus on reducing inventory for distributors could support an interpretation based on capability ʼ783 Patent, col. 3:7-14
  • Evidence for a Narrower Interpretation: A party could argue that the term requires the apparatus, as provided, to include the distinct sets of hardware for each scenario. Claim 1 explicitly recites "a plurality of first clips," "a plurality of second clips, that is different than the plurality of first clips," and "one or more mounting attachments," suggesting three structurally distinct and included hardware sets are required ʼ783 Patent, claim 1

"retrofit clips" and "new construction clips" ('118 Patent)

• Context and Importance: The '118 Patent claims an apparatus containing both types of clips. The non-infringement defense appears to rest on the accused products not having this specific combination. Practitioners may focus on these terms because their definitions will determine whether a single, multi-function clip could be argued to meet both limitations, or whether two structurally and functionally distinct sets of clips are required.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party could argue the terms are defined by their function-one set for retrofitting, one for new construction-and that any structures performing these functions would suffice. The patent's goal is to provide "both a retrofit application and a new construction application embodied in the same LED light fixture" ʼ118 Patent, col. 2:6-9
  • Evidence for a Narrower Interpretation: The patent provides distinct structural descriptions. The "retrofit clips (102)" are described as making a "friction fit inside the existing recessed housing" ʼ118 Patent, claim 1, while the "new construction clips (104)" are described as being held by "connecting posts (106)" and squeezing "ceiling material" (ʼ118 Patent, col. 1:65-67; '118 Patent, claim 1). This suggests the terms refer to two structurally different components, not just two different uses of the same component.

VI. Other Allegations

Indirect Infringement

The complaint seeks a declaratory judgment of non-infringement for both direct and indirect infringement Compl. ¶23 Compl. ¶33 Leedarson explicitly denies that its products "induce others to practice, or contribute to others practicing" the limitations of the asserted claims Compl. ¶21 Compl. ¶31

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

• A core issue will be one of functional scope: Does the accused lighting fixture, as manufactured and sold, possess the hardware and capability to be installed in the "at least three different scenarios" required by the '783 patent, or is its functionality more limited, placing it outside the claim's scope?
• A second key issue will be one of structural identity: Do the attachment components on the accused products correspond to the distinct "retrofit clips" and "new construction clips" as described and claimed in the '118 patent, or do they represent a single, unified mounting system that is structurally and functionally different from the claimed dual-system invention?
• Finally, a critical evidentiary question will be one of factual comparison: As this is a declaratory judgment action filed with limited technical detail, the case will depend on discovery to establish the actual design and operation of the accused products' mounting systems, which will then be compared against the claim limitations of the patents-in-suit.