Shenzhen Star No6 Technology Co Ltd v. Green Light Innovations Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Shenzhen Star No.6 Technology Co., Ltd. (China)
  • Defendant: Green Light Innovations Inc. (Missouri)
  • Plaintiff's Counsel: Valley & Summit Law
• Case Identification: 1:26-cv-05284, N.D. Ill., 05/07/2026
• Venue Allegations: Venue is alleged to be proper based on Defendant conducting business in the district and directing enforcement activities, specifically Amazon IP complaints, toward sellers within the district.
• Core Dispute: Plaintiff seeks a declaratory judgment that its LED "OPEN" signs do not infringe Defendant's patent related to illuminated signs, and that the patent is invalid, following repeated infringement complaints filed by Defendant on Amazon's e-commerce platform.
• Technical Context: The technology concerns LED illuminated signs designed to create a distinct, visually appealing effect similar to neon by preventing light from different colored sections from "bleeding" into one another.
• Key Procedural History: This declaratory judgment action was initiated by the accused infringer after it was targeted by three successive waves of infringement complaints on Amazon's IP platform. The complaint states that the first two waves were successfully rebutted with non-infringement analyses, but upon the third complaint, Amazon required a court order to reinstate the product listings, prompting this lawsuit.

Case Timeline

Date	Event
2013-06-14	'150 Patent Priority Date
2015-10-06	'150 Patent Issue Date
2024-09-24	First series of Amazon IP complaints initiated
2025-09-16	Second series of Amazon IP complaints initiated
2026-03-13	Third series of Amazon IP complaints initiated
2026-05-07	Complaint Filing Date

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, "Lighting Assembly Having Enhanced Visual Appearance," issued on October 6, 2015.

The Invention Explained

• Problem Addressed: The patent's background section notes that while LEDs are an alternative to traditional neon tubes for illuminated signs, they often fail to distribute light uniformly and can suffer from "bleed," where light from different colored sources interferes with one another, resulting in "undesired lighting effects" '150 Patent, col. 1:20-32
• The Patented Solution: The invention proposes a lighting assembly with at least two different light sources (e.g., one for lettering, one for a border) housed within a casing. To solve the "bleed" problem, the design incorporates a "light barrier" physically disposed between the covers that are illuminated by the different light sources. This barrier is explicitly "configured to prevent interference between the first light source and the second light source," ensuring a crisp visual separation. '150 Patent, abstract '150 Patent, col. 2:41-44
• Technical Importance: By addressing the issue of light bleed, the patented design aimed to allow cost-effective LEDs to better replicate the sharp, distinct, and visually appealing aesthetic of traditional, multi-colored neon signs '150 Patent, col. 1:29-32

Key Claims at a Glance

The complaint seeks a declaratory judgment of non-infringement of the '150 Patent but does not specify which claims were asserted by the Defendant. The patent contains three independent claims (1, 8, and 15), each of which requires a "light barrier."

• Independent Claim 1 recites, among other elements:
  • a first light source and a second light source
  • a first cover and a second cover
  • 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
• Independent Claim 8 recites a similar structure with an "inner cover" for a word and an "outer cover" for a border, separated by a "light barrier."
• Independent Claim 15 specifies a "light barrier is formed separately from and coupled to the outer cover to block light from the second light source."

III. The Accused Instrumentality

• Product Identification: The accused instrumentality is the Plaintiff's illuminated LED "OPEN" sign, sold on Amazon through its "StarNo.6" storefront Compl. ¶3
• Functionality and Market Context: The product is an electronic sign that uses LEDs to display the word "OPEN" Compl. ¶3 A photograph provided in the complaint shows a sign with blue illuminated border elements and red illuminated letters spelling "OPEN" Compl. p. 2 The complaint alleges that Defendant's repeated infringement complaints on Amazon's IP platform have resulted in the "wrongful delisting and removal" of these product listings, causing "significant disruption to Plaintiff's business operations" Compl. ¶13 The core of the Plaintiff's non-infringement argument is the assertion that its product "does not include... a light barrier" as required by the patent Compl. ¶19

IV. Analysis of Infringement Allegations

As this is a declaratory judgment action, the infringement analysis is based on the Plaintiff's asserted theory of non-infringement against the allegations made by the Defendant outside of court. The central dispute revolves around the "light barrier" element present in all independent claims of the '150 Patent.

'150 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
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.	The complaint asserts that the Plaintiff's Product "does not include such a light barrier" and therefore does not infringe the '150 Patent.	¶19	col. 13:28-33

• Identified Points of Contention:
  • Factual Question: The primary point of contention is factual: does the Plaintiff's product, upon physical inspection, contain any structure that functions as a "light barrier" to prevent light interference? The complaint's conclusory statement that the product lacks this feature Compl. ¶19 will be tested against the product's actual design and construction.
  • Scope Question: A key legal dispute will likely concern the definition of "light barrier." The question for the court will be whether this term is limited to a separate, dedicated component as depicted in certain patent figures '150 Patent, Fig. 4, item 318, or if it can be construed more broadly to read on any integrated wall or portion of the sign's housing that has the effect of blocking light between two sources. The language of claim 15, which specifies a barrier "formed separately from and coupled to the outer cover," may be used to argue that the term in claim 1 should be interpreted more broadly, as it lacks this specific limitation.

V. Key Claim Terms for Construction

• The Term: "light barrier"
• Context and Importance: This term is the crux of the non-infringement case presented in the complaint Compl. ¶19 The presence or absence of a structure meeting the construed definition of "light barrier" in the Plaintiff's product will likely be dispositive for infringement. Practitioners may focus on this term because its construction will determine whether integral housing walls can satisfy the limitation or if a separate component is required.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: Claim 1 recites the "light barrier" in broad functional terms, as being "disposed between the first and second covers" and "configured to prevent interference" '150 Patent, col. 13:28-33 This language does not explicitly require a separate component, potentially allowing an integral part of the product's housing that serves this function to meet the definition.
  • Evidence for a Narrower Interpretation: The specification consistently illustrates the light barrier as a distinct structural element (e.g., '150 Patent, Fig. 4, item 318; '150 Patent, Fig. 9, item 3180). Furthermore, claim 15 explicitly recites a "light barrier is formed separately from and coupled to the outer cover" '150 Patent, col. 14:46-49 A party could argue this language, along with the specification's examples, suggests that the term implies a structure that is more than just an undifferentiated wall of the main housing assembly.

VI. Other Allegations

• Willful Infringement: The complaint does not allege willful infringement by the Plaintiff. Instead, it lays the groundwork for a potential claim of bad faith enforcement by the Defendant. The complaint alleges that the Defendant continued to file infringement complaints with Amazon even after the Plaintiff "submitted a non-infringement analysis prepared by U.S. patent counsel" on two separate occasions Compl. ¶15 Compl. ¶16 Compl. ¶20 These allegations suggest the Defendant was on notice of potential non-infringement yet persisted in its enforcement actions, which the Plaintiff characterizes as "unjustified and made in bad faith" Compl. ¶37

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

• A core issue will be one of claim construction: how will the court define "light barrier"? Will the definition be broad enough to encompass any structural separator within the sign's housing that blocks light, or will it be narrowed to require a distinct component, as shown in the patent's specific embodiments?
• A dispositive question will be factual and technical: does the Plaintiff's LED sign contain any physical structure that meets the court's construed definition of the "light barrier" limitation? The outcome of the non-infringement claim hinges on the answer to this question, which will require an examination of the accused product's internal construction.
• A key procedural question relates to enforcement conduct: did the Defendant's submission of repeated Amazon complaints, particularly after allegedly receiving non-infringement analyses from Plaintiff's counsel, constitute bad faith enforcement sufficient to support the Plaintiff's ancillary claims for tortious interference and violation of state deceptive trade practice laws?