Bright Head LLC v. Individuals Corps Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Bright Head LLC (Delaware / New York)
  • Defendant: Unidentified Individuals, Corporations, and other entities operating e-commerce stores listed on Schedule A
  • Plaintiff’s Counsel: AVEK IP LLC; Haque III Legal Practice, LLC
• Case Identification: 5:26-cv-00404, W.D. Tex., 01/23/2026
• Venue Allegations: Venue is based on allegations that Defendants operate interactive e-commerce stores that target and sell products to consumers in the United States, including Texas.
• Core Dispute: Plaintiff alleges that Defendants’ unauthorized headlamp products, sold through various online storefronts, infringe a patent related to a hands-free, motion-activated headlamp system.
• Technical Context: The technology at issue involves wearable illumination devices, specifically headlamps designed for hands-free operation, a feature valuable in professional and consumer settings.
• Key Procedural History: The complaint does not reference prior litigation or administrative proceedings involving the patent-in-suit. It does, however, describe an alleged "ecosystem" of foreign sellers and service providers who actively monitor U.S. court filings to help infringers evade enforcement actions.

Case Timeline

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

U.S. Patent No. 10,928,052 - “Hands-Free Headlamp System”

• Patent Identification: U.S. Patent No. 10,928,052 (“Hands-Free Headlamp System”), issued February 23, 2021 (the “’052 Patent”).

The Invention Explained

• Problem Addressed: The patent’s background section identifies a problem for professionals like surgeons and dentists who require hands-free lighting but whose tasks are complicated by the need to physically touch a headlamp to turn it on or off. This contact can lead to contamination of sterile gloves, causing inconvenience and wasted time ’052 Patent, col. 1:35-44
• The Patented Solution: The invention proposes a headlamp system that attaches to headwear and is operated without physical contact. The system uses a motion sensor, such as an infrared sensor, to detect hand motions near the user's head, allowing the user to toggle the light source on and off by waving a hand nearby ’052 Patent, Abstract; col. 2:3-18 The components—including a light source, power source, controller, and motion sensor—are integrated into housings that attach to items like glasses, helmets, or headbands ’052 Patent, Fig. 2
• Technical Importance: This approach provides a method for controlling a wearable light that avoids physical contact, which is significant in settings where hands are occupied or must remain sterile ’052 Patent, col. 1:40-44

Key Claims at a Glance

• The complaint asserts at least independent Claim 1 and reserves the right to assert all other claims Compl. ¶¶ 27-28
• Independent Claim 1 recites a headlamp system with the following essential elements:
  • A "first housing" that includes a headwear fastener, an energy storage unit, a headlamp, and a controller.
  • The headlamp is connected to the housing and electrically connected to the energy storage.
  • The controller is connected to the housing, the energy storage, and the headlamp.
  • A "second housing" that includes a motion sensor connected to the controller.

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are referred to generically as "Unauthorized Products," described as hands-free headlamp systems sold by the Defendants through various e-commerce stores Compl. ¶¶ 2, 4

Functionality and Market Context

• The complaint does not provide a detailed technical breakdown of the accused products' functionality. It alleges that the products embody the patented invention and are sold to consumers through online marketplaces like Amazon Compl. ¶13 The complaint asserts these products are offered by numerous foreign sellers operating under various aliases to conceal their identities and evade enforcement of Plaintiff's patent rights Compl. ¶¶ 4, 11, 18

IV. Analysis of Infringement Allegations

The complaint alleges that the "Unauthorized Products" sold by Defendants infringe at least Claim 1 of the ’052 Patent Compl. ¶27 The complaint states that element-by-element infringement is detailed in claim charts attached as Exhibit 3; however, this exhibit was not filed with the complaint Compl. ¶27 Therefore, the pleading offers a conclusory allegation of infringement without providing a public-facing, element-level mapping of the accused products to the claim limitations.

The complaint’s broader infringement theory is contextualized by allegations of a sophisticated network of infringers. Figure 1, a screenshot of the website sellerdefense.cn, is presented as evidence of an "ecosystem" that allegedly helps sellers monitor U.S. intellectual property lawsuits to avoid accountability Compl. ¶21, Fig. 1 This allegation may be used to support claims of knowing and willful infringement.

Identified Points of Contention

• Structural Mismatch Question: Claim 1 explicitly recites "a first housing" containing the headlamp and controller, and "a second housing" containing the motion sensor. A primary point of contention may be whether the accused products, which may be constructed as single, integrated units, meet this two-housing limitation. The dispute will question whether distinct compartments within a single physical unit can satisfy the "first" and "second" housing elements.
• Functional Evidence Question: The complaint does not provide evidence that the accused products actually operate via a motion sensor as required by the patent. A key question for discovery will be whether the accused products function through motion detection for hands-free control, or if they operate via a conventional physical switch, which would not meet a key functional aspect of the invention.

V. Key Claim Terms for Construction

• The Term: "a first housing" / "a second housing"
• Context and Importance: The construction of these terms appears central to the infringement analysis. If the court construes "housing" to require two physically separate and distinct structures, any accused product with a single, unitary body would likely be found non-infringing. Practitioners may focus on this term because its interpretation could be dispositive of the infringement claim for many common headlamp designs.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification does not provide an explicit definition of "housing." A party might argue for the plain and ordinary meaning, which could potentially cover distinct modules or sections within a larger, single-piece assembly.
  • Evidence for a Narrower Interpretation: The language of Claim 1 itself structurally separates the components into two distinct lists, each associated with a different housing ’052 Patent, col. 6:12-23 Additionally, figures in the patent depict system components that are physically separated (e.g., the light source (130) is shown separate from the controller and sensor assembly (140, 150)) ’052 Patent, Figs. 3-4 This evidence may support a narrower construction requiring two physically separate enclosures.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendants induce and contribute to infringement by consumers and downstream sellers who purchase and use the accused products Compl. ¶28 The pleading does not, however, detail specific acts of inducement, such as referencing user manuals or advertising materials.
• Willful Infringement: Willfulness is alleged based on the assertion that Defendants are part of a sophisticated operation that knowingly infringes patents and uses tactics to evade legal consequences Compl. ¶¶ 19-21, 31 The complaint cites websites and online communities that allegedly provide infringers with strategies to avoid detection and enforcement, suggesting a deliberate disregard for Plaintiff's patent rights Compl. ¶19

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

This dispute, in its early stage, presents two central questions for the court and the parties:

• A core issue will be one of definitional scope: can the claim terms "a first housing" and "a second housing" be construed to read on a headlamp constructed with a single, integrated physical body, or do they strictly require two physically separate enclosures as the claim language suggests?
• A key evidentiary question will be one of technical proof: can the Plaintiff, facing Defendants alleged to be anonymous and evasive, obtain sufficient discovery to prove that the "Unauthorized Products" actually contain and practice every technical element of the asserted claim, most notably the motion-sensor functionality for hands-free activation?