DCT
2:25-cv-01036
Voltstar Tech Inc v. GC Technology LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Voltstar Technologies, Inc. (Illinois)
- Defendant: GC Technology, LLC dba Phonesuit (Nevada)
- Plaintiff’s Counsel: Sriplaw, PLLC.
- Case Identification: 2:25-cv-01036, C.D. Cal., 02/06/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Central District of California because Defendant has committed acts of infringement and maintains a regular and established place of business in the district.
- Core Dispute: Plaintiff alleges that Defendant’s Novo 35 USB Wall Charger infringes a reissue patent related to the compact physical dimensions of electrical charger plugs.
- Technical Context: The technology concerns the design of small-form-factor AC-to-DC power adapters, commonly used for charging mobile electronic devices, where the physical size is minimized to avoid blocking adjacent wall outlets.
- Key Procedural History: The asserted patent, RE48,794 E, is a reissue of U.S. Patent No. 9,024,581. The complaint notes that during reissue, Claim 1 was amended to add a specific width limitation ("a width of the housing outer profile being less than 1.75 inches") and to narrow a length limitation from "equal to or less than 2.0 inches" to "less than 2.0 inches." This change from the original patent, which issued in 2015, to the reissued patent, which issued in 2021, may give rise to questions regarding the doctrine of intervening rights.
Case Timeline
| Date | Event |
|---|---|
| 2008-05-21 | Priority Date for U.S. Patent No. 9,024,581 |
| 2009-11-26 | Application for '581 Patent first published |
| 2015-05-05 | U.S. Patent No. 9,024,581 issued |
| 2018-12-04 | Reissue Application for RE48,794 E filed |
| 2021-10-26 | Reissue U.S. Patent No. RE48,794 E issued |
| 2025-02-06 | Complaint filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Reissue Patent No. RE48,794 E - Charger Plug With Improved Package
- Issued: October 26, 2021
The Invention Explained
- Problem Addressed: The patent describes issues with prior art electrical charger plugs, noting that their physical bulk often interferes with the use of adjacent electrical outlets. (’794 Patent, col. 1:42-48). Furthermore, conventional manufacturing methods like insert molding and hand soldering were described as costly, time-consuming, and space-inefficient, leading to larger product dimensions. (’794 Patent, col. 2:1-41).
- The Patented Solution: The invention is a charger plug with a housing specifically sized to be compact. It claims a housing with a longitudinal length less than 2.0 inches and a width less than 1.75 inches, configured so its "outer profile" does not interfere with an adjacent receptacle. (’794 Patent, col. 13:51-14:56). The design aims to achieve this compact form factor through an assembly method that avoids insert-molded blades and uses wire-form spring contacts to connect the blades to the internal printed circuit board (PCB), reducing internal space requirements. (’794 Patent, col. 4:49-65; Fig. 2B).
- Technical Importance: The patent asserts that this design provides a less expensive and more reliable manufacturing process while creating a smaller, more user-friendly charger that does not obstruct other outlets. (’794 Patent, col. 13:50-61).
Key Claims at a Glance
- The complaint asserts at least Claim 1. (Compl. ¶22).
- Independent Claim 1 requires:
- A charger plug for converting 120V input power to DC output power.
- A housing containing first and second separate blade members with prong portions.
- A DC connector for a power cord.
- The housing having a specific size: (i) a longitudinal length less than 2.0 inches and a width of the housing outer profile being less than 1.75 inches.
- The housing's outer profile having no interference with an adjacent receptacle.
- A configuration allowing for convenient mounting and power cord removal even when space is limited by an obstacle.
- The complaint does not explicitly reserve the right to assert dependent claims but states infringement of "at least one of the claims of the '794 Patent." (Compl. ¶23).
III. The Accused Instrumentality
Product Identification
- The "Novo 35 USB Wall Charger". (Compl. ¶18).
Functionality and Market Context
- The complaint alleges the Novo 35 USB Wall Charger is a plug-in AC-to-DC power adapter for charging electronic devices like mobile phones. (Compl. ¶19). A visual provided in the complaint shows the accused product, a compact white wall charger with foldable prongs and a USB-C port, along with its retail packaging. (Compl. p.5, ¶18).
- The complaint alleges the product's key technical features include its "reduced plug-size" which "does not block or interfere with the use of adjacent outlets." (Compl. ¶20). It is also alleged to have a specific longitudinal length of "approximately 1.333 inches" and a width of "approximately 1.265 inches." (Compl. ¶24).
IV. Analysis of Infringement Allegations
The complaint references an Exhibit 2 claim chart that was not included with the filed document; however, the body of the complaint contains narrative infringement allegations for Claim 1.
RE48,794 E Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A charger plug capable of connecting with a two or three receptacle power source to convert 120V input power received from the power source to DC output power... | The Novo 35 USB Wall Charger connects to an AC power source like a wall outlet to charge a device such as a mobile phone through the use of DC power. | ¶19, ¶20 | col. 13:18-24 |
| first and second separate blade members secured within the housing so as to have prong portions of the blade members positioned in order to extend in a first direction from a front wall of the housing... | The Novo 35 USB Wall Charger is alleged to "employ a reduced plug-size charger plug." A visual shows a charger with two prongs for insertion into a wall outlet. | ¶20, p.5 | col. 13:26-32 |
| i) being sized so that the charger plug housing comprises a longitudinal length extending between the front wall and the rear end and the longitudinal length is less than 2.0 inches, a width of the housing outer profile being less than 1.75 inches, and | The complaint alleges the Novo 35 USB Wall Charger "has a longitudinal length less than 2 inches, approximately 1.333 inches, and a width of less than 1.75 inches, approximately 1.265 inches." | ¶24 | col. 13:51-56 |
| ii) the outer profile having no interference with an adjacent receptacle of the power source located on all sides of the first receptacle when a like charger plug is mounted in all available orientations in any of the other receptacles, | The complaint alleges that upon plugging the Novo 35 USB Wall Charger into a wall outlet, it "does not block or interfere with the use of adjacent outlets." | ¶20 | col. 13:57-64 |
| so that when space is limited by an obstacle adjacent or in front of the power source the charger plug is capable of being conveniently mounted...the power cord plug end may be conveniently received by the DC connector and...removed from the DC connector... | The complaint alleges the charger's size and shape are such that "a power cord for the device to be charged may be easily inserted into and removed from the Novo 35 USB Wall Charger while the charger is plugged into the source of AC power..." | ¶21 | col. 14:1-12 |
- Identified Points of Contention:
- Scope Questions: The complaint's allegation of infringement appears to rely on a straightforward reading of the dimensional limitations. A potential point of contention may arise from the term "outer profile," which is defined in the patent by "a perimeter of the front wall and defined by a plug body extending rearward." (’794 Patent, col. 13:42-45). The parties may dispute how this "profile" is measured and whether it truly has "no interference" with an adjacent outlet under all claimed conditions.
- Technical Questions: The complaint alleges specific dimensions for the accused product. The primary technical question will be whether discovery and expert measurement confirm that the dimensions of the manufactured product fall within the claimed ranges. The use of "approximately" in the complaint (Compl. ¶24) suggests that the precise, measured dimensions will be a key factual issue.
V. Key Claim Terms for Construction
- The Term: "outer profile"
- Context and Importance: This term is central to the non-interference and width limitations of Claim 1. The definition of what constitutes the "outer profile" will determine how the width is measured and how non-interference with adjacent outlets is assessed. Practitioners may focus on this term because its construction could either confirm or undermine the infringement allegations.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the "outer profile" as being defined by a "perimeter of the front wall" and the "plug body extending rearward." (’794 Patent, col. 13:42-45). A party could argue this encompasses the largest dimensions of the main housing, regardless of any tapers or curves.
- Evidence for a Narrower Interpretation: A party might argue that the term should be interpreted in light of the patent's overall objective of avoiding interference. This could lead to an interpretation where minor protrusions are excluded from the "profile" if they do not practically interfere with an adjacent plug. Figures 1 and 2A, which show a housing with radiused sides and a tapered rear, could be cited to argue that the "profile" is not a simple rectangular prism. (’794 Patent, Fig. 1, Fig. 2A).
VI. Other Allegations
- Indirect Infringement: The complaint does not contain specific allegations of fact to support indirect infringement.
- Willful Infringement: The complaint makes a conclusory request for a determination that infringement has been "willful, wanton, and deliberate." (Compl. ¶C, p.7). It does not allege any specific facts to support this claim, such as pre-suit knowledge of the patent.
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of factual proof: Do the measured dimensions of the accused Novo 35 USB Wall Charger literally fall within the "less than 2.0 inches" length and "less than 1.75 inches" width limitations recited in the reissued patent's Claim 1?
- A secondary question will be one of claim construction: How should the term "outer profile" be construed, and does the accused product's shape, when installed, result in "no interference with an adjacent receptacle" as required by the claim?
- A significant legal question will be the impact of the reissue: Given that the asserted claim was narrowed during reissue, a court will need to determine whether Defendant can establish a defense of intervening rights, which could protect it from damages for any infringement that occurred before the reissue patent was granted on October 26, 2021.