Voltstar Tech Inc v. Kanex Pro Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Voltstar Technologies, Inc. (Illinois)
  • Defendant: Kanex Pro Inc. (Nevada)
  • Plaintiff’s Counsel: Sriplaw, PLLC.
• Case Identification: 8:24-cv-00668, C.D. Cal., 03/28/2024
• Venue Allegations: Venue is alleged to be proper based on Defendant having committed acts of infringement and having a regular and established place of business in the district.
• Core Dispute: Plaintiff alleges that Defendant’s USB-C power adapter infringes a reissue patent related to the dimensional and functional characteristics of compact electrical chargers.
• Technical Context: The technology concerns the design of small-form-factor AC-to-DC power adapters, commonly used for mobile phones and other portable electronics, where physical size impacts usability with standard 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 the reissue amended Claim 1 to narrow a dimensional limitation from "equal to or less than 2.0 inches" to "less than 2.0 inches," a change that could impact claim scope and the doctrine of equivalents.

Case Timeline

Date	Event
2008-05-21	Earliest Priority Date ('581 Patent Application Filing)
2015-05-05	U.S. Patent No. 9,024,581 Issued
2021-10-26	U.S. Reissue Patent No. RE48,794 E Issued
2024-03-28	Complaint Filed

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, "Charger Plug With Improved Package", issued October 26, 2021.

The Invention Explained

• Problem Addressed: The patent addresses problems with prior art electrical chargers, including their physical size, which can block adjacent wall outlets, and their protrusion length, which makes them susceptible to being struck or dislodged from the wall, particularly when behind furniture ('794' Patent, col. 1:41-58). The patent also identifies high manufacturing costs and complexity associated with insert molding of electrical blades and hand-soldering connections as issues to be solved ('794 Patent, col. 2:11-30).
• The Patented Solution: The invention describes a compact charger plug with a housing designed to not interfere with adjacent outlets. The design claims to achieve this compact size through a specific internal assembly that uses slidable blades and spring contacts, which obviates the need for more costly and space-consuming insert molding and direct soldering techniques ('794 Patent, col. 3:14-28; Abstract). This construction method allows for a smaller overall package.
• Technical Importance: The described approach aimed to reduce both the manufacturing cost and the physical footprint of common power adapters, improving user convenience and device reliability ('794 Patent, col. 1:15-19).

Key Claims at a Glance

• The complaint asserts infringement of at least independent Claim 1 (Compl. ¶27).
• Essential elements of Independent Claim 1 include:
  • A charger plug for converting 120V input power to DC output power.
  • A housing with first and second separate blade members secured within.
  • A DC connector with an aperture for a power cord.
  • The housing being sized so that its longitudinal length is "less than 2.0 inches" and the width of its "outer profile" is "less than 1.75 inches."
  • The "outer profile having no interference with an adjacent receptacle of the power source" 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 Kanex GoPower 18W USB-C Power Adapter ("Power Adapter") (Compl. ¶18).

Functionality and Market Context

• The complaint alleges the Power Adapter is a charger that connects between an AC power source, like a wall outlet, and a device such as a mobile phone to provide DC charging power (Compl. ¶¶19, 27). The complaint includes an image of the accused Power Adapter, showing a compact, black, wall-wart style charger with a USB-C port (Compl. p. 5).
• Plaintiff alleges the accused product employs a "reduced plug-size charger plug" design that, when plugged in, "does not block or interfere with the use of adjacent outlets" (Compl. ¶20). The complaint further alleges that a power cord can be easily inserted and removed while the adapter remains plugged into the wall (Compl. ¶21).

IV. Analysis of Infringement Allegations

The complaint references a claim chart attached as Exhibit 2 that purportedly illustrates the infringement of Claim 1 (Compl. ¶22). However, this exhibit was not included with the filed complaint document. In its absence, the infringement theory is summarized from the complaint's narrative allegations.

The core of the infringement allegation is that the accused Kanex Power Adapter meets the specific dimensional and functional limitations of Claim 1 of the '794 Patent. Plaintiff alleges that the Power Adapter has a longitudinal length of approximately 1.766 inches (less than the claimed 2.0 inches) and a width of approximately 1.592 inches (less than the claimed 1.75 inches) (Compl. ¶24). The complaint also asserts that the size and shape of the Power Adapter are such that it does not interfere with the use of adjacent outlets, directly mapping to the "no interference" limitation of Claim 1 (Compl. ¶20). An image of the accused product is provided to visually support its compact nature (Compl. p. 5).

Identified Points of Contention

• Factual Question: The primary dispute will likely be factual: do the accused Power Adapters, as sold, consistently meet the precise dimensional limitations of "less than 2.0 inches" in length and "less than 1.75 inches" in width? The specific methodology for measuring these dimensions on the product's potentially curved or tapered housing could be a point of contention.
• Scope Question: A key legal and factual question is what constitutes "no interference with an adjacent receptacle" under the claim. This raises the question of whether this limitation is met if any commercially available plug can be used in an adjacent socket, or only certain types of plugs. The parties may dispute the standard for assessing "interference."

V. Key Claim Terms for Construction

• The Term: "outer profile having no interference with an adjacent receptacle"
• Context and Importance: This term is critical because it moves beyond simple numerical dimensions to define a functional characteristic of the claimed charger. The entire purpose of the dimensional limitations is to achieve this functional outcome. How "interference" is defined—whether it means any physical contact, or a level of obstruction that prevents practical use of the adjacent outlet—will be central to the infringement analysis. Practitioners may focus on this term because it is less objective than a numerical measurement and requires interpretation in the context of a standard power outlet.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification repeatedly emphasizes the goal of avoiding obstruction, stating the plug "provides little or no interference with use of an adjacent receptacle" ('794 Patent, col. 1:46-48). This language may support an interpretation where any functional impairment of the adjacent outlet constitutes "interference."
  • Evidence for a Narrower Interpretation: The claims tie the "no interference" feature to a "like charger plug" being mounted in an adjacent receptacle (Claim 1(ii)). A defendant may argue this limits the "no interference" test to a specific scenario involving another identical charger, not just any possible plug, potentially narrowing the scope of what constitutes infringement. The patent also describes the problem in the context of "two- or three-outlet receptacles as defined by NEMA standards" ('794 Patent, col. 12:14-15), which could be used to argue for a specific, standardized context for evaluating interference.

VI. Other Allegations

• Indirect Infringement: The complaint does not contain a specific count for indirect infringement. It makes a general allegation that Kanex "advertises the use of" its Power Adapter, but provides no specific facts to support the knowledge and intent required for induced infringement (Compl. ¶19).
• Willful Infringement: A request for a determination of willful infringement is included in the prayer for relief (Compl. p. 7, ¶C). However, the complaint does not plead specific facts to support a claim of willfulness, such as allegations of pre-suit knowledge of the patent or egregious conduct.

VII. Analyst’s Conclusion: Key Questions for the Case

1. A central issue will be one of factual proof and measurement: Can Plaintiff demonstrate through expert testimony and evidence that the accused Kanex Power Adapter's "longitudinal length" and "width of the housing outer profile," when measured according to a methodology consistent with the patent, fall within the precise numerical limits of Claim 1?
2. The case may also turn on a question of claim scope and interpretation: How will the court construe the functional limitation "outer profile having no interference with an adjacent receptacle"? The definition of "interference" and the context in which it is measured (e.g., with what type of adjacent plug) will be critical to the infringement analysis.
3. A significant legal question involves the effect of the reissue proceeding: The complaint highlights the narrowing amendment made to Claim 1 during reissue (Compl. ¶13, n.1). This history raises the question of whether prosecution history estoppel will bar the plaintiff from asserting infringement under the doctrine of equivalents for any charger with a length of exactly 2.0 inches or greater.