ElectraLED Inc v. Guangzhou Shehds Stage Lighting Equipment Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ElectraLED, Inc. (Florida)
  • Defendant: Guangzhou SHEHDS Stage Lighting Equipment Co. Ltd. (China)
  • Plaintiff’s Counsel: Garteiser Honea, PLLC
• Case Identification: 2:26-cv-00071, E.D. Tex., 01/23/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas under the "alien venue rule," asserting that Defendant is a foreign entity that maintains a regular and established business presence in the United States and conducts substantial business in the district.
• Core Dispute: Plaintiff alleges that Defendant’s commercial LED stage lighting fixtures infringe patents related to durable light fixture designs with improved thermal management properties.
• Technical Context: The technology concerns heat dissipation in high-power LED lighting, a critical factor for ensuring the longevity and performance of commercial and industrial fixtures.
• Key Procedural History: The complaint asserts that U.S. Patent No. 7,651,245 is a "pioneering patent" that has been cited as relevant prior art in 191 subsequent U.S. patent applications.

Case Timeline

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

U.S. Patent No. 7,651,245 - LED LIGHT FIXTURE WITH INTERNAL POWER SUPPLY, Issued Jan. 26, 2010

The Invention Explained

• Problem Addressed: Prior art commercial light fixtures were often inefficient, costly, and produced poor quality light. While LED fixtures offered improvements, embedding the necessary power supply inside a rugged housing created a new problem: heat generated by the LEDs could cause the heat-sensitive power supply to fail, reducing the fixture's reliability. (Compl. ¶¶ 15-16; ’245 Patent, col. 1:26-44, 1:56-61).
• The Patented Solution: The invention is a light fixture design that physically and thermally isolates an internal power supply from the heat-generating LED light engine. This is achieved by placing the power supply in a box within a "receptacle" formed by an array of external heat-dissipating fins on the main housing. Heat from the LEDs is conducted into the housing and fins and dissipated into the ambient air, creating a flow path that bypasses the power supply. (’245 Patent, Abstract; col. 2:1-7).
• Technical Importance: This design sought to combine the durability of an internally-housed power supply with the reliability needed for long-life LED systems in demanding commercial environments like warehouses and loading docks. (Compl. ¶16).

Key Claims at a Glance

• The complaint asserts independent claim 21. (Compl. ¶23).
• Claim 21 requires:
  • A housing with a flange, an internal receiver, a frontal lens, and an array of fins defining a rear receptacle.
  • A light engine assembly mounted to the receiver, including LEDs on a printed circuit board.
  • A power supply residing within the rear receptacle and enclosed by a rear cover.
  • A functional limitation wherein heat from the LEDs is dissipated by the fins "without the use of a fan."
• The complaint reserves the right to assert additional claims. (Compl. ¶23).

U.S. Patent No. 9,618,187 - LED LIGHT FIXTURE, Issued Apr. 11, 2017

The Invention Explained

• Problem Addressed: The patent background reiterates the thermal management challenges of prior LED fixtures and also notes the limitations of conventional track lighting systems. High-wattage incandescent fixtures limit the number of units per circuit, whereas the lower power draw of LEDs allows for significantly more fixtures, reducing infrastructure costs. (’187 Patent, col. 1:38-59).
• The Patented Solution: The invention describes a light fixture, suitable for track lighting, featuring a circular housing with a central spindle and radiating fins. This design creates an air flow passageway from inlets in the front lens cover, across the LED modules, through a gap between the circuit board and the housing, and out through vents in the housing's rear. This structure uses passive air convection to cool the light engine. The power supply is described as external, housed in a separate enclosure. (’187 Patent, Abstract; col. 2:13-20).
• Technical Importance: This architecture provides a self-cooling system for a compact, high-output LED fixture, making it suitable for applications where many lights are needed on a single circuit. (Compl. ¶13).

Key Claims at a Glance

• The complaint asserts independent claim 1. (Compl. ¶24).
• Claim 1 requires:
  • A housing with a circular main body portion, a rear wall, and a front flange.
  • A plurality of fins "integrally extending" from the outer surface of the rear wall.
  • A light engine assembly positioned within the main body portion, with a printed circuit board residing against an internal mounting surface.
  • A front lens cover affixed to another internal mounting surface.
• The complaint reserves the right to assert additional claims. (Compl. ¶24).

III. The Accused Instrumentality

Product Identification

The complaint identifies a series of light fixtures, including models SHE-BWBE1915D-BPUS and SH-CORALP18A-IPUS, collectively termed the "Accused Instrumentalities." (Compl. ¶¶ 21-22).

Functionality and Market Context

The Accused Instrumentalities are described as light fixtures utilizing durable designs with improved thermal management properties. (Compl. ¶21). A product image for the "CORALPAR Waterproof 18x12W LED Flat Par Light" shows a self-contained stage light with a circular face, multiple LED lenses, and a rugged, finned housing. (Compl. p. 7). The complaint alleges these products are sold and offered for sale in the United States through various channels, including resellers and Defendant's own websites. (Compl. ¶28).

IV. Analysis of Infringement Allegations

The complaint does not provide a detailed claim chart. The following tables summarize the infringement theory based on the complaint's narrative allegations and visual evidence.

’245 Patent Infringement Allegations

’187 Patent Infringement Allegations

• Identified Points of Contention:
  • Architectural Questions: A potential point of contention for the ’187 patent infringement allegation is the difference in overall architecture. The ’187 patent specification describes a system with an external power supply enclosure and specific air flow channels for cooling (’187 Patent, col. 8:26-34), while the accused product depicted appears to be a self-contained unit, which may more closely align with the internal power supply architecture of the ’245 patent.
  • Scope Questions: The analysis may raise the question of whether the physical structures of the accused products meet the specific definitions of claimed elements, such as the ""internal receiver"" and ""receptacle"" in the ’245 patent, or if the fins are ""integrally extending"" as required by the ’187 patent.
  • Technical Questions: The complaint provides little direct evidence of the internal configuration of the accused products. A key question will be whether discovery reveals that the internal power supply placement and thermal management systems function in the manner required by the asserted claims.

V. Key Claim Terms for Construction

• The Term: "power supply residing within the rear receptacle" (’245 Patent, Claim 21)

  • Context and Importance: The location of the power supply relative to the heat-dissipating fins is the core of the ’245 patent's thermal isolation invention. The definition of "receptacle" (which the claim states is defined by the fins) and the meaning of "residing within" will be central to determining whether the accused products, which may have power supplies mounted to the rear of the housing, meet this limitation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party might argue that "residing within" simply means being located in the general area defined by the fins, not necessarily fully enclosed by them on all sides.
    • Evidence for a Narrower Interpretation: The patent specification shows the power supply box (30) fitting "substantially within the rear receptacle 105" formed by the fins. (’245 Patent, col. 4:26-29; Fig. 3). This depiction may support a narrower construction requiring the power supply to be nestled among the fins.

• The Term: "fins integrally extending from an outer surface of the rear wall" (’187 Patent, Claim 1)

  • Context and Importance: This term defines the physical relationship between the heat-dissipating fins and the main housing. Practitioners may focus on this term because its construction could determine whether fixtures with fins attached via secondary means (e.g., welding, fasteners) infringe, or if the claim is limited to single-piece constructions.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party could argue that "integrally" refers to a functional integration where the fins are a permanent and thermally conductive part of the housing, regardless of manufacturing method.
    • Evidence for a Narrower Interpretation: The specification describes the housing as a "uniquely shaped, die cast head," which implies the fins and housing are formed as a single, monolithic piece. (’187 Patent, col. 6:64-65). This could support an interpretation requiring a one-piece casting.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, asserting that Defendant provides "tutorials, brochures, manuals, [and] instructional documents" that instruct others on how to use the accused products in an infringing manner. (Compl. ¶¶ 29, 39). It also alleges contributory infringement, claiming Defendant provides material parts of the invention that are not staple articles of commerce and are especially adapted for infringement. (Compl. ¶¶ 30, 40).
• Willful Infringement: Willfulness is alleged based on Defendant’s purported knowledge of the patents-in-suit "at least as early as the date of this Original Complaint." (Compl. ¶¶ 31, 41).

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

1. Architectural Congruence: A core issue will be one of technical alignment: can the plaintiff demonstrate that the accused products, which appear to be self-contained units, practice the specific claims of the ’187 patent, whose specification emphasizes an architecture with a physically separate, external power supply and a distinct convective air cooling path?
2. Structural Interpretation: The dispute will likely involve questions of definitional scope, particularly whether the internal power supply of the accused products is located "within the rear receptacle" as defined by claim 21 of the ’245 patent, and whether the fins are "integrally extending" as required by claim 1 of the ’187 patent.
3. Evidentiary Sufficiency: A central challenge for the plaintiff will be one of proof: moving beyond surface-level visual similarities, what evidence can be marshaled from product teardowns and technical discovery to demonstrate that the internal construction and thermal management methods of the Accused Instrumentalities map onto the specific structural and functional limitations of the asserted claims?