DCT

1:26-cv-04722

DS Advanced Enterprises Ltd v. Home Depot Inc

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Complaint
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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-00045, S.D. Ohio, 01/14/2026
  • Venue Allegations: Plaintiff alleges venue is proper in the Southern District of Ohio because Defendants operate at least 70 retail stores and at least four distribution centers in Ohio, with at least two distribution centers located within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s "3-in-1 Universal Installation" recessed LED lighting products infringe two patents related to versatile lighting fixtures designed for multiple installation scenarios.
  • Technical Context: The technology addresses inefficiencies in the lighting market by creating a single lighting fixture adaptable for retrofitting into existing housings, new construction installations, or mounting to electrical junction boxes.
  • Key Procedural History: The complaint alleges that the inventor presented the technology underlying the '118 Patent to Home Depot in 2019. It also references a separate 2023 litigation accusing Home Depot U.S.A., Inc. of infringing the '118 Patent and a demand letter sent in July 2025 regarding the '783 Patent, which may be relevant to the allegations of willful infringement.

Case Timeline

Date Event
2018-05-18 '118 Patent Priority Date
2019-04-02 Plaintiff's inventor allegedly presented technology to Home Depot
2019-08-27 Plaintiff's inventor allegedly made a second presentation to Home Depot
2021-07-06 '118 Patent Issue Date
2021-08-27 '783 Patent Priority Date
2023-XX-XX Prior litigation involving the '118 Patent and Home Depot U.S.A., Inc. initiated
2024-03-14 Accused Product manuals allegedly created
2024-04-24 Accused Products received Energy Star certification
2024-05-07 Accused Products allegedly became available on the market
2025-07-15 '783 Patent Issue Date
2025-07-18 Plaintiff sent demand letter regarding the '783 Patent to Home Depot
2026-01-14 Complaint Filing Date

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"

The Invention Explained

  • Problem Addressed: The patent's background describes the problem faced by consumers and electricians who typically must purchase different light fixtures for new construction, retrofit, and electrical outlet box installations, creating logistical and inventory challenges for distributors ʼ783 Patent, col. 1:31-52
  • The Patented Solution: The invention provides a single, universal lighting apparatus that can be attached to a mounting surface in at least three different ways. It includes distinct hardware components for each scenario: a set of "first clips" for retrofitting into an existing recessed housing, a set of "second clips" for new construction where no housing is present, and "mounting attachments" for installing to an existing outlet or junction box ʼ783 Patent, abstract ʼ783 Patent, Claim 1
  • Technical Importance: The technology aims to consolidate multiple product types into a single SKU, thereby saving money, reducing warehouse space for distributors, and simplifying the purchasing and installation process for electricians and consumers ʼ783 Patent, col. 3:5-14

Key Claims at a Glance

  • The complaint asserts infringement of "each and every claim," with a specific reference to independent claims 1 and 9 Compl. ¶77 Compl. ¶80
  • Independent Claim 1 requires:
    • A light source attachable to a mounting surface in "at least three different scenarios"
    • A body for the light source with a wire for connecting to a power supply
    • A "plurality of first clips" for attaching the light source in a first scenario (existing recessed housing)
    • A "plurality of second clips" for attaching the light source in a second scenario (no recessed housing)
    • "One or more mounting attachments" for attaching the light source in a third scenario (existing outlet/junction box)
    • A junction box connectable to the body
  • Independent Claim 9 recites a similar system with corresponding elements. The complaint does not foreclose assertion of dependent claims Compl. ¶77

U.S. Patent No. 11,054,118 - "APPARATUS TO DETACHABLY ATTACH LED LIGHT FIXTURE TO CEILING OR RECESSED LIGHTING FIXTURE HOUSING"

The Invention Explained

  • Problem Addressed: The patent identifies the need for consumers and electricians to purchase different types of LED recessed light fixtures for new construction versus retrofit installations, which increases inventory for distributors ’118 Patent, col. 1:21-34
  • The Patented Solution: The patent discloses a single lighting apparatus that includes two distinct types of mounting hardware: a plurality of "retrofit clips" designed to create a friction fit inside an existing recessed housing, and a plurality of "new construction clips" held by "connecting posts" that can squeeze ceiling material to mount the fixture directly to a ceiling where no housing exists ’118 Patent, abstract ’118 Patent, col. 2:6-12
  • Technical Importance: The invention provides a "two-in-one" solution that allows lighting retailers and distributors to carry only one set of inventory for both retrofit and new construction applications, saving costs and warehouse space ’118 Patent, col. 2:10-12

Key Claims at a Glance

  • The complaint asserts infringement of "each and every claim," which includes independent claim 1 Compl. ¶95
  • Independent Claim 1 requires:
    • A "plurality of retrofit clips" attachable to the fixture body
    • A "plurality of new construction clips"
    • A "plurality of connecting posts" to hold the new construction clips
    • A metal housing embodying the fixture
    • A junction box to hold wiring
    • A twist connector to attach wires from the junction box to the housing
    • The claim further specifies that the retrofit clips "make a friction fit inside" an existing housing, while the new construction clips are attached to the connecting posts if no housing is present.
  • The complaint does not foreclose assertion of dependent claims Compl. ¶95

III. The Accused Instrumentality

Product Identification

The accused products are identified as Home Depot SKU#1011028804 (Model: NJ03a4IN3in1-W) and SKU# 1011028805 (Model: NJ03a6IN3in1-W) Compl. ¶7

Functionality and Market Context

The complaint alleges the Accused Products are marketed and sold as "3-in-1 Universal Installation Recessed Light[s]" Compl. ¶79 The product manuals allegedly provide instructions for three distinct installation methods: installation into an "existing recessed housing," a "Canless" installation directly to a ceiling, and installation to an "existing junction box of the ceiling" (Compl. ¶¶81-82; Compl. ¶85-87). The complaint includes a screenshot from Home Depot's website showing one of the Accused Products, described as a "3-in-1 Universal Installation" light Compl. p. 11

IV. Analysis of Infringement Allegations

'783 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a light source attachable to, and detachable from, a mounting surface in at least three different scenarios The Accused Products are described as "3-in-1 Universal Installation" lights, and their manuals allegedly detail three different installation methods. ¶79; ¶80; ¶81 col. 13:27-30
a plurality of first clips connectable to the body for attaching the light source... when... an existing recessed lighting fixture housing is available The manuals for the Accused Products allegedly instruct users on "Using Spring Clips" to install the product in an "existing recessed housing." ¶85 col. 13:36-40
a plurality of second clips... connectable to the body for attaching the light fixture... when... a recessed lighting fixture housing is not present The manuals allegedly instruct on using "spring-loaded clips" for "Canless" installations where no pre-existing housing is used. ¶86 col. 13:41-45
one or more mounting attachments connectable to the body for attaching the light fixture... when... an existing outlet box or existing junction box is present The manuals allegedly instruct users to use screws and a mounting plate to install the product to an existing "junction box of the ceiling." ¶87 col. 13:51-56
a junction box that is connectable to the body for containing an electrical component and wire connection The Accused Products are allegedly sold with a junction box, and diagrams in the manuals illustrate this component. ¶88 col. 13:61-65

'118 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a plurality of retrofit clips (102) adaptable to attach with a body of the LED light fixture... wherein the retrofit clips (102) make a friction fit inside the recessed lighting fixture housing The manuals allegedly direct users to utilize "clips" for installation in an "existing recessed housing." ¶97 col. 6:11-15
a plurality of new construction clips (104)... wherein the new construction clips (104) are attached to the connecting posts (106) if the recessed lighting fixture housing is not present The manuals allegedly direct users to use "spring-loaded clips" for a "canless" installation. Each manual allegedly shows a "spring-loaded clip" attached to a piece of metal. ¶98; ¶99 col. 6:15-16
a junction box (116) to hold a plurality of connection wirings The Accused Products are allegedly sold with junction boxes, and the manuals direct users to connect home wiring into these boxes. ¶100; ¶101 col. 6:20-23
a twist connector (118) to attach the output wires of the junction box (116) to the metal housing (108) The Accused Products are allegedly sold with wire connectors, and the manuals direct users to attach wires from the LED driver to input wires using these connectors. ¶102; ¶104 col. 6:24-27

Identified Points of Contention

  • Structural Differentiation of Clips: Both patents claim distinct types of clips for different installation scenarios e.g., "first clips" vs. "second clips" in the '783 Patent "retrofit clips" vs. "new construction clips" in the '118 Patent The complaint alleges the use of "spring clips" and "spring-loaded clips" for different installations Compl. ¶85 Compl. ¶86 Compl. ¶97 Compl. ¶98 A key question will be whether the hardware of the Accused Products includes structurally distinct components that map onto these separate claim limitations, or whether a single type of clip is being used for multiple purposes. The screenshot from a Canadian retail website appears to show a similar product, providing further visual context for the accused device's design Compl. p. 13
  • Scope of "Scenarios": For the '783 Patent, a point of contention may be whether the three installation methods described in the accused product's manuals correspond directly to the three specific "scenarios" defined in the claims. The court will need to construe the scope of each claimed scenario and compare it to the functionality of the accused device.

V. Key Claim Terms for Construction

  • Term: "a plurality of first clips" and "a plurality of second clips" '783 Patent, Claim 1
  • Context and Importance: The '783 Patent's core inventive concept rests on providing a single fixture with distinct hardware for different scenarios. The infringement analysis will depend on whether the Accused Product contains two structurally different sets of clips that correspond to the claimed "first" and "second" clips. Practitioners may focus on this distinction, as it is central to proving that the accused device embodies the claimed multi-scenario solution.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification discusses the overall goal of providing a versatile fixture for multiple applications, which could support an argument that the precise form of the clips is less important than their function in enabling these different installations ʼ783 Patent, col. 3:5-14
    • Evidence for a Narrower Interpretation: The claim language explicitly recites two separate pluralities of clips ("a plurality of first clips" and "a plurality of second clips"), and the summary of invention describes them as being for different applications (retrofit vs. new construction) ʼ783 Patent, col. 1:45-50 This suggests that they are structurally and functionally distinct elements, not just a single set of clips used in two different ways.
  • Term: "retrofit clips" and "new construction clips" '118 Patent, Claim 1
  • Context and Importance: Similar to the '783 Patent, the '118 Patent claim requires two different types of clips. The patent's viability and the infringement case depend on these terms being construed as requiring two structurally distinct mechanisms. Whether the Accused Product's hardware meets this requirement will be a dispositive issue.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: An argument could be made that the terms are defined by their function. If a single clip design can perform both the "friction fit" of a retrofit clip and the "squeezing" action of a new construction clip, it might be argued to satisfy both limitations.
    • Evidence for a Narrower Interpretation: The patent figures and abstract clearly distinguish between "retrofit clips (102)" and "new construction clips (104)," showing them as different structures ’118 Patent, Fig. 1 ’118 Patent, Fig. 3 ’118 Patent, abstract The claim separately lists "a plurality of retrofit clips" and "a plurality of new construction clips," strongly suggesting two distinct sets of hardware are required ’118 Patent, col. 6:11-16

VI. Other Allegations

Indirect Infringement

The complaint alleges that Defendants induce infringement by providing installation manuals with the Accused Products Compl. ¶63 These manuals allegedly instruct customers on how to perform the infringing installations corresponding to the patented methods (Compl. ¶¶81-87; Compl. ¶¶97-104).

Willful Infringement

The complaint alleges willful infringement based on both pre-suit and post-suit knowledge. For the '118 Patent, pre-suit knowledge is alleged based on presentations made by the inventor to Home Depot in 2019 and a prior 2023 lawsuit involving the same patent Compl. ¶¶46-51 Compl. ¶61 For the '783 Patent, pre-suit knowledge is alleged based on a demand letter sent in July 2025 Compl. ¶66 The complaint also alleges that Home Depot continues to sell the Accused Products despite being accused of infringement, which would support post-suit willfulness Compl. ¶74

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

  • A core issue will be one of claim construction and structural mapping: Do the Accused Products contain the specific, structurally distinct sets of clips required by the independent claims of both the '783 and '118 patents? The case may turn on whether the hardware described in the complaint as "spring clips" and "spring-loaded clips" constitutes two separate types of mechanisms corresponding to the "retrofit" vs. "new construction" functionalities as claimed.
  • A second key question will be one of willfulness and intent: What is the legal effect of the alleged 2019 presentations to Home Depot, the prior 2023 litigation over the '118 Patent, and the 2025 demand letter for the '783 Patent? The court will need to evaluate this evidence to determine if Home Depot acted with the knowledge and intent required to support a finding of willful infringement and potential enhanced damages.