Federal Circuit Appeal Noticed After Dismissal of Huzhou Xinju's Declaratory Judgment Suit Against Semisilicon Over TV Backlight Strips.

The complaint

Huzhou Xinju Electronic Commerce Co., Ltd. v. Semisilicon Technology Corp., No. 5:26-cv-08217 (N.D. Cal.), is a 17-page complaint filed August 6, 2026, ECF No. 1, with a jury demand. Huzhou Xinju is a Chinese company, and the complaint alleges, on information and belief, that Semisilicon is a Taiwanese corporation based in New Taipei City. The complaint alleges that in 2026 Semisilicon filed an Amazon patent complaint on the '546 patent against Huzhou Xinju's listing for its Ailofy TV LED backlight strips, and that Amazon removed the listing without first giving Huzhou Xinju the seller-side notice that Amazon's APEX procedure describes.

Count I seeks a declaratory judgment that the strips do not infringe claims 4-6, and Count II seeks a declaratory judgment that claims 4-6 are invalid. Count III alleges tortious interference, and Count IV alleges unfair competition under California Business and Professions Code § 17200. The prayer asks for an injunction barring Semisilicon from asserting the patent against the product through Amazon or similar platform mechanisms, an order requiring it to withdraw its Amazon complaint, damages, restitution, attorneys' fees under 35 U.S.C. § 285, and costs.

The patent

U.S. Patent 8,884,546, titled Driving Apparatus for Light-Emitting Diode Curtain Lamp, issued November 11, 2014, from Application No. 13/232,932, filed September 14, 2011. The complaint says the patent has eight claims, that the Board found claims 1-3 and 8 unpatentable in IPR2024-00156, and that claim 4, the only challenged independent claim the Board did not find unpatentable, and its dependents 5 and 6 remain.

Claim 4, as quoted in the complaint, covers a driving apparatus for an LED curtain lamp, used with an AC power source and at least one LED light string, with a master control unit that has a power negative terminal pin and a signal output pin and connects to the AC power source, and at least one slave control unit that has a signal input pin, a signal output pin, a power positive terminal pin, and a power negative terminal pin, connects to the master control unit and the light string, and drives the light string under the master control unit's control. The master's signal output pin connects to the slave's signal input pin, and the master's power negative terminal pin connects to the slave's power positive terminal pin. Huzhou Xinju argues that its product is a TV backlight, not a curtain lamp, and that Semisilicon's reading of pin conflicts with positions Semisilicon took in the IPR.

The rulings

On August 26, 2026, the court denied Huzhou Xinju's motion for a temporary restraining order, which sought to require Semisilicon to withdraw its Amazon complaint. The order found that Huzhou Xinju had not made the required showing on the four injunction factors and noted that Semisilicon's pending motion to dismiss or transfer raised serious issues of personal jurisdiction and the first-to-file rule. It also noted that Semisilicon had sued Huzhou Xinju in the Eastern District of Texas six days before this case was filed, over the same patent and products.

On October 23, 2026, the court granted Semisilicon's motion to dismiss without leave to amend. It held that using Amazon's patent enforcement process against a listing offered nationwide did not show that Semisilicon purposefully directed activities at California; that 28 U.S.C. § 1391(c)(3) governs venue, not personal jurisdiction; and that Rule 4(k)(2) does not apply because Semisilicon is subject to general jurisdiction in Virginia. It also held that the first-to-file rule required dismissal because Semisilicon filed first in Texas, on July 31, 2026, with identical parties and issues, and that the anticipatory suit exception did not apply because Huzhou Xinju's notice letter only said it intended to file by July 20, 2026, and it did not. The dismissal is without prejudice, and the order says Huzhou Xinju may present its claims in Semisilicon Technology Corp. v. Huzhou Xinju Electronic Commerce Co., No. 4:26-cv-00979 (E.D. Tex.). Judgment entered the same day.

The appeal

A notice of appeal to the Federal Circuit was filed on November 4, 2026, ECF No. 36. In the Texas case, a motion to dismiss was filed on November 10, 2026, ECF No. 11. Watch for the Federal Circuit briefing schedule and for a ruling on the Texas motion.