Seller Hardware LLC v. Ship Hero LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Seller Hardware, LLC (New Jersey)
  • Defendant: Ship Hero, LLC (New York)
  • Plaintiff's Counsel: Widerman Malek, PL; Barton LLP
• Case Identification: 1:26-cv-03493, S.D.N.Y., 08/05/2026
• Venue Allegations: Venue is alleged to be proper in the Southern District of New York because Defendant resides in the district, has committed alleged acts of infringement there, and maintains a regular and established place of business.
• Core Dispute: Plaintiff alleges that Defendant's "Pick-to-Light" warehouse fulfillment products infringe a patent related to a modular, light-guided system for sorting items in a warehouse.
• Technical Context: The technology involves "put-to-light" systems used in e-commerce fulfillment, where lights guide warehouse workers to place items into specific slots corresponding to customer orders, thereby increasing sorting speed and accuracy.
• Key Procedural History: The asserted patent is subject to a terminal disclaimer over a parent patent. Plaintiff alleges it provided Defendant with formal notice of the patent via a letter on May 20, 2025, approximately one year before filing this amended complaint.

Case Timeline

Date	Event
2021-06-25	Priority Date for U.S. Patent 11,988,367
2024-05-21	U.S. Patent 11,988,367 Issued
2025-05-20	Plaintiff allegedly sent formal notice of infringement to Defendant
2026-08-05	Amended Complaint Filed

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

• Patent Identification: U.S. Patent No. 11,988,367, "Put Wall Light Integration System, Devices, And Associated Methods," issued May 21, 2024 (the "'367 Patent"). Compl. ¶8

The Invention Explained

• Problem Addressed: The patent background identifies a need in e-commerce and warehouse management for a "customizable, simplified sorting and optimized fulfillment approach" beyond existing "Put Wall" systems, which can be inflexible. '367 Patent, col. 2:1-5
• The Patented Solution: The invention is a modular sorting system comprised of interconnected "sorter light boxes" that can be arranged on shelving in a customizable "chain." '367 Patent, abstract A central "hub" acts as a "concentrator" for power and data signals, which it receives from a "controller" (such as a PC) and distributes to the chain of light boxes. '367 Patent, abstract '367 Patent, Fig. 2 This architecture allows for a flexible, scalable "put-to-light" system that is not permanently built into the warehouse shelving. '367 Patent, col. 8:13-22
• Technical Importance: The described solution offers a do-it-yourself (DIY), reconfigurable alternative to fixed, large-scale sorting automation, allowing users to adapt their sorting walls to changing product sizes and order volumes. '367 Patent, col. 8:13-22

Key Claims at a Glance

• The complaint asserts at least independent claim 1. Compl. ¶17
• The essential elements of independent claim 1 are:
  • A plurality of sorter light boxes configured for shelf mounting and for being coupled together to define a chain.
  • A hub configured to couple to the first sorter light box in the chain and to operate as a concentrator of control signals and power for the chain.
  • A controller configured to couple to the hub and to generate control signals for the sorter light boxes.

III. The Accused Instrumentality

Product Identification

• The complaint identifies Defendant's "Pick-to-Light" put wall light packing and shipping fulfillment products as the "Accused Products." Compl. ¶11

Functionality and Market Context

• The complaint alleges the Accused Products embody the patented invention and include a "hub and sorter lights to be mounted adjacent to an associated box." Compl. ¶11
• Critically, the complaint alleges that the Accused Products as sold by Defendant "include each and every component protected by the '367 Patent except the controller device." Compl. ¶11 (emphasis added).
• The complaint alleges that Defendant instead "instructs third parties to purchase and install hardware that acts as the controller." Compl. ¶10 This allegation frames the dispute around indirect infringement.
• The complaint asserts that the Accused Products target the same market as the Plaintiff: warehouses that process e-commerce orders. Compl. ¶13

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not include a claim chart exhibit, but it alleges infringement of at least Claim 1 of the '367 Patent. The infringement theory is constructed from narrative allegations that map to the elements of Claim 1.

'367 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a plurality of sorter light boxes each configured to be mounted to a respective shelf, and each configured to be coupled to another one of the sorter light boxes to define a chain of sorter light boxes	The Accused Products allegedly include a "plurality of sorter light boxes" that are configured to be mounted on a shelf and coupled to one another to form a "chain."	¶10; ¶11	col. 5:46-54
a hub configured to be coupled to a first sorter light box in the chain of sorter light boxes and to operate as a concentrator of control signals and power for the plurality of sorter light boxes...	The Accused Products allegedly include a "hub" that couples to the sorter light boxes and functions as a "concentrator of control signals and power" for them.	¶10; ¶11	col. 6:4-8
a controller configured to be coupled to the hub and generate control signals for the sorter light boxes	Defendant allegedly "instructs third parties to purchase and install hardware that acts as the controller which is configured to be coupled to the hub and generate control signals."	¶10	col. 6:15-19

• Identified Points of Contention:
  • Indirect Infringement: The central dispute appears to be one of indirect infringement, as the complaint concedes Defendant does not supply the "controller". The case may turn on whether Plaintiff can prove that Defendant's actions-selling an incomplete system while instructing customers on how to obtain and add the missing "controller"-constitute either induced or contributory infringement.
  • Technical Questions: A key factual question will be what the "hardware that acts as the controller" actually is and whether it meets the claim limitation of being "configured to... generate control signals." The complaint does not specify the nature of this third-party controller, leaving open questions about its functionality and how it integrates with the accused hub.

V. Key Claim Terms for Construction

• The Term: "controller"

• Context and Importance: This term is critical because it identifies the component that Defendant allegedly does not sell but instructs its customers to add. The definition of "controller" will determine what must be added to the accused system to make it infringing, which is central to the indirect infringement analysis. Practitioners may focus on this term because the patent suggests it can be a common piece of hardware.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification provides an example suggesting a broad scope: "Controller is a computer (e.g. PC running Microsoft Windows and the Skublox Hub Application)." '367 Patent, col. 4:61-63 This could support an argument that any standard PC capable of running the necessary software meets the limitation.
  • Evidence for a Narrower Interpretation: The claim requires the controller to be "configured to be coupled to the hub and generate control signals." '367 Patent, col. 12:42-44 An argument could be made that a "controller" is not a general-purpose PC itself, but rather a PC that has been specifically modified or programmed for this purpose, making it a more specific apparatus.

• The Term: "hub"

• Context and Importance: The claim requires the "hub" to "operate as a concentrator of control signals and power." The accused device's ability to perform this dual function will be a key factual issue in the infringement analysis.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent uses functional language, defining the hub by what it does-"operate as a concentrator"-rather than by its specific structure. '367 Patent, col. 12:35-39 This may support finding infringement even if the accused device's internal architecture differs from the patent's embodiments.
  • Evidence for a Narrower Interpretation: The specification defines a "Hub Device" as "a device that plugs into the Controller (e.g. via USB) with a standalone power supply." '367 Patent, col. 4:63-65 This description, along with figures showing the hub as a distinct physical box, could support an argument that the term requires a separate hardware component with specific physical interfaces. '367 Patent, Fig. 2

VI. Other Allegations

• Indirect Infringement: The complaint explicitly pleads both induced and contributory infringement. Compl. ¶16 The claim for inducement is based on allegations that Defendant instructs customers on how to complete the infringing system, including through "instructional videos and installation and operational tutorials." Compl. ¶18 Compl. ¶19 The claim for contributory infringement is based on the allegation that the Accused Products, sold without the controller, have "no substantial non-infringing uses." Compl. ¶20
• Willful Infringement: The complaint alleges willful infringement based on Defendant's purported knowledge of the '367 Patent since at least 2025, citing a formal notice letter and a LinkedIn conversation. Compl. ¶14 Compl. ¶15 The complaint alleges that Defendant acted despite an "objectively high likelihood" of infringement, tracking the post-Halo standard for willfulness. Compl. ¶22

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

• A primary issue will be one of indirect infringement liability: given that Defendant allegedly sells an incomplete system, can Plaintiff provide sufficient evidence that Defendant's instructions and the lack of substantial non-infringing uses for the accused components meet the legal standards for induced and/or contributory infringement?
• A second core issue is one of claim scope and component functionality: does the third-party hardware that customers allegedly add to the accused system qualify as a "controller" as defined by the patent? The resolution will likely depend on the construction of the term "controller" and factual evidence regarding the functionality of the hardware used by Defendant's customers.