Fluxwerx Illumination v. OKT Lighting USA - Complaint

Case 4:19-cv-01113 Document 1 Filed on 03/26/19 in TXSD Page 1 of 14
IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION
Fluxwerx Illumination, Inc., §

§
Plaintiff, §
Civil Action No. ____________
§
v. §
JURY TRIAL DEMANDED
§
OKT Lighting USA, LLC, and Shenzhen §
OKT Lighting Co., Ltd., §
§
Defendants. §
PLAINTIFF’S ORIGINAL COMPLAINT
Plaintiff Fluxwerx Illumination, Inc. (“Fluxwerx”) hereby asserts the following claim for
patent infringement against Defendants OKT Lighting USA, LLC (“OKT USA”) and Shenzhen
OKT Lighting Co., Ltd. (“OKT China”) (unless otherwise indicated, “Defendants”), and states as
follows:
NATURE OF ACTION
1. This is an action for patent infringement based upon Defendants’ infringing
Fluxwerx’s intellectual property, including Fluxwerx’s patented LED luminaire design protected
by U.S. Design Patent No. D747,539 (the “’539 Patent”).
2. Defendants manufacture, sell, and import knock-off LED lighting fixtures to
customers, distributors, and resellers in place of the patented products designed, manufactured,
sold by Fluxwerx.
3. As a result of Defendants’ unlawful infringement, Defendants have been
wrongfully enriched, and Fluxwerx has been injured through loss of sales and good will, and seeks
injunctive and monetary remedies under the federal patent statute, 35 U.S.C. §§ 284, 285, and 289.
THE PARTIES
4. Plaintiff incorporates the preceding paragraphs herein by reference.
5. Fluxwerx is a Canadian corporation, having its principal place of business at 9255
-194th Street, Surrey, BC, Canada V4N 4G1.
6. Fluxwerx is a business unit of Canadian corporation Lumenpulse Group, Inc.,
headquartered at 1220 Marie-Victorin Blvd., Longueuil, Quebec, Canada J4G 2H9. Lumenpulse
Group, Inc. also has a Sales & Technology Center in Boston, Massachusetts.
7. Defendant OKT USA is registered in the State of Texas as a limited liability
company. OKT USA resides in this District, having a principal place of business at 3707 Meadow
Spring Dr., Sugar Land, Texas 77479. According to Texas State records, (a) OKT China is a
Managing Member of OKT USA and owns 51% of OKT USA; (b) Mr. Yilong Zhang is a
Managing Member of OKT USA and owns 49% of OKT USA, providing the same address as
OKT China; and (c) Mr. Yilong Zhang is a Registered Agent of OKT USA, providing the same
address as OKT USA. Defendant OKT USA can be served via an officer, managing agent or
general agent, including, but not limited to, by serving Mr. Yilong Zhang as Registered Agent for
OKT USA.
8. Defendant OKT China is a Chinese corporation with its principal place of business
at 2076 Jincheng Rd. Shajing, Bao'an, SZ 518104, CN. On information and belief, Mr. Allan
Zhang is the President and/or CEO of OKT China. According to OKT China’s website quoting
Mr. Zhang, “Currently, almost all OKT products are exported to North America, with the majority
destined for the US. ‘When we first started, Europe and Asia were our main markets. But after
seeing that just a few Chinese LED manufacturers had entered the North American market, we
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made the decision in 2010 to shift our direction, dedicating our resources to serving this market
alone,’ says Zhang.” (https://www.oktlighting.com/products-about-okt.html).
9. On information and belief, Defendant OKT USA is a subsidiary and agent for OKT
China, and sells, imports, resells, distributes, and warehouses products for OKT China at the
direction of OKT China.
10. Defendant OKT China can be served via an officer, managing agent or general
agent, including, but not limited to, by serving OKT USA, its majority owned subsidiary and for
which OKT China is a Managing Member, or on Yilong Zhang as Registered Agent of OKT USA.
11. OKT China announced that it will attend the 2019 LightFair International Trade
Show and Conference (“LightFair 2019”), an industry trade show occurring at Philadelphia’s
Pennsylvania Convention Center between May 19-23, 2019, in booth 1049.
12. On information and belief, OKT China has promoted its intention to present
products including the product accused in this action at the LightFair 2019, which infringes
Fluxwerx’s intellectual property rights under the ‘539 Patent.
JURISDICTION AND VENUE
14. This is an action for patent infringement brought under the patent laws of the United
States, 35 U.S.C. § 1, et seq. This Court has original subject matter jurisdiction over the claims in
this action pursuant to 28 U.S.C. § 1331 (federal question), 28 U.S.C. § 1332(a)(2) (international
diversity), and 28 U.S.C. § 1338(a) (patents).
15. Venue is proper in this judicial district pursuant to 28 U.S.C. §§ 1391, 1400
because OKT USA is registered in the State of Texas as a limited liability company listing its
principal place of business in this District.
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16. Venue is proper in this judicial district pursuant to 28 U.S.C. §§ 1391, 1400
because Defendant OKT China through its majority owned subsidiary OKT USA may be found
in this District. Further, Defendant OKT China is a foreign corporation and thus may be sued in
any judicial district.
17. Defendants can be found in the judicial district, or otherwise established contacts
with this judicial district sufficient enough to make the exercise of personal jurisdiction proper.
18. Further, the Court has personal jurisdiction over OKT China because OKT China’s
infringing products are offered for sale across the United States, including in the State of Texas.
For example, the accused OKT China device was sold to and installed at St. Mark’s Catholic
School in Plano, TX.
19. On information and belief, OKT China manufactured, sold, and imported its
products to the following parties in Texas:
a. Pollyanna Group located at 2402 Indigo Lane, Arlington, TX 76015;
b. Galaxy LED located at 5718 Fondren Rd., Houston, TX 77036; and
c. MJK Lighting, Inc. located at 3026 Mockingbird Lane, Suite 136, Dallas, TX 75205
and/or 5307 E. Mockingbird Lane, Dallas, TX 75206.
20. On information and belief, OKT China has manufactured, sold, shipped, and
imported its products to over half the United States, including Florida, Louisiana, Illinois,
Massachusetts, California, New York, Texas, Minnesota, Arkansas, New Jersey, Connecticut,
Colorado, Michigan, Wisconsin, North Carolina, Oregon, Georgia, Ohio, Maryland, Indiana,
Iowa, Delaware, Virginia, Nevada, New Hampshire, Tennessee, South Carolina, New Mexico,
Pennsylvania, Washington, Missouri, and Utah. On information, and belief, these shipments
include the accused product.
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21. Further, Defendant OKT China offers its infringing products for sale in
Pennsylvania at LightFair 2019.
BACKGROUND FACTS
23. Fluxwerx is in the business of designing, manufacturing, and selling high quality
LED lighting fixtures in the United States and throughout the world. Fluxwerx is established at
the forefront of LED lighting technology, with a distinctive product offering and breakthrough
proprietary anidolic optics technology that offers substantial energy savings, lighting quality, and
remarkable lifetime.
24. Fluxwerx is the owner of U.S. Patent No. D747,539 (the “’539 Patent”) entitled
“Luminaire,” which issued by the United States Patent and Trademark Office on January 12, 2016.
A copy of the ’539 Patent is attached as Exhibit A.
25. The ’539 Patent is valid, enforceable, and was duly issued in full compliance with
Title 35 of the United States Code.
26. The ’539 Patent claims the ornamental design, as shown below:
5
’539 Patent, FIG. 1.
27. Fluxwerx manufactures and sells lighting products with the design of the ’539
Patent under its “VIEW” brand (“BEAM” endcap) in several sizes, finishes, and energy/lighting
configurations.
28. In contravention to 35 U.S.C. § 271 and § 289, Defendants infringed the ’539 Patent
by making, using, selling, and/or offering to sell, or causing others to make, use, sell, and/or offer
to sell LED lighting fixtures, including but not limited to the Vertical LED Linear Pendant (Model
Nos. LV4-DM-XXU, LV4-DM-XXE, the “Accused Products”), which embody the design claimed
in the ’539 Patent. Photographs of the Accused Products are attached hereto as Exhibit B, and
reproduced below for convenience.
6
Exhibit B at 2 (LV4-DM-XXE); see also Shenzhen OKT Lighting Co. Ltd., 50W 4 feet Vertical
LED Linear Pendant Fixture (Diffuser) Product Information, available at
https://www.oktlighting.com/vertical-led-linear-pendant-fixture.html (last visited Mar. 26, 2019).
7
Exhibit B at 8 (LV4-DM-XXU); see also Shenzhen OKT Lighting Co. Ltd., 50W 4 feet
Suspended Linear LED Lighting (Lens Cover), available at https://www.oktlighting.com/50w-4-
feet-suspended-linear-led-lighting.html (last visited Mar. 26, 2019).
8
29. The overall appearance of Defendants’ Accused Products is substantially the same
as the design in the ’539 Patent, and/or at least a colorable imitation thereof.
30. By way of example, both designs comprise an industrial design, including an I-
beam styled frame, and a joiner.
Fluxwerx’s Design Defendants’ Design
’539 Patent, FIG.1. Exhibit B at 2 (LV4-DM-XXE).
31. The Accused Products also contain unprotected elements of Fluxwerx’s design,
such the placement of the screws for mounting on a ceiling.
32. The ordinary observer, seeing the Accused Products, would be deceived into
believing that it is the same as Fluxwerx’s patented design.
33. Defendant OKT China announced that it will attend LightFair 2019, an industry
trade show occurring at Philadelphia’s Pennsylvania Convention Center from May 19-23, 2019.
Defendant OKT China will display its Accused Products for sale within the United States at
LightFair 2019. Exhibit C at 1 (reproduced below) (highlighting the Accused Products).
9
34. By selecting the “LED Pendant Lights” from Defendant OKT China’s website,
users are direct to two versions of Defendants’ Accused Products.
10
Shenzhen OKT Lighting Co. Ltd., LED Linear Pendant Lighting Fixtures available at
https://www.oktlighting.com/products-pendant-linear-light.html (last visited March 18, 2019).
35. Defendant OKT China’s marketing, advertising and other communications in
preparation for LightFair 2019 comprise an offer for sale within the meaning of the patent statute,
35 U.S.C. § 271(a), and is an infringement of the ‘539 Patent.
CAUSE OF ACTION
COUNT I
(Infringement of U.S. Patent No. D747,539)
37. Defendants have infringed, currently infringe, and will continue to infringe, the
’539 Patent unless enjoined by this Court from making, using, offering for sale, importing and/or
selling Fluxwerx’s patented design within the United States. 35 U.S.C. § 271(a).
11
38. On information and belief, Defendants induced and/or directed its distributors,
resellers and customers, to infringe upon the ’539 patent in violation of 35 U.S.C. § 271(b)-(c).
39. Defendants acts of direct and indirect patent infringement are continuing and
ongoing.
40. On information and belief, Defendants knew of Fluxwerx, Fluxwerx’s patented
product, the ’539 Patent, or were willfully blind to its existence, and Defendants knew or were
willfully blind in consciously ignoring the possibility that its actions would infringe the ’539
Patent.
41. As a direct and proximate result of Defendants’ direct and indirect infringement of
the ’539 Patent, Fluxwerx is suffering damages as well as irreparable injury for which it has no
adequate remedy at law.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff respectfully requests the Court enter judgment against
Defendants:
1. Finding that Defendants infringe U.S. Patent No. D747,539;
2. Pursuant to 35 U.S.C. § 283, grant a preliminary and permanent injunction
enjoining Defendants, their subsidiaries, affiliates, divisions, officers, agents,
servants, employees, directors, partners, representatives, and all parties in active
concert and/or participation with Defendants from directly or indirectly making,
having made, selling, offering for sale, distributing, using, or importing into the
United States products that infringe the ’539 Patent;
3. Issue and Order prohibiting Defendants from:
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a. Making, using, selling, offering for sale, and/or importing the Accused
Products into the United States;
b. From using, selling, offering for sale, or displaying the Accused Products
in the United States, including LightFair 2019;
4. Pursuant to 35 U.S.C. § 284, Defendants account for and pay to Plaintiff all
damages caused by Defendants’ infringement of the ’539 Patent, including lost
profits and interest, but no event less than a reasonable royalty;
5. Pursuant to 35 U.S.C. § 289, awarding to Plaintiff the total extent of Defendants’
total profits derived from sales of the Accused Products;
6. Pursuant to 35 U.S.C. § 285, Plaintiff be awarded costs and attorney’s fees incurred
in connection with this action, upon a judgment declaring this an exceptional case;
and
7. Such other and further relief as the Court deems just and proper.
JURY DEMAND
Plaintiff demands trial by jury pursuant to Fed. R. Civ. P. 38(b).
Respectfully Submitted,
/s/ Bruce Morris

Bruce Morris
Southern District of Texas Bar No. 14198
Texas State Bar No. 14469850
KANE RUSSEL COLEMAN LOGAN PC
5051 Westheimer Road, 10th Floor
Houston, TX 77056
Telephone: (713) 425-7450
Facsimile: (713) 425-7700
bmorris@krcl.com
ATTORNEY-IN-CHARGE
FOR PLAINTIFF
FLUXWERX ILLUMINATION, INC.
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OF COUNSEL:
Howard J. Susser*
Joseph M. Maraia*
Eric G. J. Kaviar*
Anthony E. Faillaci*
BURNS & LEVINSON LLP
125 Summer Street
Boston, MA 02110-1324
Telephone: 617-345-3000
Facsimile: 617-345-3299
hsusser@burnslev.com
jmaraia@burnslev.com
ekaviar@burnslev.com
afaillaci@burnslev.com
* - Pro Hac Vice motions to be filed with the Court.
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Case 4:19-cv-01113 Document 1-1 Filed on 03/26/19 in TXSD Page 1 of 2
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EXHIBIT A
USOOD747539S
(12) United States Design Patent (10) Patent No.: US D747,539 S

Santoro et al. (45) Date of Patent: ... Jan. 12, 2016
(54) LUMINAIRE 3,741,588 A * 6/1973 Dotterweich ............ B6OD 1 06
(71) Applicant: Fluxwerx Illumination Inc., Delta (CA) 280,491.5
(Continued)
(72) Inventors: Scott Santoro, Delta (CA); Timothy
Edward Berman, Langley (CA); Lance OTHER PUBLICATIONS
David Howitt, Vancouver (CA) Frameless pendant luminaire rectangular, image post date 2004, site
(73) Assignee: Fluxwerx Illumination Inc., Delta (CA) visited Dec. 16, 2014, (online), <http://www.architonic.com/pmsht
(**) Term: 14 Years frameless-luminaire-family-spectra 1/1010195>.*
(21) Appl. No. 29/520,325 (Continued)
(22) Filed: Mar 13, 2015 Primary Examiner — Kevin Rudzinski
Related U.S. Application Data Assistant Examiner — Sean D Lough
74). Att
(62) Division of application No. 29/443,179, filed on Jan. Mr. try Agent
gent, or Firm
Firm - Oyen W G
W1ggS Oreen &
14, 2013, now Pat. No. Des. 737,500.
(51) LOC (10) Cl. ................................................ 26-99 (57) CLAM
(52) U.S. Cl. The ornamental design for a luminaire, as shown and
USPC ......................................................... D26/120 described.
(58) Field of Classification Search DESCRIPTION
USPC ............ D26/9, 10, 12, 13, 15, 16, 24, 51, 61,
D26/72, 76, 80, 81, 85, 86, 88,90, 113, 118, FIG. 1 is a perspective view of a first embodiment of a lumi
D26/119, 120, 122, 128, 129, 138, 143, 144, naire, showing our new design;
D26/5, 6, 11, 79, 114, 116, 131, 137, 121, FIG. 2 is a front view thereof; the rear view being identical
D26/127, 135, 180, 28, 29, 97, 126, 64, 65, thereto;
D26/124, 125, 132, 84, 87, 69, 62, 1, 2, 134, FIG. 3 is a top view thereof;
D26/89, 145, 142, 74, 63: D13/180, 179, FIG. 4 is a bottom view thereof;
D13/133, 113; D10/18, 21, 24, 25, 27, 28, FIG. 5 is a left side view thereof
D10/46, 93, 104.1, 113, 114, 116.1, 118: FIG. 6 is a right side view thereof;
D17/99 FIG. 7 is a perspective view of a second embodiment of a
CPC ............. B60Q 1/04; B60Q 1/26: F21S 8/026; luminaire, showing our new design;
F21S 8/04: F21S 8/035; F21V 29/004: F21V FIG. 8 is a front view thereof; the rear view being identical
21/02; F21V 21/04: F21V 29/2212: F21V thereto;
37/002; F21V 7/00; F21V 29/83; F21V 7/22; FIG.9 is a top view thereof;
F21Y 2101/02; F21Y 2103/00; F21L 19/00; FIG. 10 is a bottom view thereof;
F23D 1 1/443; A61L 9/037; H01R 33/0836; FIG. 11 is a left side view thereof, and,
H01R 2103/00; H01R 24/68: G02B 6/4298 FIG. 12 is a right side view thereof.
See application file for complete search history. The luminaire is shown with symbolic break lines along its
width. The appearance of any portion of the article between
(56) References Cited the break lines forms no part of the claimed design.
U.S. PATENT DOCUMENTS The broken lines present in FIGS. 4 and 10 illustrate portions
of the luminaire that form no part of the claimed design.
3,664.254. A * 5, 1972 Henson ................... F24F 13 OO
165,53 1 Claim, 4 Drawing Sheets
US D747,539 S
Page 2
(56) References Cited 8,038,315 B1 * 10/2011 Santoro ................... F21S 8,061

362,217.05
U.S. PATENT DOCUMENTS D650.509 S * 12/2011 Wegger .......................... D26/90
D653.375 S * 1/2012 Chung ........................... D26/75
3,800,660 A * 4, 1974 Gladwin ................... B23C 1.16 RES s : 33: NE . . . . . . . . . . . . . . . . . . . . . . . . . . R22
409/121 ll.9 . . . . . . . . . . . . . . . . . . . . . . . . . . .
3,807,105. A * 4, 1974 Rudkin, Jr. .......... E04B 1,34853
52/79.7
E. s : 38: S.ll.9 . . . . . . . . . . . . . . . . . . . . . . . . . . . P.S.
3,995,904 A * 12, 1976 Matthews ................. B66C 1.64
294f104
RS:S : 385 Siki
UWalk .
R".
4,045,665 A * 8/1977 Williams ................ F21S362,223
8,035 E. s : g: E" OO ...
BS's
D251.806 S * 5/1979 Brady .......................... D25,119 D677,422 S * 3/2013 Lin .............................. D26/120
D302,049 S * 7/1989 Gecchelin ... D26,122 R22 S 32 Reddy - D26/128
D304,173 S * 10/1989 Frassati. D13,155 D679,860 S 4/2013 Maxik. ... D26/141
D321,063 S * 10, 1991 Neece .......................... D26,139 D680,679 S 4/2013 Kim ... ... D26,118
5,207,504 A * 5/1993 Swift ........................ F21S 8/04 D681,265 S * 4/2013 Kim ... ... D26/141
362,147 D685,130 S * 6/2013 Kim ...... ... D26/141
D373,432 S * 9/1996 Wu ................................ D26/28 D695,951 S * 12/2013 Miyatake . ... D26/120
D374,295 S * 10/1996 Farchione D12/114 D700,736 S * 3/2014 Schuyler . ... D26,113
D418.936 S * 1/2000 Dunning . ... D26/3 D702,875 S * 4/2014 Klus ........ ... D25,122
D539,945 S * 4/2007 Egawa ........ . . D26/24 D707,880 S * 6/2014 Magnusson. D26,120
D545.483 S * 6/2007 Mayfield, III D26,118 R937 S 8294 Lehman ......................... D26/77
D545,991 S * 7/2007 Mayfield, III ... D26,118 RSS 24 hr. ... D26,113
7,267,459 B2* 9/2007 Matheson ... F21K9/00
362,240
B. s ck 838. yer
IIS ... . . . . . . . . . . . . . . . . . . . . . . . . . . . .
P.I.:
7,314,295 B2 * 1/2008 Legat ...................... F21V362,223
15.O1 R22 s : '3. Nilai
US .....
R; 1
D569,542 S * 5/2008 Toda ............................ D26,122 D724,776 S * 3/2015 Sonneman ..................... D26/85
D580,583 S * 1 1/2008 Pfund ............................ D26/76 D726,361 S * 4/2015 Rischau ... D26, 107
D581,080 S * 1 1/2008 Mier-Langner ... D26,63 D726,362 S * 4/2015 Kim ...... D13,180
D584,848 S * 1/2009 Menke ........ D26/76 D727,551 S * 4/2015 Clark ............................. D26/88
D597.241 S * 7, 2009 Fabbri ... D26,74 D727,554 S * 4/2015 Clark ............................. D26/90
D599.945 S * 9, 2009 Pfund . D26/76 D728,153 S * 4/2015 Blessitt D26,118
D602,626 S * 10, 2009 Santoro D26/76 D731,700 S * 6/2015 Santoro ........................ D26,118
D608,929 S * 1/2010 Castelli D26/76 D732,225 S * 6/2015 Grandsart ...................... D26/75
D608,933 S * 1/2010 Castelli D26/76 R3222 S 929. Fartman D26,76
D612,958 S * 3/2010 Uemoto ........................... D26/1 R733. S 29 Pingan ......................... D26/76
D614,792 S * 4/2010 Fabbri ..................... D26/120 R73.5 S 29 Slus. ... D26, 138
D618,845 S * 6/2010 D26,113 D737,500 S 8/2015 Santoro ........................ D26/120
D620, 189 S * 7/2010 D26,119 OTHER PUBLICATIONS
D621,542 S * 8/2010 D26, 138
D621,989 S * 8/2010 D26/76 Ecoxotic Panorama Pro LED Light Strip, image post date Oct. 20.
D623, 149 S * 9/2010 D13,180 2012, site visited Sep. 25, 2014 (online), <http://www.
D626,268 S * 10/2010 Santoro ... D26/76 drsfostersmith.com/product/prod display.cfm?pcatid=24727.>.*
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D629,554 S * 12/2010 Gielen ........................... D26/76 2012121802 1303/http://store.luminaire.com/prado-mirror>.*
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D645,193 S * 9/2011 Chung ........................... D26/75 metal-level-red-level-port?ref-market.*
D646,003 S * 9/2011 Wang ............................. D26/24
D647,246 S * 10/2011 Chadwick .................... D26, 138 * cited by examiner
U.S. Patent Jan. 12, 2016 Sheet 1 of 4 US D747,539 S

G. 3
G. S. G. S
G. 7
G. 9
G. 8
G. O.
G. G. 2
EXHIBIT B
Welcome to Shenzhen OKT Lighting Co.,Ltd,.  Login English
Home Product Cut sheet Project News Company Contact OKT 
Home > Product > New product > 50W 4 feet Vertical LED Linear Pendant Fixture (Diffuser)
50W 4 feet Vertical LED Linear Pendant Fixture

(Diffuser)
Model No LV4-DM-XXE
Features ETL, DLC, CE

100-277V or 200-240V AC Input Voltage options
Direct and indirect light with 3-sideds emitted
Seamless Continuous Runs
Emergency Function Options
Inquire Online
Downloads Product Information EU Version
Data Sheet Description

LV4-DM-XXX OKT 4FT Vertical LED linear pendant light fixtures integrated with high transmittance PMMA light guide
plates. Transparent, vertical optics designed specifically for LED sources are integrated with minimalist
design and architectural materials to create a broad range of solutions. No direct or indirect view of the light
LM79 Report source with transparent optics when on. It is distributed at a rate of 3:3:4 in horizontal and down directions,
LV4-DM-XXX precisely controlled optimal distributions for low glare and wide beam angle. Seamless continuous runs
speed installation and reduce the labor cost.
IES Files
Performance Summary
LV4-DM-XXX
Model Number LV4-DM-XXE
Installation Instruction Size 4FT

LV4-DM-XXX
Input Wattage 50 Watts
Input Voltage 100-277V AC

Data Sheet
LV4E-DM-XXX Delivered Lumen 5500lm
Efficacy 110 lm/w

Installation Instruction
LV4E-DM-XXX Dimming Type 0-10V Dimming
Light Distribution 3 Side at rate of 3:3:4
Mounting Suspended with canopy

RELATED PRODUCTS
Color Rendering Index Ra>80
Power Factor PF > 0.9
Lifespan 50,000 Hours
Warranty 5 Years
ETL 5001795
DLC YES
2x4 Indirect LED Troffer Light

Damp Rated YES
Features
Contact 
 sales@okt-led.com
 +86-755-61157553 
Indirect LED Troffer Light 2x2


US Patent 2FT T-Grid LED Linear

Light

Light
Contact 
 +86-755-61157553
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Contact 
 +86-755-61157553
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
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Contact 
 +86-755-61157553
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Contact 
 +86-755-61157553
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Contact 
Need more ? Please fill out the following form, we OKT sales representative will contact you within
12 hours. Thank you!
 +86-755-61157553 

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Feedback Home Product Cut sheet Project News Company Contact OKT 
Jean Scantland
Looking to buy 60 units of the LV4-DM-120v-4000k need price and lead time + ies files for lighting
calculation also we must do two conference romm with 8 feet fixtures as shown on the picture We are
already customer with OTK Lighting Can you alos send me password to the web site to get the
specification sheet and technical drawing. Thanks for a quick reply Best regards Jean
2018-01-26 03:05:41
Tim Gravert
Neat fixture concept. Please send me more information. Tim
2017-11-14 08:14:28
Product Message
* Name Name
* E-mail E-mail
* Content Content
* Captcha Captcha
Leave a Message
ABOUT US PRODUCTS QUICK LINKS LEAVE A MESSAGE

> New product > Home * Name
> T-grid led > Cut sheet
> Project * E-mail

> Led panel light
HK Headquarters: OKT
> News * Content
> Led emergency backup
Lighting Int'l Group Limited > Company
Shenzhen Factory: Shenzhen OKT > Led troffers * Captcha
> Contact OKT
Lighting Co., Ltd > Led linear fixture
Send Inquiry Now
Add.:No.2076 Jincheng Rd, Shajing, > J-box downlight
Bao'an, SZ 518104, CN  Sitemap
> Commercial led downlight
Copyright © 2018 Shenzhen OKT Lighting Co.,Ltd. | All Rights Reserved
Contact 
 +86-755-61157553



Welcome to Shenzhen OKT Lighting Co.,Ltd,.  Login English
Home > Product > New product > 50W 4 feet Suspended Linear LED Lighting ( Lens Cover)
50W 4 feet Suspended Linear LED Lighting ( Lens

Cover)
Model No LV4-DM-XXU, LV4E-NM-XXU
Features Low Glare Lens Cover UGR<5

Direct And Indirect Light
Seamless Continuous Runs
Emergency Function Options
Inquire Online
Downloads Product Information EU Version
Data Sheet Description

LV4-DM-XXU OKT vertical suspended linear led lighting fixtures with lens integrated with high transmittance PMMA light
guide plates. Transparent, vertical optics designed specifically for LED sources are integrated with
minimalist design and architectural materials to create abroad range of solutions. Modular Optics Available
Installation Instruction with field interchangeable optics in 15° Spot, 30° Narrow Flood, or 40° Flood distributions. Advanced design
LV4-DM-XXU provides efficient functional downlighting and ambient horizontal lighting a rate of 3:3:4 with seamless
continuous runs. It is suitable for commercial and architectural lighting application.
Data Sheet
Performance Summary
LV4E-NM-XXU
Model Number LV4-DM-XXU
IES Files Size 4FT

LV4E-NM-XXU
Input Wattage 50 Watts
Input Voltage 100-277V AC

Installation Instructoon
LV4E-NM-XXU Delivered Lumen 5500lm
Efficacy 110 lm/w
Dimming Type 0-10V Dimming

RELATED PRODUCTS
Beam Angle 15°/ 30° /40°
Color Rendering Index Ra>80
Power Factor PF > 0.9
Lifespan 50,000 Hours
Warranty 5 Years
ETL 5001795
2x4 Indirect LED Troffer Light
Damp Rated YES
Contact 
Indirect LED Troffer Light 2x2
 +86-755-61157553 


Features

Light

Light
Contact 
 +86-755-61157553 


Contact 
 +86-755-61157553 


Contact 
 +86-755-61157553 


Contact 
 +86-755-61157553 


Contact 
Need more ? Please fill out the following form, we OKT sales representative will contact you within 12
hours. Thank you!  +86-755-61157553 


Home Product
Product Message
Cut sheet Project News Company Contact OKT 
* Name Name
* E-mail E-mail
* Content Content
* Captcha Captcha
Leave a Message
ABOUT US PRODUCTS QUICK LINKS LEAVE A MESSAGE

> New product > Home * Name
> T-grid led > Cut sheet
* E-mail
> Led panel light > Project
HK Headquarters: OKT
> News * Content
> Led emergency backup
Lighting Int'l Group Limited
> Company
Shenzhen Factory: Shenzhen OKT > Led troffers * Captcha
> Contact OKT
Lighting Co., Ltd > Led linear fixture
Send Inquiry Now
Add.:No.2076 Jincheng Rd, Shajing,
> J-box downlight
Bao'an, SZ 518104, CN  Sitemap
> Commercial led downlight
Copyright © 2018 Shenzhen OKT Lighting Co.,Ltd. | All Rights Reserved
Contact 
 +86-755-61157553 


EXHIBIT C
3/8/2019 SHENZHEN OKT
Case 4:19-cv-01113 Document 1-4LIGHTING
FiledCO.,
onLTD. | LIGHTFAIR
03/26/19 in International
TXSD Page 2 of 4
Pennsylvania Convention Center Philadelphia, PA USA Pre-Conference May 19-20, 2019
Trade Show & Conference May 21-23, 2019
Learn
←EXHIBITOR LIST Explore Attend Exhibit Events Press Log In Registration
SHENZHEN OKT LIGHTING CO., LTD.

BOOTH 1049
Since 2008, we've been No. 2076

Jincheng
dedicated to design and
Rd.
manufacture the most
Shajing
innovative and easy-to-use Town
commercial led lighting Bao'an
fixtures. Its main products District
include led linear light, led Shenzhen,
pendant lights, led panel Guangdong,
518104
light, led flat panel light, led
China
tro er, led downlights and P: - ++86-
emergency led driver, all of 755-6115
which have achieved 7553
certifications such as UL, ETL, F: - ++86
755 6115
Energy Star, DLC, TITLE 24,
7550
TUV, CSA, SASO and FCC.
Product Showcase Sign up for updates →
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FiledCO.,
onLTD. | LIGHTFAIR
TXSD Page 3 of 4
OKT Suspended Up and Down LED OKT 50W 4 feet Vertical LED Linear OKT U
Linear Panel Pendant Fixture
Product Categories
Recessed Downlights… Suspended Indirect a… Tro ers, Commercial …

O ice Lighting Retrofit, Retrofit Kits
Contacts
Allan Zhang Cher Lew

sales@okt-led.com cher@okt-led.com
72 Days Until LFI 2019 REGISTRATION
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Fluxwerx Illumination v. OKT Lighting USA - Complaint

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Fluxwerx Illumination v. OKT Lighting USA - Complaint

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Case 4:19-cv-01113 Document 1 Filed on 03/26/19 in TXSD Page 1 of 14

IN THE UNITED STATES DISTRICT COURT

Fluxwerx Illumination, Inc., §

PLAINTIFF’S ORIGINAL COMPLAINT

1. This is an action for patent infringement based upon Defendants’ infringing

by U.S. Design Patent No. D747,539 (the “’539 Patent”).

2. Defendants manufacture, sell, and import knock-off LED lighting fixtures to

3. As a result of Defendants’ unlawful infringement, Defendants have been

4. Plaintiff incorporates the preceding paragraphs herein by reference.

5. Fluxwerx is a Canadian corporation, having its principal place of business at 9255

-194th Street, Surrey, BC, Canada V4N 4G1.

6. Fluxwerx is a business unit of Canadian corporation Lumenpulse Group, Inc.,

7. Defendant OKT USA is registered in the State of Texas as a limited liability

alone,’ says Zhang.” (https://www.oktlighting.com/products-about-okt.html).

direction of OKT China.

Pennsylvania Convention Center between May 19-23, 2019, in booth 1049.

Fluxwerx’s intellectual property rights under the ‘539 Patent.

JURISDICTION AND VENUE

13. Plaintiff incorporates the preceding paragraphs herein by reference.

diversity), and 28 U.S.C. § 1338(a) (patents).

principal place of business in this District.

any judicial district.

School in Plano, TX.

products to the following parties in Texas:

a. Pollyanna Group located at 2402 Indigo Lane, Arlington, TX 76015;

b. Galaxy LED located at 5718 Fondren Rd., Houston, TX 77036; and

and/or 5307 E. Mockingbird Lane, Dallas, TX 75206.

include the accused product.

Pennsylvania at LightFair 2019.

22. Plaintiff incorporates the preceding paragraphs herein by reference.

A copy of the ’539 Patent is attached as Exhibit A.

Title 35 of the United States Code.

’539 Patent, FIG. 1.

reproduced below for convenience.

30. By way of example, both designs comprise an industrial design, including an I-

beam styled frame, and a joiner.

Fluxwerx’s Design Defendants’ Design

’539 Patent, FIG.1. Exhibit B at 2 (LV4-DM-XXE).

such the placement of the screws for mounting on a ceiling.

believing that it is the same as Fluxwerx’s patented design.

LightFair 2019. Exhibit C at 1 (reproduced below) (highlighting the Accused Products).

users are direct to two versions of Defendants’ Accused Products.

https://www.oktlighting.com/products-pendant-linear-light.html (last visited March 18, 2019).

35. Defendant OKT China’s marketing, advertising and other communications in

35 U.S.C. § 271(a), and is an infringement of the ‘539 Patent.

36. Plaintiff incorporates the preceding paragraphs herein by reference.

40. On information and belief, Defendants knew of Fluxwerx, Fluxwerx’s patented

adequate remedy at law.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests the Court enter judgment against

1. Finding that Defendants infringe U.S. Patent No. D747,539;

2. Pursuant to 35 U.S.C. § 283, grant a preliminary and permanent injunction

enjoining Defendants, their subsidiaries, affiliates, divisions, officers, agents,

servants, employees, directors, partners, representatives, and all parties in active

concert and/or participation with Defendants from directly or indirectly making,

United States products that infringe the ’539 Patent;

3. Issue and Order prohibiting Defendants from:

Products into the United States;

in the United States, including LightFair 2019;

damages caused by Defendants’ infringement of the ’539 Patent, including lost

profits and interest, but no event less than a reasonable royalty;

5. Pursuant to 35 U.S.C. § 289, awarding to Plaintiff the total extent of Defendants’

total profits derived from sales of the Accused Products;

Plaintiff demands trial by jury pursuant to Fed. R. Civ. P. 38(b).