DCT

2:25-cv-01204

Xiamen Pvtech Corp Ltd v. Jiaxing Super Lighting Electric Appliance Co Ltd

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Amended Complaint
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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-01204, E.D. Tex., 08/27/2026
  • Venue Allegations: Venue is alleged to be proper because the defendants are not residents of the United States and therefore may be sued in any judicial district.
  • Core Dispute: Plaintiff alleges that Defendant's LED tube lighting products infringe ten U.S. patents related to various features of LED lamp technology, including color temperature adjustment, safety devices, and internal circuit design.
  • Technical Context: The lawsuit concerns LED tube lighting, an energy-efficient technology that has become a widespread replacement for traditional fluorescent lamps in commercial and industrial settings.
  • Key Procedural History: The complaint alleges a history of business disputes, including accusations of infringement by Defendant against Plaintiff and its customers, Amazon takedown procedures, and failed cross-licensing discussions. Plaintiff alleges it provided Defendant with notice of infringement and claim charts prior to filing suit, which Defendant allegedly dismissed.

Case Timeline

Date Event
2010-04-21 Plaintiff Pvtech is founded.
2017-07-07 Priority Date for '474 Patent.
2017-09-08 Priority Date for '571 Patent.
2018-08-17 Priority Date for '303 Patent.
2018-12-25 '571 Patent is issued.
2019-03-22 Priority Date for '784 Patent.
2019-07-09 '474 Patent is issued.
2019-10-31 Priority Date for '352 Patent.
2019-12-25 Priority Date for '065 Patent.
2020-05-05 '784 Patent is issued.
2020-06-01 Priority Date for '671 Patent.
2020-08-18 '303 Patent is issued.
2021-01-19 '352 Patent is issued.
2021-01-27 Priority Date for '150 Patent.
2021-05-31 Priority Date for '601 Patent.
2021-08-03 '065 Patent is issued.
2021-09-14 '671 Patent is issued.
2021-12-08 Priority Date for '419 Patent.
2021-12-28 '150 Patent is issued.
2022-08-09 '601 Patent is issued.
2022-12-27 '419 Patent is issued.
2023 Super Lighting allegedly initiates APEX process against Luxrite.
late 2024 Super Lighting allegedly accuses Pvtech directly of infringement.
2025-05-13 Super Lighting allegedly provides Pvtech a draft complaint.
2026-08-27 First Amended Complaint is filed.

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

U.S. Patent No. 11,209,150 - "Color temperature adjustable lamp socket and color temperature adjustable lamp tube"

The Invention Explained

  • Problem Addressed: The patent's background describes how existing tubular lamps typically offer only a single, fixed color temperature and power setting, which limits their application flexibility and increases inventory pressure on suppliers who must stock multiple versions of the same lamp ('150 Patent, col. 1:35-43).
  • The Patented Solution: The invention is a lamp socket that incorporates a "color temperature adjustment element," such as a switch, directly on its housing ('150 Patent, abstract). This element allows a user to select from two or more different sets of light-emitting members within the lamp tube, thereby changing the light's color temperature ('150 Patent, col. 3:1-4). Figure 1 of the patent illustrates the lamp socket (11) with the adjustment member (111) as part of the overall lamp tube (1) ('150 Patent, Fig. 1).
  • Technical Importance: This technology allows a single lamp product to be customized for various environments, offering greater flexibility to end-users and simplifying inventory management for manufacturers and distributors.

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶47).
  • Essential elements of claim 1 include:
    • A housing with an opening.
    • A color temperature adjustment element (a switch) disposed on the housing and connected to multiple light-emitting members corresponding to different color temperatures.
    • A protection cover disposed on the housing with a switch slot, which covers the opening and from which the switch's control portion is exposed.
    • The protection cover comprises a bottom plate and two side wings.
  • The complaint reserves the right to assert additional claims (Compl. ¶45).

U.S. Patent No. 11,536,419 - "Lighting device with improved luminous performance"

The Invention Explained

  • Problem Addressed: The patent background identifies the problem of non-uniform luminous performance in lighting devices, which can result from using LEDs from different production batches that have inconsistent characteristics, or from circuit designs that create impedance imbalances between different light paths ('419 Patent, col. 1:12-34).
  • The Patented Solution: The invention proposes a circuit board design with at least two serpentine "light paths" arranged in a "staggered arrangement" and connected in parallel ('419 Patent, abstract). Light sources (LEDs) are strategically distributed over specific "bending portions" of these paths. This specific geometric layout is designed to make the total impedance of each light path substantially equal, ensuring that the current flowing through them is balanced and the resulting light output is uniform ('419 Patent, col. 2:35-50).
  • Technical Importance: This circuit architecture aims to improve the visual quality and consistency of LED lighting while potentially reducing manufacturing costs by allowing for greater tolerance in the selection of LED components.

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶56).
  • Essential elements of claim 1 include:
    • A first light path with first and second bending portions in a staggered arrangement.
    • A plurality of first light sources distributed over the second bending portions.
    • A second light path connected in parallel to the first, also with a staggered arrangement of third and fourth bending portions.
    • A plurality of second light sources distributed over the third bending portions.
    • The arrangement is such that the total impedance of the first light path is substantially equal to the total impedance of the second light path.
  • The complaint reserves the right to assert additional claims (Compl. ¶54).

Multi-Patent Capsule: U.S. Patent No. 10,161,571 - "LED tube with safety device"

  • Technology Synopsis: The patent addresses the risk of fire or damage in LED tubes when a poor electrical contact causes high temperatures ('571 Patent, col. 1:11-18). The solution involves placing fuses directly at the conductive needle groups (pins) of the lamp, such that heat from a poor contact will melt the fuse and cut the current flow, preventing damage ('571 Patent, abstract; '571 Patent, col. 2:39-54).
  • Asserted Claims: At least claim 1 (Compl. ¶65).
  • Accused Features: The accused LED tube products are alleged to incorporate the claimed safety device with fuses at the conductive needle groups (Compl. ¶63).

Multi-Patent Capsule: U.S. Patent No. 10,749,303 - "Lamp device with changeable lamp socket"

  • Technology Synopsis: The patent addresses the problem of incompatibility between different lamp tubes and lamp holders ('303 Patent, col. 1:15-24). The invention is a modular system with a base lamp socket and detachable "adapter covers," allowing a single lamp tube to be fitted with different end-cap configurations to match various fixtures ('303 Patent, abstract).
  • Asserted Claims: At least claim 1 (Compl. ¶74).
  • Accused Features: The accused products are alleged to feature the claimed changeable lamp socket system (Compl. ¶72).

Multi-Patent Capsule: U.S. Patent No. 10,349,474 - "Lamp tube capable of rectifying and stabilizing voltages"

  • Technology Synopsis: The patent addresses the issue of a single LED lamp tube needing to be compatible with different types of ballasts (e.g., electronic or inductor) ('474 Patent, col. 1:35-40). The solution is an internal circuit with a polarity conversion module, a suppressor, and a voltage buck-booster module that allows the lamp tube to rectify and stabilize input voltages from various power sources ('474 Patent, abstract).
  • Asserted Claims: At least claim 1 (Compl. ¶83).
  • Accused Features: The accused products are alleged to contain circuitry capable of rectifying and stabilizing voltages as claimed (Compl. ¶81).

Multi-Patent Capsule: U.S. Patent No. 10,645,784 - "Electric leakage protection electronic rectifier and lamp with electric leakage protection electronic rectifier"

  • Technology Synopsis: The patent addresses safety and longevity issues in certain LED lamps where high output from a ballast can exceed what the LEDs can tolerate ('784 Patent, col. 1:41-47). The invention is an electronic rectifier with a leakage detecting module and a driving module that includes a "current-limiting control unit" to limit the output current and prevent it from exceeding the lamp's tolerable range ('784 Patent, abstract).
  • Asserted Claims: At least claim 1 (Compl. ¶92).
  • Accused Features: The accused products are alleged to use an electronic rectifier with the claimed current-limiting protection features (Compl. ¶90).

Multi-Patent Capsule: U.S. Patent No. 11,122,671 - "Light tube with anti-electric shock protection function and capable of being supplied with electricity by electrical ballast and alternate-current power supply in working frequency"

  • Technology Synopsis: The patent describes a safety function to prevent electric shock during installation if a user touches the conductive pins ('671 Patent, abstract). It uses a direct-current filtering circuit to generate a "false voltage" that is detected by an anti-electric shock control circuit. This design prevents the lamp from fully activating unless properly installed in a fixture, enhancing safety ('671 Patent, abstract).
  • Asserted Claims: At least claim 1 (Compl. ¶101).
  • Accused Features: The accused products are alleged to include the claimed anti-electric shock protection circuitry (Compl. ¶99).

Multi-Patent Capsule: U.S. Patent No. 10,895,352 - "LED tube capable of being supplied with electricity by electrical ballast and mains supply"

  • Technology Synopsis: This patent aims to create an LED tube that is compatible with both direct mains power and existing electronic ballasts, simplifying retrofits ('352 Patent, col. 1:31-36). It discloses a "voltage impedance signal-recognizing device" that detects the voltage state from the power source (mains or ballast) and generates the appropriate DC starting voltage for the lamp's LEDs ('352 Patent, abstract).
  • Asserted Claims: At least claim 1 (Compl. ¶110).
  • Accused Features: The accused products, particularly those marketed as "Type A/B," are alleged to contain the claimed power source recognition and adaptation circuitry (Compl. ¶108).

Multi-Patent Capsule: U.S. Patent No. 11,408,601 - "Illumination device with couple lamp tubes having temperature and power adjustment functions"

  • Technology Synopsis: The patent addresses the inconvenience of adjusting color temperature and power on LED lamps, and the difficulty of transporting long lamp tubes ('601 Patent, col. 1:28-34). The invention is a modular, two-part lamp tube system joined by a coupling assembly, where one tube has a color temperature switch and the other has a power adjustment terminal ('601 Patent, abstract).
  • Asserted Claims: At least claim 1 (Compl. ¶119).
  • Accused Features: The accused products, particularly longer models, are alleged to use the claimed coupled-tube design with adjustment functions (Compl. ¶117).

Multi-Patent Capsule: U.S. Patent No. 11,083,065 - "Driving circuit device for anti-leakage LED tube with dual-end input"

  • Technology Synopsis: The patent seeks to provide an improved anti-leakage driving circuit for dual-end input LED tubes to prevent electric shock ('065 Patent, col. 1:10-13). The solution is an integrated circuit combining an anti-leakage detection module and a constant current module that detects a current state (e.g., leakage) and controls the output current to not exceed a rated safety standard ('065 Patent, abstract).
  • Asserted Claims: At least claim 1 (Compl. ¶128).
  • Accused Features: The accused products are alleged to incorporate the claimed integrated anti-leakage driving circuit (Compl. ¶126).

III. The Accused Instrumentality

Product Identification

The complaint accuses a broad category of LED tube lighting products allegedly manufactured by Defendant Super Lighting and sold under its own name or rebranded for other suppliers (Compl. ¶22). These suppliers include RAB Lighting, PLT Solutions, Keystone Technologies, Light Efficient Design, and Green Creative (Compl. ¶20). The complaint lists dozens of specific model numbers as exemplary accused products (Compl. ¶¶23-27).

Functionality and Market Context

The accused products are LED tube lights designed to replace traditional fluorescent tubes (Compl. ¶1). Many are identified as "Type B" (operates without a ballast) and feature user-adjustable settings, such as selectable color temperature (CCT) and wattage (Compl. p. 8; Compl. p. 11). The complaint uses a screenshot of an online retail listing for a "RAB 96" Field-Adjustable LED T8" to show an example of an accused product with "Wattage & CCT Selectable" functionality (Compl. p. 8). The complaint alleges that Defendant is the original manufacturer of these products, citing identical technical specifications on the DesignLights Consortium (DLC) Qualified Products List for products registered to both Super Lighting and its branded reseller partners (Compl. ¶¶21-22). The products are allegedly sold throughout the United States via the internet and through brick-and-mortar distributors located in the judicial district (Compl. ¶7). A screenshot from RAB Lighting's website shows distributors located in Marshall, Texas, the division where the case was filed (Compl. p. 7).

IV. Analysis of Infringement Allegations

The complaint references, but does not include, claim chart exhibits (Exhibits 11-20) that purportedly detail the infringement of each patent-in-suit (Compl. ¶28). The complaint alleges that the accused products satisfy each limitation of at least claim 1 of each asserted patent (Compl. ¶47; Compl. ¶56).

For U.S. Patent No. 11,209,150, the infringement theory is predicated on accused products that feature adjustable color temperatures. The complaint provides a screenshot of a product listing for a "PLT... LED T8 Tube - Color Selectable" that advertises five adjustable color temperatures (3000K, 3500K, 4000K, 5000K, and 6500K) adjusted via a switch on the end cap (Compl. p. 11). The plaintiff's theory is that this functionality is achieved using a "color temperature adjustment element" on the lamp's "housing," as recited in claim 1 of the '150 Patent.

For U.S. Patent No. 11,536,419, the infringement theory centers on the internal circuit board design of the accused products. The complaint does not provide any direct evidence of the products' internal construction. The infringement allegation rests on the assertion that these products contain the claimed parallel, serpentine light paths in a "staggered arrangement" to achieve uniform luminous performance, as required by claim 1 of the '419 Patent. Proving this allegation would necessitate reverse engineering of the accused products.

  • Identified Points of Contention:
    • Scope and Factual Questions for the '150 Patent: A central question will be whether the physical switch mechanism on the accused products (often a small dip switch on the lamp's end cap) falls within the court's construction of the claim term "color temperature adjustment element." The analysis will also involve a factual comparison of the accused device's structure to the claim's requirement that the element is disposed on the "housing" and covered by a "protection cover."
    • Technical and Evidentiary Questions for the '419 Patent: The dispute over the '419 Patent will likely be highly technical and factual. The key question is whether the printed circuit boards within the accused products actually implement the specific "staggered arrangement" of serpentine light paths with LEDs distributed in the claimed manner. This suggests that the case will depend heavily on evidence obtained through discovery and reverse engineering, followed by expert testimony on circuit design and operation.

V. Key Claim Terms for Construction

'150 Patent

  • The Term: "color temperature adjustment element"
  • Context and Importance: This term is the central feature of claim 1. The outcome of the infringement analysis for the '150 Patent may depend on whether the physical switches used in the accused products are encompassed by the definition of this term. Practitioners may focus on this term because the patent's embodiments show specific types of switches (a lever and a slidable button), which Defendant may argue limits the claim's scope.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself is broad, referring to an "element" that adjusts color temperature. The abstract also uses the general term "adjustment member" ('150 Patent, abstract). Plaintiff may argue this suggests the claim is not limited to a specific type of switch.
    • Evidence for a Narrower Interpretation: The specification explicitly discloses a "control lever" and a "slidable button" as examples of the control portion ('150 Patent, col. 3:30-31; '150 Patent, col. 5:54-55). Figures 2A and 5A depict these specific structures. Defendant may argue that these embodiments define the scope of the term and exclude other types of switches, such as recessed dip switches commonly found on such products.

'419 Patent

  • The Term: "staggered arrangement"
  • Context and Importance: This term describes the novel spatial relationship between the multiple serpentine light paths, which is the core of the invention's solution for achieving uniform brightness. Infringement hinges on whether the circuit layout in the accused products meets this structural definition.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent abstract describes the arrangement as "staggered" without imposing rigid geometric constraints, suggesting any layout where the paths are offset could qualify. The purpose of the arrangement is to equalize impedance ('419 Patent, col. 2:42-45), which could support a more functional interpretation.
    • Evidence for a Narrower Interpretation: The figures, particularly Figure 2, depict a specific, interlocking, serpentine pattern where the "bending portions" of one path fit between the bending portions of the other ('419 Patent, Fig. 2). A defendant may argue that "staggered arrangement" requires this specific interlocking topology, and that simpler parallel, offset paths would not infringe.

VI. Other Allegations

Indirect Infringement

The complaint alleges that Super Lighting indirectly infringes all ten patents by inducing its customers to use the accused products (Compl. ¶46; Compl. ¶55; Compl. ¶64). The basis for inducement is alleged to be Defendant's knowledge that the products infringe while providing them to customers for their intended use.

Willful Infringement

The complaint makes detailed allegations of willful infringement for all asserted patents. The basis is alleged pre-suit knowledge stemming from a period of prior engagement between the parties (Compl. ¶¶37-41). The complaint specifically alleges that in late 2024, Super Lighting directly accused Pvtech of infringement (of Super Lighting's own patents), and in response, Pvtech provided "detailed legal support for its non-infringement position and identified Super Lighting products that infringed Pvtech's patents" (Compl. ¶39; Compl. ¶40). The complaint further alleges that despite this notice, Super Lighting "refused, dismissed Pvtech's patent portfolio" and later sent a draft complaint, demanding a settlement (Compl. ¶40; Compl. ¶41). These allegations of direct, pre-suit notice and subsequent disregard form the basis for the willfulness claims (Compl. ¶51; Compl. ¶60).

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

  1. Evidentiary Proof vs. Allegation: A central issue for many of the asserted patents, particularly the '419 Patent concerning circuit design, will be a question of technical fact. Does the internal construction of the accused products, which must be determined through discovery and likely reverse engineering, actually practice the specific circuit layouts, safety mechanisms, and power compatibility features recited in the claims? The complaint currently lacks direct evidence on these points.
  2. Claim Construction and Scope: The case will likely feature a significant battle over definitional scope. For the '150 Patent, can the term "color temperature adjustment element," illustrated with user-operable levers and sliders, be construed to cover the potentially different switch types used in the accused products? Similarly, the meaning of "staggered arrangement" in the '419 Patent will be critical to determining if a merely offset layout infringes, or if a specific interlocking topology is required.
  3. Willfulness and Pre-Suit Conduct: A key question for damages will be the parties' pre-suit conduct. The complaint alleges that Pvtech provided specific notice of infringement, which Super Lighting allegedly dismissed. The court will need to evaluate the adequacy of this notice and Defendant's response to determine if any infringement was willful, which could expose the Defendant to enhanced damages.