Jiaxing Super Lighting Electric Appliance, Co. v. Ch Lighting Technology Co., Ltd.

CourtCourt of Appeals for the Federal Circuit
DecidedJuly 28, 2025
Docket23-1715
StatusPublished

This text of Jiaxing Super Lighting Electric Appliance, Co. v. Ch Lighting Technology Co., Ltd. (Jiaxing Super Lighting Electric Appliance, Co. v. Ch Lighting Technology Co., Ltd.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Federal Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jiaxing Super Lighting Electric Appliance, Co. v. Ch Lighting Technology Co., Ltd., (Fed. Cir. 2025).

Opinion

Case: 23-1715 Document: 64 Page: 1 Filed: 07/28/2025

United States Court of Appeals for the Federal Circuit ______________________

JIAXING SUPER LIGHTING ELECTRIC APPLIANCE, CO., LTD., OBERT, INC., Plaintiffs-Appellees

v.

CH LIGHTING TECHNOLOGY CO., LTD., ELLIOTT ELECTRIC SUPPLY, INC., SHAOXING RUISING LIGHTING CO., LTD., Defendants-Appellants ______________________

2023-1715 ______________________

Appeal from the United States District Court for the Western District of Texas in No. 6:20-cv-00018-ADA, Judge Alan D. Albright. ______________________

Decided: July 28, 2025 ______________________

MATTHEW COOK BERNSTEIN, Perkins Coie LLP, San Di- ego, CA, argued for plaintiffs-appellees. Also represented by EVAN SKINNER DAY, ABIGAIL A. GARDNER, JOSEPH P. REID; DAN L. BAGATELL, Hanover, NH.

JEFFREY A. LAMKEN, MoloLamken LLP, Washington, DC, argued for defendants-appellants. Also represented by CALEB HAYES-DEATS, LUCAS M. WALKER; ALEXANDRA C. EYNON, SWARA SARAIYA, New York, NY. Case: 23-1715 Document: 64 Page: 2 Filed: 07/28/2025

______________________

Before DYK, CHEN, and HUGHES, Circuit Judges. DYK, Circuit Judge. Jiaxing Super Lighting Electric Appliance Co., Ltd. and its North American affiliate Obert, Inc. (collectively, “Super Lighting”) brought suit against CH Lighting Tech- nology Co., Ltd., Elliott Electric Supply, Inc., and Shaoxing Ruising Lighting Co., Ltd. (collectively, “CH Lighting”) for infringement of U.S. Patent Nos. 10,295,125 (the “’125 pa- tent”), 10,352,540 (the “’540 patent”), and 9,939,140 (the “’140 patent”). Before trial, CH Lighting conceded infringe- ment of the ’125 and ’540 patents. At trial, the district court granted Super Lighting’s motions to exclude evidence relating to the validity of the asserted claims of the ’125 and ’540 patents and subsequently granted Super Light- ing’s motion for judgment as a matter of law (“JMOL”) that the ’125 and ’540 patents were not invalid on the ground of an on-sale bar. A jury found the ’140 patent infringed and not invalid and awarded damages for infringement of claims of the three patents. CH Lighting appeals. We conclude as follows. First, the district court erred in granting JMOL that the ’125 and ’540 patents were not invalid because it erroneously prevented CH Lighting from presenting evidence of their invalidity; the district court was required to hold a new trial as to the invalidity of the ’125 and ’540 patents. Second, with respect to the ’140 pa- tent, substantial evidence supports the jury’s verdicts of in- fringement and no invalidity. Third, the district court should assess the reliability of Ms. Kindler’s testimony con- sistent with this court’s recent en banc decision in EcoFac- tor and under Rule 702 of the Federal Rules of Evidence. Accordingly, a new trial is required as to the validity of the ’125 and ’540 patents and as to damages for infringement of all three patents. We accordingly affirm-in-part, Case: 23-1715 Document: 64 Page: 3 Filed: 07/28/2025

JIAXING SUPER LIGHTING ELECTRIC APPLIANCE, CO. v. 3 CH LIGHTING TECHNOLOGY CO., LTD.

reverse-in-part, vacate-in-part, and remand for further proceedings consistent with this opinion. BACKGROUND I Super Lighting owns the three asserted patents, which relate generally to light-emitting diode (“LED”) tube lamps. LED tube lamps resemble traditional incandescent and fluorescent tube lamps and can operate in fluorescent light fixtures. LED tube lamps typically comprise a lamp tube, an LED light strip, two end caps, and a power source that supplies external electricity to one or both of the end caps. LED tube lamps are more energy efficient and last longer than their incandescent and fluorescent counter- parts. The ’125 and ’540 patents (together, the “tube patents”) both relate to purported structural improvements in LED tube lamps. The ’125 patent discloses an LED tube lamp in which a flexible printed circuit board is mounted directly onto the tube’s inner surface.1 Claim 1 is the only claim of the ’125 patent that is the subject of this appeal and recites: 1. An LED tube lamp, comprising: a lamp tube;

1 This is in contrast to LED tube lamps’ usual struc- tural configuration, in which the lamp’s circuit board is supported on aluminum rails encased in plastic insulating sleeves. This configuration apparently has several draw- backs, since the plastic sleeves may change color as they age—thereby affecting lighting quality—and the rails can block transmission of light in certain directions. According to the ’125 patent’s specification, relocating the circuit board to the tube’s inner circumference improves bright- ness and light quality. Case: 23-1715 Document: 64 Page: 4 Filed: 07/28/2025

two end caps, each of the two end caps cou- pled to a respective end of the lamp tube; a power supply disposed in one or two end caps; an LED light strip disposed on an inner cir- cumferential surface of the lamp tube, the LED light strip comprising a mounting re- gion and a connecting region, the mounting region for mounting a plurality of LED light sources, the connecting region having at least two soldering pads, and the mount- ing region and the connecting region being electrically connected to the plurality of LED light sources and the power supply; and a protective layer disposed on a surface of the LED light strip, the protective layer having a plurality of first openings to ac- commodate the plurality of LED light sources and at least two second openings to accommodate the at least two soldering pads. ’125 patent, col. 99 ll. 7–24. The ’540 patent builds on the ’125 patent by including a diffusion film that can be placed on the tube lamp to pro- vide a uniform glow.2 Claims 13 and 14 are the only claims

2 Since LEDs are spot light sources, the light emitted by them does not necessarily contribute to uniform illumi- nance of the entire tube lamp without optical manipula- tion. The ’540 patent’s specification states that using a diffusion film is a useful measure “to avoid grainy visual effects.” ’540 patent col. 2 l. 15. Case: 23-1715 Document: 64 Page: 5 Filed: 07/28/2025

JIAXING SUPER LIGHTING ELECTRIC APPLIANCE, CO. v. 5 CH LIGHTING TECHNOLOGY CO., LTD.

of the ’540 patent that are the subject of this appeal and recite: 13. An LED tube lamp, comprising: a tube, comprising: a main body; and two rear end regions respectively at two ends of the main body; two end caps respectively sleeving the two rear end regions, each of the end caps com- prising: a lateral wall substantially coaxial with the tube, the lateral wall sleeving the respective rear end re- gion; an end wall substantially perpen- dicular to the axial direction of the tube; and two pins on the end wall for receiv- ing an external driving signal; an LED light strip disposed on an inner cir- cumferential surface of the main body with a plurality of LED light sources mounted thereon; a power supply comprising a circuit board and configured to drive the plurality of LED light sources, the circuit board dis- posed inside one of the rear end regions and one of the end caps; an adhesive disposed between each of the lateral wall and each of the rear end re- gions; and Case: 23-1715 Document: 64 Page: 6 Filed: 07/28/2025

a diffusion film disposed on the glass lamp tube so that light emitted from the LED light sources passing through the inner surface of the glass lamp tube and then passing through the diffusion film on the glass lamp tube. 14. The LED tube lamp of claim 13, wherein a por- tion of the circuit board, one of the rear end regions, the adhesive and one of the lateral wall are stacked sequentially in a radial direction of the LED tube lamp.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Daubert v. Merrell Dow Pharmaceuticals, Inc.
509 U.S. 579 (Supreme Court, 1993)
Pfaff v. Wells Electronics, Inc.
525 U.S. 55 (Supreme Court, 1998)
Finisar Corp. v. DirecTV Group, Inc.
523 F.3d 1323 (Federal Circuit, 2008)
Verizon Services Corp. v. Vonage Holdings Corp.
503 F.3d 1295 (Federal Circuit, 2007)
ACCO Brands, Inc. v. ABA Locks Manufacturer Co.
501 F.3d 1307 (Federal Circuit, 2007)
Microsoft Corp. v. i4i Ltd. Partnership
131 S. Ct. 2238 (Supreme Court, 2011)
Meyer Intellectual Properties Ltd. v. Bodum, Inc.
690 F.3d 1354 (Federal Circuit, 2012)
Laserdynamics, Inc. v. Quanta Computer, Inc.
694 F.3d 51 (Federal Circuit, 2012)
Ericsson, Inc. v. D-Link Systems, Inc.
773 F.3d 1201 (Federal Circuit, 2014)
Omega Patents, LLC v. Calamp Corp.
920 F.3d 1337 (Federal Circuit, 2019)
Power Mosfet Technologies, L.L.C. v. Siemens AG
378 F.3d 1396 (Federal Circuit, 2004)

Cite This Page — Counsel Stack

Bluebook (online)
Jiaxing Super Lighting Electric Appliance, Co. v. Ch Lighting Technology Co., Ltd., Counsel Stack Legal Research, https://law.counselstack.com/opinion/jiaxing-super-lighting-electric-appliance-co-v-ch-lighting-technology-cafc-2025.