DCT
4:23-cv-00281
Voltstar Tech Inc v. Peak Design
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Voltstar Technologies, Inc. (Illinois)
- Defendant: Peak Design (California)
- Plaintiff’s Counsel: Sriplaw, PLLC.
- Case Identification: 3:23-cv-00281, N.D. Cal., 01/19/2023
- Venue Allegations: Venue is asserted based on Defendant having a regular and established place of business within the Northern District of California and having committed alleged acts of infringement in the district.
- Core Dispute: Plaintiff alleges that Defendant’s Wall Power Adapter infringes a reissue patent related to the specific size, dimensions, and non-interfering profile of electrical charger plugs.
- Technical Context: The technology concerns the design of compact AC-to-DC power adapters, commonly used for charging mobile electronic devices, where the physical size is minimized to prevent obstruction of adjacent electrical outlets.
- Key Procedural History: The asserted patent, U.S. Reissue Patent No. RE48,794 E, is a reissue of U.S. Patent No. 9,024,581. The complaint notes that the reissue amended Claim 1 to add a specific width limitation ("a width of the housing outer profile being less than 1.75 inches") and removed "equal to or" from the length limitation, thereby narrowing the original claim's dimensional scope.
Case Timeline
| Date | Event |
|---|---|
| 2008-05-21 | '581 Patent Priority Date (Application No. 12/124,515) |
| 2009-11-26 | '581 Patent Application Published |
| 2015-05-05 | '581 Patent Issued |
| 2018-12-04 | '794 Reissue Patent Application Filed |
| 2021-10-26 | '794 Reissue Patent Issued |
| 2023-01-19 | 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 addresses design issues with prior art power converters or "charger plugs." These issues include plugs being physically bulky, often blocking access to adjacent receptacles in a power outlet, and having manufacturing processes (like insert molding and hand soldering) that are costly, time-consuming, and can introduce defects. (RE48,794 E Patent, col. 1:42-51, col. 2:1-31).
- The Patented Solution: The invention discloses a charger plug with a specific housing structure and dimensional profile designed to be compact and non-obstructing. The design uses separate blade members that are slidably mounted into the housing rather than insert-molded, and solder-less spring contacts to connect the blades to the internal circuitry, simplifying assembly and reducing size. (’794 Patent, col. 4:3-17, Abstract). The overall configuration, including the shape and specific dimensions, is intended to ensure the plug does not interfere with adjacent outlets. (’794 Patent, col. 13:45-49).
- Technical Importance: The described approach sought to reduce manufacturing costs and create a more user-friendly, compact charger that could be used in crowded power strips or wall outlets without impeding other plugs. (’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.
- First and second separate blade members secured within a housing.
- A DC connector with an aperture to removably receive a power cord.
- A housing with a specific size and profile, comprising:
- i) a longitudinal length of less than 2.0 inches and a width of the outer profile of less than 1.75 inches.
- ii) an outer profile that has "no interference with an adjacent receptacle" on all sides when plugged into a standard wall outlet.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
- The "Peak Design Wall Power Adapter." (Compl. ¶18).
Functionality and Market Context
- The complaint alleges the accused product is a charger that connects an AC power source, like a wall outlet, to a device with a rechargeable battery. (Compl. ¶19).
- The complaint describes the accused product as employing a "reduced plug-size charger plug" and asserts that its size and shape are such that it "does not block or interfere with the use of adjacent outlets." (Compl. ¶20). An image provided in the complaint shows a compact, black rectangular wall adapter with two prongs. (Compl. p. 5). The complaint also alleges that a power cord can be easily inserted into and removed from the adapter while it remains plugged into an AC source. (Compl. ¶21).
IV. Analysis of Infringement Allegations
The complaint references a claim chart in an unattached exhibit. (Compl. ¶22). The infringement theory for Claim 1 can be constructed from the narrative allegations.
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 accused product is a "charger that is to be connected between a source of AC power, such as a wall outlet, and a device... with the battery being rechargeable through the use of DC power." | ¶19 | col. 13:17-24 |
| ...the charger plug including a DC connector having an aperture adapted to removably receive a corresponding power cord plug end for transmitting DC power... | "...a power cord for the device to be charged may be easily inserted into and removed from the Peak Design Wall Power Adapter while the charger is plugged into the source of AC power..." | ¶21 | col. 13:26-30 |
| ...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... | "The Peak Design Wall Power Adapter has a longitudinal length less than 2 inches, approximately 1.741 inches..." | ¶24 | col. 13:49-53 |
| ...a width of the housing outer profile being less than 1.75 inches... | "...and a width of less than 1.75 inches, approximately 1.301 inches." | ¶24 | col. 13:53-54 |
| ...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... | "...upon plugging the Peak Design Wall Power Adapter into a source of AC power such as a wall outlet, the Peak Design Wall Power Adapter does not block or interfere with the use of adjacent outlets." | ¶20 | col. 13:55-62 |
- Identified Points of Contention:
- Scope Questions: A central dispute may concern the meaning of "outer profile having no interference with an adjacent receptacle." The complaint makes a conclusory allegation of non-interference. (Compl. ¶20). The case may require defining what constitutes "interference" and establishing a standard for how this functional limitation is tested and proven.
- Technical Questions: The complaint provides specific length and width measurements for the accused product. (Compl. ¶24). A factual question may arise as to how the "longitudinal length" and "width of the housing outer profile" are properly measured on the accused product, as shown in the complaint's photograph (Compl. p. 5), and whether those measurement methods align with the patent's description.
V. Key Claim Terms for Construction
"outer profile having no interference with an adjacent receptacle"
- Context and Importance: This is a functional limitation that lies at the core of the invention's stated purpose. Practitioners may focus on this term because its construction will determine the standard of infringement. The definition of "interference"—whether it means any physical contact, obstruction of plug insertion, or some other standard—will be critical.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language "on all sides of the first receptacle" and "in all available orientations" suggests the non-interference requirement is comprehensive and applies to any standard multi-receptacle outlet configuration. (’794 Patent, col. 13:55-62).
- Evidence for a Narrower Interpretation: The specification provides specific, preferred dimensions (e.g., width of "approximately 1.35 inches," length of "approximately 1.75 inches," height of "approximately 0.7 inches"). (’794 Patent, col. 14:5-10). A party could argue that the functional "no interference" language should be understood in the context of a device that meets these exemplary dimensions, potentially limiting its scope to similarly-sized profiles.
"longitudinal length" and "width of the housing outer profile"
- Context and Importance: These terms define the specific dimensional boundaries of the claimed invention. The complaint alleges that the accused product falls squarely within these numeric limits. (Compl. ¶24). The dispute will likely turn on the precise definitions of what constitutes the "housing outer profile" and from which points the "length" and "width" are measured.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The terms are not explicitly defined, which may support giving them their plain and ordinary meaning as understood by a person of ordinary skill in the art. The patent refers to the "longitudinal length" as extending "between the front wall and the rear end," providing a general axis for measurement. (’794 Patent, col. 13:50-51).
- Evidence for a Narrower Interpretation: Figure 15 of the patent depicts vertical dimensions (150, 154) which, along with other figures, could be used to argue for a specific methodology for measuring the "profile" that excludes certain features or requires measurement from specific structural points, potentially altering the resulting dimensions. (’794 Patent, Fig. 15).
VI. Other Allegations
- Indirect Infringement: The complaint does not contain an explicit count for indirect infringement, nor does it allege specific facts to support the elements of inducement or contributory infringement, such as knowledge or intent based on product manuals or advertising.
- Willful Infringement: The complaint does not contain a separate count for willful infringement or plead specific facts supporting it, such as allegations of pre-suit knowledge of the patent. However, the prayer for relief requests a determination that infringement has been "willful, wanton, and deliberate" and seeks enhanced damages. (Compl. p. 7, ¶C).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of claim construction and functional scope: How will the court define the functional requirement of "no interference with an adjacent receptacle"? The outcome may depend on whether this is construed as a strict, zero-tolerance standard or a more practical standard that allows for incidental contact without functional obstruction.
- A second key issue will be one of metrology and evidence: Assuming the court construes the dimensional terms, what evidence will be required to prove that the accused product's "longitudinal length" and "width of the housing outer profile" meet the specific sub-2.0-inch and sub-1.75-inch limitations? The case may turn on a "battle of the experts" regarding the proper method for measuring the physical device.