Link to Seasonal Specialties, LLC v. Holiday Designs, LLC, No. 1:23-cv-14008 (N.D. Ill. Dec. 22, 2025) (Kness, J.). Seasonal Specialties, LLC v. Holiday Designs, LLC, No. 1:23-cv-14008 (N.D. Ill. Dec. 22, 2025) (Kness, J.).
Judge Kness ruled on claim construction in a patent dispute over pre-lit Christmas tree lighting making clear the Court’s preference for plain and ordinary meaning where the intrinsic record resolved the parties’ disagreements without requiring any constructions. Applying Phillips and O2 Micro, the Court held no further construction was necessary for six disputed terms across two patents, including “an illumination element,” “a first switching circuit … a second switching circuit,” and “special lighting effect.” The court also rejected an indefiniteness challenge to “blinking” and “twinkling,” finding the Nautilus standard satisfied because a person of ordinary skill, informed by the claims and specification, would understand the scope with reasonable certainty. Of particular note, the Court held as follows:
- Illumination Element – The Court concluded that the claim language itself—particularly the use of “said illumination element” in functional limitations—already required at least one element capable of performing all recited functions, rendering a reworded construction unnecessary.
- First and Second Switching Circuits – The separation of first and second switching circuits coupled with their distinct roles as described in the claims and specification, made clear that two distinct circuits are required, even if implemented on the same board or package. And because the claims already delineate the transition from an initial steady-on state to “special lighting effects,” any further paraphrasing risked confusing rather than clarifying the jury.
The Court cited Vivid Techs. to avoid “an obligatory exercise in redundancy” and declined to add narrowing language absent lexicography or clear disavowal (Thorner). The Court also treated “blinking” and “twinkling” as examples of lighting sequences described in the specification, rejecting a § 112(b) indefiniteness argument for lack of “objective boundaries” where the intrinsic record adequately cabins meaning under Nautilus.