DCT

1:26-cv-05373

Rainbow 100 Inc v. Shenzhen Andelian Technology Co Ltd

Log In
Key Events
Complaint
complaint Intelligence

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:26-cv-05373, N.D. Ga., 09/17/2026
  • Venue Allegations: Venue is asserted on the basis that the defendants are not residents of the United States and may be sued in any judicial district. The complaint also alleges that a substantial part of the events giving rise to the claim, specifically the assertion of the patent against products sold to consumers in the district, occurred in the Northern District of Georgia.
  • Core Dispute: Plaintiff seeks a declaratory judgment that its solar-powered mosquito-control devices do not infringe the Defendants' patent, and that the patent-in-suit is invalid.
  • Technical Context: The lawsuit concerns solar-powered, outdoor insect-killing devices, a consumer product category where weather resistance and operational autonomy are relevant features.
  • Key Procedural History: This declaratory judgment action was prompted by Defendants' assertion of the patent against Plaintiff's products through Amazon's Patent Evaluation Express (APEX) program, which could lead to the removal of Plaintiff's products from the marketplace. Shortly before filing this suit, Plaintiff filed a Request for Ex Parte Reexamination of the patent-in-suit at the USPTO, challenging its validity based on prior art not considered during original examination. The complaint also notes that specific claim limitations were added during prosecution to secure allowance, a factor that may influence claim construction.

Case Timeline

Date Event
2025-08-28 '093 Patent Priority Date
2025-09-04 '093 Patent Application Filing Date
2026-06-30 '093 Patent Issue Date
2026-08-24 Amazon APEX Infringement Notification Received by Plaintiff
2026-08-27 Request for Ex Parte Reexamination of '093 Patent Filed
2026-09-17 Complaint for Declaratory Judgment Filed

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

U.S. Patent No. 12,667,093 B1 - "Solar Mosquito Killer"

  • Patent Identification: U.S. Patent No. 12,667,093 B1, "Solar Mosquito Killer," issued June 30, 2026 (the "'093 Patent").

The Invention Explained

  • Problem Addressed: The patent's background section identifies several issues with prior art solar mosquito killers, including the safety hazards of high-voltage grids, the need for external power sources that limit flexibility, and the risk of rainwater seeping into button assemblies and causing damage or safety hazards ׳093 Patent, col. 1:21-40
  • The Patented Solution: The invention is a self-contained, solar-powered mosquito killer. It uses a solar module to power a high-voltage electric grid and other components, eliminating the need for an external power source ׳093 Patent, col. 2:1-5 To address water intrusion, the invention proposes a "flexible waterproof cover" that is placed over the control buttons, which is described as preventing rainwater from seeping into the device's interior through gaps at the buttons ׳093 Patent, abstract ׳093 Patent, col. 2:5-15
  • Technical Importance: This approach sought to create a more convenient and safer outdoor insect control device by making it self-powered and more resistant to weather, particularly water infiltration around control switches ׳093 Patent, col. 2:1-21

Key Claims at a Glance

  • The complaint seeks a declaratory judgment of non-infringement and invalidity for all fifteen claims of the '093 Patent, highlighting independent claims 1, 11, and 14 Compl. ¶12 Compl. ¶26 Compl. ¶¶31-34
  • Independent Claim 1 recites the core apparatus, with essential elements including:
    • A solar module.
    • A mosquito killing module with a frame, an electric grid, a control component, and a button.
    • A detachable supporting module.
    • The button having multiple gears for "automatic," "normally off," and "normally on" states.
    • The button comprising a "first switch (K1)" and a "second switch (K2)."
    • A "switch control circuit (232)" including a "third switch (Q2)."
    • A specific circuit topology where the second switch (K2) is connected between the solar module and the third switch (Q2), and the first switch (K1) is connected in parallel with the third switch (Q2).
  • The complaint indicates that all claims are in dispute Compl. ¶4

III. The Accused Instrumentality

Product Identification

  • The "Accused Products" are identified as solar-powered mosquito-control devices sold by Plaintiff Rainbow 100, Inc. on the Amazon.com marketplace, including those sold under ASIN B0DPHKSFVH Compl. ¶18 Compl. ¶19

Functionality and Market Context

  • The complaint, being for declaratory judgment, does not provide a technical description of the Accused Products' functionality. Instead, it makes blanket denials that the products embody the limitations of the '093 Patent's claims Compl. ¶25
  • The complaint specifically denies that the Accused Products contain certain narrowly-defined combinations recited in the independent claims Compl. ¶26 For example, it alleges the products do not have the specific switch-control circuit of claim 1, the opposed L-shaped fixing components of claim 11, or the detachable auxiliary lamp with a ball-head bracket of claims 14 and 15 Compl. ¶26
  • No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement. The following table summarizes the key non-infringement position asserted by the Plaintiff for independent claim 1.

  • '093 Patent Infringement Allegations
Claim Element (from Independent Claim 1) Plaintiff's Stated Basis for Non-Infringement Complaint Citation Patent Citation
wherein the button (24) comprises a first switch (K1) and a second switch (K2); the solar mosquito killer further comprises a switch control circuit (232) which includes a third switch (Q2), with two conducting terminals of the third switch (Q2) respectively connected between the button (24) and the mosquito killing module (2); the second switch (K2) is connected between the solar module (1) and the third switch (Q2), and the first switch (K1) is connected in parallel with the third switch (Q2). The complaint alleges that the Accused Products do not include or perform this specific switch-control circuit limitation. ¶26 col. 19:15-30
a supporting module (3), wherein the supporting module (3) is detachably connected to the mosquito killing module (2) to support the mosquito killing module (2) The complaint alleges that the Accused Products do not embody each and every limitation of the '093 Patent, which would include the detachable supporting module. ¶25 col. 7:13-15
  • Identified Points of Contention:
    • Technical Questions: A primary factual dispute will involve a technical comparison of the Accused Products' circuitry and mechanical structures against the limitations of the asserted claims. The complaint's focus on the specific K1/K2/Q2 switch arrangement suggests a central question will be whether the Accused Products' control logic operates in the same manner and uses the same parallel/series structure as required by claim 1 Compl. ¶26
    • Scope Questions: The complaint alleges that several key limitations, including the switch-control circuit and a detachable auxiliary lamp, were added during prosecution to secure allowance Compl. ¶14 This raises the question of whether prosecution history estoppel will narrow the scope of these terms, potentially limiting them to the specific embodiments shown in the patent and making it more difficult for the patent holder to prove infringement, including under the doctrine of equivalents.

V. Key Claim Terms for Construction

  • The Term: The specific "switch-control circuit" architecture recited in claim 1, comprising a first switch (K1), a second switch (K2), and a third switch (Q2) in a specific parallel and series arrangement.

  • Context and Importance: The complaint identifies this circuit as a limitation that the Accused Products lack and notes it was added during prosecution Compl. ¶14 Compl. ¶26 The construction of this term—whether it is limited to the precise topology described or can cover other circuits that achieve a three-state (auto/on/off) functionality—will be critical to the infringement analysis.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: A party arguing for broader scope may point to the overall function of enabling automatic, on, and off states as the core of the invention, suggesting that different but equivalent circuit designs should be covered ׳093 Patent, col. 18:7-14
    • Evidence for a Narrower Interpretation: The claim language itself is highly specific about the parallel and series connections of K1, K2, and Q2 ׳093 Patent, claim 1 The circuit diagram in Figure 72 and the accompanying detailed description provide a precise implementation ׳093 Patent, FIG. 72 ׳093 Patent, col. 19:15-40 The allegation that this was a narrowing amendment Compl. ¶14 would strongly support a construction limited to this specific arrangement.

VI. Other Allegations

  • Indirect Infringement: The Plaintiff, Rainbow, seeks a declaratory judgment that it has not infringed the '093 Patent either directly or indirectly, and has not induced or contributed to the infringement of any claim Compl. ¶24

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

  • Claim Construction and Scope: A central issue will be one of claim scope defined by prosecution history. Given the Plaintiff's allegation that key limitations like the specific "switch-control circuit" were added to overcome prior art, the case may turn on whether the court adopts a narrow construction. The key question for infringement will then be whether the accused products, as a matter of fact, fall within that potentially narrowed scope.

  • Validity Over New Art: The case presents a significant validity challenge based on prior art that the USPTO allegedly did not consider during examination. The pending Ex Parte Reexamination filed by the Plaintiff Compl. ¶15 introduces a parallel proceeding focused on this very issue. A key question is whether the numerous newly cited references, alone or combined, disclose or render obvious the claimed features, such as the solar-power system, three-state switch logic, and waterproof button cover.

  • Procedural Strategy: A threshold question for the court will be case management in light of the concurrent USPTO reexamination. The court will need to decide whether to stay the district court litigation pending the outcome of the reexamination, a decision that could significantly affect the timing and scope of the dispute by potentially invalidating or narrowing the claims at issue.