DCT
8:23-cv-02101
Voltstar Tech Inc v. Spigen Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Voltstar Technologies, Inc. (Illinois)
- Defendant: Spigen, Inc. (California)
- Plaintiff’s Counsel: Sriplaw, PLLC.
- Case Identification: 8:23-cv-02101, C.D. Cal., 11/08/2023
- Venue Allegations: Venue is alleged to be proper based on the Defendant having committed acts of infringement and maintaining a regular and established place of business within the Central District of California.
- Core Dispute: Plaintiff alleges that Defendant’s line of USB wall chargers infringes a patent related to the specific dimensions and non-interfering design of compact charger plugs.
- Technical Context: The technology concerns power adapters for consumer electronics, specifically designs that minimize the physical footprint to avoid obstructing adjacent electrical outlets.
- Key Procedural History: The patent-in-suit is a reissue of an earlier patent. During the reissue process, the scope of the asserted independent claim was amended to add a specific width limitation and remove the phrase "equal to or" from a length limitation, thereby narrowing the claim's dimensional requirements. This prosecution history may be significant for claim construction.
Case Timeline
| Date | Event |
|---|---|
| 2008-05-21 | Priority Date for U.S. Patent No. 9,024,581 |
| 2015-05-05 | Issue Date of U.S. Patent No. 9,024,581 |
| 2021-10-26 | Issue Date of Reissue Patent No. RE48,794 E |
| 2023-11-08 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Reissue Patent No. RE48,794 E - "Charger Plug With Improved Package"
- Patent Identification: U.S. Reissue Patent No. RE48,794 E, issued October 26, 2021.
The Invention Explained
- Problem Addressed: The patent's background section describes problems with prior art electrical charger plugs, noting they are often bulky and can block adjacent receptacles in a wall outlet (ʼ794 Patent, col. 1:42-48). It also identifies the manufacturing processes of insert-molding electrical blades and hand-soldering internal components as being costly, time-consuming, and contributing to a larger product size (ʼ794 Patent, col. 2:1-41).
- The Patented Solution: The invention claims to solve these problems with a "reduced plug-size charger" that uses a simplified, solder-less assembly method and is specifically dimensioned to be compact ('794 Patent, Abstract). The design features slidably mounted electrical blades that connect to the internal printed circuit board via spring contacts, which is intended to reduce manufacturing complexity and cost while enabling a smaller physical housing that does not interfere with other outlets ('794 Patent, col. 3:14-28; Fig. 2C).
- Technical Importance: The claimed technical approach addresses a common consumer annoyance with power adapters and aims to reduce manufacturing costs for a high-volume consumer product (Compl. ¶12).
Key Claims at a Glance
- The complaint asserts infringement of at least Claim 1 of the '794 Patent (Compl. ¶41).
- The essential elements of independent Claim 1 include:
- A charger plug with a housing and separate blade members.
- A DC connector for a removable power cord.
- The housing being sized with a longitudinal length less than 2.0 inches and a width of the outer profile being less than 1.75 inches.
- The housing's outer profile having "no interference with an adjacent receptacle" when plugged in.
- The complaint does not explicitly reserve the right to assert dependent claims but alleges infringement of "at least one of the claims" (Compl. ¶23).
III. The Accused Instrumentality
Product Identification
- The complaint identifies three accused products: the Spigen ArcStation USB-C PD 27W Charger, the Spigen PowerArc ArcStation Pro Charger, and the Spigen ArcStation Pro GaN 652 (Compl. ¶18, ¶25, ¶32).
Functionality and Market Context
- The accused instrumentalities are described as USB-C wall chargers that connect to a standard AC power outlet to provide DC power for charging electronic devices such as mobile phones (Compl. ¶19, ¶26, ¶33). The complaint alleges that these chargers employ a "reduced plug-size" design, a key feature of which is that they do not block or interfere with the use of adjacent outlets (Compl. ¶20, ¶27, ¶34). The complaint provides a visual example of the Spigen ArcStation USB-C PD 27W Charger, showing the device and its retail packaging (Compl. p.5).
IV. Analysis of Infringement Allegations
The complaint does not attach the referenced claim chart exhibits. The following summary is based on the narrative allegations for the Spigen ArcStation USB-C PD 27W Charger.
'794 Patent 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... | The accused charger is advertised and sold to be connected between a source of AC power, such as a wall outlet, and a device such as a mobile phone. | ¶19 | col. 13:18-24 |
| the charger plug including a DC connector having an aperture adapted to removably receive a corresponding power cord plug end... | The accused product is a USB-C charger, which by definition includes a DC connector (the USB-C port) to receive a power cord. | ¶18-19 | col. 13:31-34 |
| 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... | The complaint alleges the ArcStation USB-C Charger has a longitudinal length of "approximately 1.209 inches" and a width of "approximately 1.228 inches." | ¶24 | col. 13:51-14:5 |
| 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 the ArcStation USB-C Charger "does not block or interfere with the use of adjacent outlets." | ¶20 | col. 14:6-12 |
Identified Points of Contention
- Scope Questions: A central issue may be the proper methodology for measuring the "longitudinal length" and "width of the housing outer profile." The patent does not appear to provide an explicit measurement protocol, raising the question of which physical features on the accused products constitute the boundaries for these dimensions.
- Technical Questions: The functional limitation of "no interference with an adjacent receptacle" will require factual determination. A question for the court will be what level of physical interaction, if any, constitutes "interference" as contemplated by the patent. The evidence presented on how the accused products perform in various multi-outlet configurations will be critical.
V. Key Claim Terms for Construction
"outer profile"
- Context and Importance: This term is foundational to both the dimensional limitation (width less than 1.75 inches) and the functional limitation (no interference). Its construction will define the physical boundary of the object being measured and assessed for interference, directly impacting the infringement analysis. Practitioners may focus on this term because its definition dictates whether the specific shapes of the accused products fall within the claim scope.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself uses the term broadly: "a width of the housing outer profile" and "the outer profile having no interference" ('794 Patent, col. 14:4, col. 14:7). This could suggest the term encompasses the overall external boundary of the housing.
- Evidence for a Narrower Interpretation: The specification discusses specific features that contribute to the shape, such as "generally radiused sides 82, which serve to reduce packaging size" ('794 Patent, col. 8:62-64). A party could argue that "outer profile" is tied to these specific design characteristics shown in figures like Fig. 10, potentially excluding minor protrusions or surface textures from the measurement.
"longitudinal length"
- Context and Importance: The claim requires this dimension to be "less than 2.0 inches." The infringement determination for this element will depend entirely on the agreed-upon start and end points for measurement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim defines the length as "extending between the front wall and the rear end" ('794 Patent, col. 13:52-54). A party could argue this refers to the absolute outermost points of the housing along the longitudinal axis, regardless of the specific components at those points.
- Evidence for a Narrower Interpretation: The specification refers to a "front surface 100 of a front wall 102" and a "rear end 40 of the housing" ('794 Patent, col. 9:15, col. 7:57-58). Parties will likely dissect these descriptions and the associated figures to argue for specific measurement landmarks, such as whether the "rear end" measurement should include or exclude any part of the DC connector that may protrude from the main housing.
VI. Other Allegations
Willful Infringement
- The complaint seeks a determination that the infringement was "willful, wanton, and deliberate" and requests enhanced damages (Compl. p.10, ¶C). The complaint does not, however, allege any specific facts to support pre-suit knowledge of the patent, such as a notice letter or prior litigation. The basis for willfulness appears to be the act of infringement itself, potentially limiting the claim to post-suit conduct.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional precision: How are the claim terms "longitudinal length" and "width of the housing outer profile" to be construed and measured? The outcome may turn on whether the court adopts a measurement methodology that places the accused products' dimensions inside or outside the specific numeric limits recited in Claim 1.
- A key evidentiary question will be one of functional scope: What constitutes "no interference with an adjacent receptacle" under the patent? The case will likely involve factual disputes over whether the physical presence of the accused chargers in standard multi-receptacle outlets meets the non-interference standard required by the claim.