DCT

1:26-cv-11254

Salondepot Inc v. Shenzhen Andelian Technology Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:26-cv-11254, N.D. Ill., 09/15/2026
  • Venue Allegations: Venue is alleged to be proper because the defendants are not residents of the United States and may be sued in any judicial district.
  • Core Dispute: Plaintiff seeks a declaratory judgment that its solar mosquito killer products do not infringe U.S. Patent No. 12,667,093 and that the patent is invalid as anticipated or rendered obvious by prior art.
  • Technical Context: The lawsuit concerns solar-powered outdoor insect zappers, a common consumer electronics product.
  • Key Procedural History: The action was initiated after Defendants filed a patent infringement complaint against Plaintiff’s product listings through Amazon.com’s patent enforcement procedure, leading to a notification that the listings would be removed.

Case Timeline

Date Event
2022-03-15 Alleged prior art disclosure (Chinese design patent CN307171824)
2023-01-31 Alleged prior art disclosure (Chinese design patent CN307820993)
2023-04-10 Alleged prior art disclosure (Amazon Listing "ZRLKM")
2023-04-20 Alleged prior art disclosure (Facebook Public Posting)
2023-06-02 Alleged prior art disclosure (Facebook User, Salomon Abrego)
2023-09-26 Alleged prior art disclosure (Chinese design patent CN308246059)
2023-11-14 Alleged prior art disclosure (Chinese design patent CN308322747)
2024-05-13 Earliest Priority Date for '093 Patent
2025-09-04 '093 Patent Application Filing Date
2026-06-30 '093 Patent Issue Date
2026-08-24 Amazon.com notifies Plaintiff of infringement report
2026-09-15 Complaint Filing Date

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

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

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

The Invention Explained

  • Problem Addressed: The patent's background section describes limitations of existing solar mosquito killers, including the need for external power sources and susceptibility to water damage from rainwater seeping into gaps around control buttons, which creates safety hazards ʼ093 Patent, col. 1:28-39
  • The Patented Solution: The invention is a self-contained, solar-powered mosquito killer featuring a modular design (solar module, killing module, supporting module) and, critically, a "flexible waterproof cover" designed to fit over the device's buttons to prevent water infiltration ʼ093 Patent, abstract ʼ093 Patent, col. 1:53-63 This design aims to improve the device's durability and safety for outdoor use ʼ093 Patent, col. 2:5-18
  • Technical Importance: The invention purports to solve key usability and safety issues for outdoor electronics by combining solar power for operational flexibility with specific waterproofing features for weather resistance ʼ093 Patent, col. 1:40-53

Key Claims at a Glance

  • The complaint states that Defendants asserted independent claim 11 in their submission to Amazon.com Compl. ¶12
  • Independent Claim 11 of the ’093 Patent recites:
    • A solar module (1);
    • A mosquito killing module (2) on one side of the solar module, comprising a frame component (21), an electric grid (22) in the frame, a control component (23) connected to the grid, and a button (24) on the frame connected to the control component;
    • A supporting module (3) detachably connected to the mosquito killing module;
    • Wherein the frame component (21) comprises two mounting columns (211), a top beam (212), a bottom beam (213), and two protective nets (214) connected to form a frame, with specific opposite arrangements and insertion holes (2111) for the grid, and with the control component and button on one mounting column;
    • Wherein the mosquito killing module (2) further comprises at least one mosquito trap lamp (26), with specific mounting features (second insertion holes 2112, fixing slots 2113);
    • Wherein the mosquito lure lamp (26) comprises a lampshade (261) and a circuit board component (262), with the lampshade comprising a shade body (2611) and a fixing portion (2612) made of two L-shaped components that cooperatively enclose a strip-shaped storage slot for the circuit board.

III. The Accused Instrumentality

Product Identification

  • The complaint identifies Plaintiff’s "Mosquito Killers" sold on Amazon.com under ASINs B0F43NBHW2 and B0FH9GJ46S Compl. ¶11 Compl. ¶16

Functionality and Market Context

  • The products are described and depicted as solar-powered outdoor bug zappers Compl. ¶16 The complaint includes an image of the products, showing devices with a top-mounted solar panel, a central electrified grid, and ground stakes for support Compl. ¶16, p. 10
  • The central allegation regarding functionality is that the Plaintiff’s products were made "according to the prior art such as ZRLKM" Compl. ¶16 This forms the basis of the Plaintiff’s argument for non-infringement and invalidity.

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement and does not provide an element-by-element mapping of the accused products to the patent claims. Instead, the Plaintiff’s theory of non-infringement is predicated on its invalidity argument: that its products practice the prior art and thus cannot infringe a valid patent claim Compl. ¶14 Compl. ¶¶25-26 The complaint provides a side-by-side visual comparison purporting to show similarity between a prior art device and the representative figure from the ’093 Patent Compl. ¶17, p. 11

'093 Patent Infringement Allegations

Claim Element (from Independent Claim 11) Alleged Infringing Functionality Complaint Citation Patent Citation
A solar mosquito killer, comprising: a solar module (1); a mosquito killing module (2)...; and a supporting module (3)...detachably connected to the mosquito killing module (2) The complaint does not map these elements to its products. Instead, it argues that its products embody prior art and therefore cannot infringe any valid claim of the '093 Patent. ¶14; ¶25 col. 7:1-14
wherein the frame component (21) comprises two mounting columns (211), a top beam (212), a bottom beam (213), and two protective nets (214)... The complaint does not map these elements to its products. Instead, it argues that its products embody prior art and therefore cannot infringe any valid claim of the '093 Patent. ¶14; ¶25 col. 13:10-23
wherein the mosquito killing module (2) further comprises at least one mosquito trap lamp (26)... The complaint does not map these elements to its products. Instead, it argues that its products embody prior art and therefore cannot infringe any valid claim of the '093 Patent. ¶14; ¶25 col. 13:40-44
the mosquito lure lamp (26) comprises a lampshade (261)...the fixing part (2612) comprises two L-shaped fixing components...cooperatively enclose a strip-shaped storage slot... The complaint does not map these elements to its products. Instead, it argues that its products embody prior art and therefore cannot infringe any valid claim of the '093 Patent. ¶14; ¶25 col. 14:9-24
  • Identified Points of Contention:
    • Invalidity vs. Infringement: The case presents a classic declaratory judgment scenario where the plaintiff argues that its product cannot infringe because it simply practices what was already in the public domain before the patent was filed Compl. ¶14 Compl. ¶25 The court will likely need to address the patent's validity before or concurrently with determining infringement.
    • Scope Questions: A central question will be whether the prior art cited by the plaintiff—particularly the "ZRLKM" device Compl. ¶15—actually discloses every element of the highly detailed Claim 11. For example, does the ZRLKM device contain the specific "two L-shaped fixing components" that "cooperatively enclose a strip-shaped storage slot" as required by the claim? The complaint makes a conclusory statement of identity but does not provide this level of detailed mapping.
    • Technical Questions: The plaintiff's case hinges on proving that the alleged prior art, such as the ZRLKM device available on April 10, 2023, anticipates or renders obvious a patent with an earliest priority date of May 13, 2024 Compl. ¶13 Compl. ¶15 Compl. ¶21 The outcome will depend on a factual comparison between the claim limitations and the features of the prior art devices.

V. Key Claim Terms for Construction

  • The Term: "cooperatively enclose a strip-shaped storage slot"
  • Context and Importance: This term appears in the final, highly specific limitation of Claim 11, describing the structure of the mosquito lure lamp ʼ093 Patent, col. 27:1-3 Practitioners may focus on this term because its narrow structural requirements could be a key point of distinction from the prior art. The Plaintiff's invalidity and non-infringement arguments may falter if the prior art ZRLKM device lacks this specific configuration.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The complaint does not provide a basis for analysis of this specific element.
    • Evidence for a Narrower Interpretation: The patent specification describes this feature in detail, stating the "fixing portion (2612) and the shade body (2611) can enclose a storage slot," into which the circuit board component slides ʼ093 Patent, col. 14:25-29 The associated figures, such as FIG. 42, show a specific physical arrangement that may be used to argue for a narrow construction limited to a structure that forms a channel for receiving the circuit board.

VI. Other Allegations

This is a complaint for declaratory judgment of non-infringement and invalidity. It does not contain counts for indirect or willful infringement.

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

  • A central question will be one of validity: Does the prior art identified by the Plaintiff, particularly the "ZRLKM" device allegedly sold on Amazon more than a year before the '093 Patent's priority date, disclose every element of the asserted and highly detailed Claim 11, thereby anticipating it under 35 U.S.C. § 102?
  • A related evidentiary question will be one of non-infringement: Can the Plaintiff prove that its accused products are "made according to the prior art" Compl. ¶16, and can the '093 Patent's claims be interpreted to cover those products without also being invalid over that same prior art? The case may turn on whether the patent's specific structural limitations, such as the "L-shaped fixing components" enclosing a "storage slot," are present in both the prior art and the accused devices.