DS Advanced Enterprises Ltd v. Home Depot Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: DS Advanced Enterprises, Ltd. (Ontario, Canada)
  • Defendant: The Home Depot, Inc., Home Depot U.S.A., Inc. (Delaware), and Home Depot Investment Management (Shanghai) Co., Ltd (China)
  • Plaintiff’s Counsel: Dean Cummins Law Firm LLC
• Case Identification: 2:26-cv-00045, S.D. Ohio, 01/14/2026
• Venue Allegations: Venue is alleged to be proper in the Southern District of Ohio based on the presence of at least 70 Home Depot retail stores and at least two distribution centers within the district.
• Core Dispute: Plaintiff alleges that Defendant’s universal installation LED recessed lighting fixtures infringe patents related to lighting apparatuses adaptable for multiple installation environments.
• Technical Context: The technology addresses inefficiencies in the lighting market created by the transition from incandescent to LED recessed lights, where distributors and electricians previously had to stock separate kits for "retrofit" and "new construction" installations.
• Key Procedural History: The complaint alleges that the inventor presented the technology, then the subject of a patent application, to Home Depot product managers in April and August 2019. It also notes that Defendant Home Depot U.S.A., Inc. was accused of infringing the ’118 Patent in separate litigation in 2023. A demand letter regarding the ’783 Patent was allegedly sent to Home Depot in July 2025.

Case Timeline

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 section identifies the problem faced by consumers and electricians who historically had to purchase different types of light fixtures for "new construction installations, retrofit installations, and electrical outlet box installations," leading to wasted time, money, and inventory for distributors Compl. ¶38-42 ’783 Patent, col. 1:36-54
• The Patented Solution: The invention is a single lighting apparatus that can be installed in three distinct scenarios: into an existing recessed lighting "can," into a ceiling without an existing can ("new construction"), or into a standard electrical outlet/junction box. The solution provides different attachment hardware—such as distinct sets of clips or mounting plates—to accommodate each of these scenarios with a single core light fixture body ’783 Patent, col. 2:5-24, claim 1
• Technical Importance: This approach allows a single product to meet the needs of multiple, distinct installation environments, which the complaint alleges reduces material waste and simplifies inventory management for retailers and electricians Compl. ¶43

Key Claims at a Glance

• The complaint asserts infringement of all claims but focuses on elements from independent claims 1 and 9 Compl. ¶77, ¶80
• Essential Elements of Independent Claim 1:
  • A light source attachable to, and detachable from, a mounting surface in at least three different scenarios.
  • A body to which the light source is attached.
  • A plurality of "first clips" for attaching the light source when an existing recessed lighting fixture housing is available (first scenario).
  • A plurality of "second clips," different from the first clips, for attaching the light fixture when a recessed housing is not present (second scenario).
  • One or more "mounting attachments" for attaching the light fixture when an existing outlet or junction box is present (third scenario).
  • A junction box connectable to the body.
• The complaint does not explicitly reserve the right to assert dependent claims but alleges infringement of "each and every claim" 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’s background section states that consumers and electricians typically have to buy different LED recessed light fixtures for "new construction installations and retrofit installations," which can "reduce the amount of inventory carried by lighting distributors" ’118 Patent, col. 1:20-33
• The Patented Solution: The invention provides a single LED light fixture apparatus that includes two distinct sets of clips: a plurality of "retrofit clips" and a plurality of "new construction clips." The user can select and attach the appropriate set of clips to the fixture’s metal housing, allowing the same light fixture to be installed either into an existing recessed housing or directly into a ceiling where no housing is present ’118 Patent, col. 1:42-56 This dual-use capability is intended to save money and warehouse space for distributors Id. at col. 2:10-14
• Technical Importance: This invention provides a two-in-one solution for the most common recessed lighting installations, simplifying product selection for consumers and inventory for sellers Id. at col. 2:7-14

Key Claims at a Glance

• The complaint asserts infringement of all claims of the ’118 Patent Compl. ¶95
• Essential Elements of Independent Claim 1:
  • A plurality of "retrofit clips" adaptable to attach to the body of an LED light fixture.
  • A plurality of "new construction clips."
  • A plurality of connecting posts to hold the new construction clips.
  • A metal housing to embody the complete fixture.
  • A junction box to hold connection wirings.
  • A twist connector to attach the junction box wires to the metal housing.
  • The claim specifies that the retrofit clips "make a friction fit inside the recessed lighting fixture housing," while the new construction clips are attached to the connecting posts if no housing is present.
• The complaint does not explicitly reserve the right to assert dependent claims but alleges infringement of "each and every claim" Compl. ¶95

III. The Accused Instrumentality

Product Identification

• Home Depot SKU#1011028804 Model: NJ03a4IN3in1-W and SKU# 1011028805 Model: NJ03a6IN3in1-W Compl. ¶7

Functionality and Market Context

• The Accused Products are described and marketed as "3-in-1 Universal Installation" integrated LED recessed lights Compl. ¶79 The complaint provides a screenshot of a product page for the accused product, which describes it as a "3-in-1 Universal Installation 5/6 in. White Integrated LED Recessed Light" Compl. ¶62 The product's instruction manuals allegedly detail three different methods of installation, labeled "A," "B," and "C," corresponding to installation in an existing recessed housing, a "canless" installation directly into a ceiling, and installation into an existing junction box Compl. ¶81-82, ¶85-87

IV. Analysis of Infringement Allegations

U.S. Patent No. 12,359,783 Infringement Allegations

Identified Points of Contention

• Scope Questions: A central question may be whether the installation options offered by the Accused Product constitute three truly "different scenarios" as required by the claim. The defense may argue that the hardware used for a "Canless" installation (second scenario) and an "existing junction box" installation (third scenario) is substantially the same, or that the methods are not distinct enough to meet the claim limitation.
• Technical Questions: The analysis will question whether the "Spring Clips" and "spring-loaded clips" described in the complaint are structurally different from each other, as required by the claim language "a plurality of second clips, that is different than the plurality of first clips."

U.S. Patent No. 11,054,118 Infringement Allegations

Identified Points of Contention

• Scope Questions: Does the term "retrofit clips" as used in the patent read on the "clips" provided for recessed housing installation, and does "new construction clips" read on the "spring-loaded clips" for canless installation? The defense may argue that the product provides a single type of universal clip rather than two distinct types as claimed.
• Technical Questions: What evidence does the complaint provide that the Accused Products include distinct structures corresponding to "retrofit clips" and "new construction clips"? The infringement theory appears to rely on the manuals describing different uses for clips, which may or may not establish that the clips themselves are structurally distinct types.

V. Key Claim Terms for Construction

Term: "at least three different scenarios" (’783 Patent, Claim 1)

• Context and Importance: This term is the central feature of the ’783 Patent, defining its "3-in-1" functionality. The case may turn on whether the accused product's installation options meet this definition. Practitioners may focus on this term because the plaintiff’s theory relies on mapping the product’s three manual-described installation methods to the three scenarios recited in the claim.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The body of claim 1 itself defines the three scenarios by the condition of the mounting surface: (1) existing recessed housing is available, (2) recessed housing is not present, and (3) existing outlet/junction box is present. This could support an interpretation where any installation method tailored to one of these conditions qualifies as a distinct "scenario."
  • Evidence for a Narrower Interpretation: Claim 1 recites structurally distinct hardware for each scenario: "first clips," "second clips, that is different than the plurality of first clips," and "one or more mounting attachments." This suggests a "scenario" requires not just a different condition but also the use of a distinct set of hardware provided for that specific purpose, potentially narrowing the claim's scope.

Term: "retrofit clips" and "new construction clips" (’118 Patent, Claim 1)

• Context and Importance: The ’118 Patent's advance is providing a single fixture with two distinct types of clips for two distinct installation types. Infringement hinges on whether the accused product contains structures that meet both of these definitions.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the function of each clip type: "retrofit clips (102) make a friction fit inside the existing recessed lighting fixture housing" while "new construction clips (104) are attached to the connecting posts (106)" when no housing is present ’118 Patent, col. 4:20-24 This functional language could support construing any clip that performs the "retrofit" function as a "retrofit clip," regardless of its specific structure.
  • Evidence for a Narrower Interpretation: The patent consistently refers to the clips as distinct pluralities and assigns them different reference numerals (102 for retrofit, 104 for new construction), as shown in Figures 1, 3, 8A, and 8B. This separation in the figures and description may support an interpretation that the terms refer to two structurally different types of clips, not just a single type of clip used in two different ways.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement based on Defendant's providing installation instruction manuals that allegedly direct and encourage end-users to install the Accused Products in a manner that infringes the patents-in-suit Compl. ¶85-87, ¶97-98, ¶101
• Willful Infringement: The complaint alleges willfulness based on both pre-suit and post-suit knowledge. Pre-suit knowledge is alleged based on presentations made by the inventor to Home Depot personnel in 2019 regarding a "patent application" for the technology, and based on separate litigation involving the ’118 patent in 2023 Compl. ¶46-50, ¶61 Post-suit knowledge is alleged based on a demand letter sent in July 2025 regarding the ’783 patent and subsequent correspondence Compl. ¶66, ¶71

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

• A core issue will be one of definitional scope: Do the accused product's installation options, described as "3-in-1," map directly onto the "at least three different scenarios" as defined by Claim 1 of the ’783 patent, particularly given the claim's requirement for structurally distinct hardware for each scenario?
• A second primary issue will be one of structural differentiation: Does the mounting hardware included with the accused product constitute two distinct sets of clips corresponding to the "retrofit clips" and "new construction clips" required by Claim 1 of the ’118 patent, or does it provide a single, universal type of clip whose classification depends only on its method of use?
• A key question for damages will be one of knowledge and intent: To what extent did the alleged 2019 presentations, prior 2023 litigation, and 2025 demand letter provide Home Depot with pre-suit knowledge of infringement, and can the plaintiff prove that any continued infringement was egregious enough to warrant enhanced damages?