Voltstar Tech Inc v. Vava Intl Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Voltstar Technologies, Inc. (Illinois)
  • Defendant: VAVA International Inc. (California)
  • Plaintiff’s Counsel: Sriplaw, PLLC.
• Case Identification: 5:23-cv-00284, N.D. Cal., 01/19/2023
• Venue Allegations: Venue is alleged to be proper in the Northern District of California because Defendant VAVA International Inc. has committed alleged acts of infringement and maintains a regular and established place of business within the district.
• Core Dispute: Plaintiff alleges that Defendant’s compact wall chargers infringe a reissue patent related to the specific dimensional and functional characteristics of small form-factor power adapters.
• Technical Context: The technology concerns AC-to-DC power adapters for consumer electronics, a field where miniaturization is a key driver of product design and marketability.
• Key Procedural History: The patent-in-suit, RE48,794, is a reissue of U.S. Patent No. 9,024,581. The complaint notes that the reissue process amended the original patent's Claim 1 to narrow its scope, changing a length limitation from "equal to or less than 2.0 inches" to strictly "less than 2.0 inches," and adding a new width limitation of "less than 1.75 inches." This amendment highlights the centrality of precise physical dimensions to the patent’s claims. The complaint also states that as of the original patent's issue date, the Plaintiff had ceased selling any articles covered by the patent.

Case Timeline

Date	Event
2008-05-21	Priority Date for U.S. Patent No. 9,024,581 (based on application filing)
2009-11-26	Application for the '581 Patent published
2015-05-05	U.S. Patent No. 9,024,581 issues
2021-10-26	U.S. Reissue Patent No. RE48,794 E issues
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"

• 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 describes issues with prior art power adapters, which were often bulky and manufactured using costly and time-consuming processes like insert-molding AC blades into the plastic housing and hand-soldering connections to the internal circuit board. These large designs could block adjacent electrical outlets, hindering usability (’794 Patent, col. 1:42-48, col. 1:60-2:11).
• The Patented Solution: The invention discloses a compact charger plug with an improved mechanical design. It obviates the need for insert molding by using a housing with openings that slidably receive separate AC blades. Electrical connection is made without solder by using wire-form spring contacts that press against the inserted blades to connect them to the internal power conversion circuitry ('794 Patent, col. 3:14-28, Fig. 2B). This construction method is intended to simplify assembly, reduce manufacturing costs, and enable a smaller final product ('794 Patent, col. 1:13-18).
• Technical Importance: The design aimed to produce a charger that was not only smaller and less expensive to manufacture but also more consumer-friendly by ensuring its physical profile did not obstruct the use of adjacent outlets ('794 Patent, col. 13:4-9).

Key Claims at a Glance

• The complaint asserts independent Claim 1.
• Essential elements of Claim 1 include:
  • A charger plug for converting 120V AC power to DC output power.
  • A housing containing first and second separate blade members.
  • A DC connector for a power cord.
  • A specific configuration where the housing is sized with i) a longitudinal length less than 2.0 inches and a width less than 1.75 inches, and ii) an outer profile that creates no interference with an adjacent receptacle.
• The complaint does not explicitly reserve the right to assert dependent claims, but infringement is alleged for "at least one of the claims" (Compl. ¶23).

III. The Accused Instrumentality

Product Identification

• The complaint identifies two accused products: the "RAVPower 2-Pack 30W Power Delivery Wall Charger" (the "RAVPower 30W Wall Charger") and the "RAVPower PD Pioneer 20W Wall Charger" (the "RAVPower 20W Wall Charger") (Compl. ¶18, ¶25).

Functionality and Market Context

• The complaint describes the accused products as "reduced plug-size" chargers used to connect between an AC power source, like a wall outlet, and a mobile device for battery charging (Compl. ¶19, ¶26). Plaintiff alleges the compact design of the chargers ensures that they do not block or interfere with the use of adjacent outlets when plugged in (Compl. ¶20, ¶27). An image provided in the complaint shows the RAVPower 30W Wall Charger, a compact black rectangular adapter with foldable AC prongs (Compl. p. 5, Image). A similar image depicts the RAVPower 20W Wall Charger (Compl. p. 6, Image).

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits that were not included in the filing; therefore, the infringement theory is summarized below based on the narrative allegations.

The infringement allegations for both the 30W and 20W RAVPower chargers center on Claim 1 of the ’794 Patent. The complaint alleges that these products are compact wall chargers that convert AC to DC power as broadly required by the claim (Compl. ¶19, ¶26). The core of the infringement allegation rests on the specific dimensional and functional limitations recited in sub-parts (i) and (ii) of Claim 1.

For sub-part (i), the complaint alleges that the accused products meet the specific size requirements. It provides purported measurements, stating the 30W charger has a longitudinal length of approximately 1.682 inches and a width of 1.216 inches, and the 20W charger has a length of 1.207 inches and a width of 1.116 inches (Compl. ¶24, ¶31). These alleged dimensions fall within the claimed limits of "less than 2.0 inches" for length and "less than 1.75 inches" for width ('794 Patent, col. 13:50-55).

For sub-part (ii), the complaint alleges that the "reduced plug-size" of the accused chargers ensures they do "not block or interfere with the use of adjacent outlets," which maps to the claim's requirement of having an "outer profile having no interference with an adjacent receptacle" (Compl. ¶20, ¶27; ’794 Patent, col. 13:56-14:3).

Identified Points of Contention:

• Factual & Measurement Questions: A primary point of contention may be factual: do the accused products actually have the dimensions alleged by the Plaintiff? The methodology for measuring the "longitudinal length" and "width of the housing outer profile" on the specific geometry of the accused products could become a focus of dispute.
• Scope Questions: The case raises the question of how to interpret the functional limitation "no interference with an adjacent receptacle." Does this mean no interference with the physical outlet, or no interference with another standard plug being used in that outlet? The complaint’s allegation that the chargers do not "block or interfere with the use" of adjacent outlets suggests Plaintiff may advocate for the latter, potentially more stringent, interpretation (Compl. ¶20, ¶27).

V. Key Claim Terms for Construction

• The Term: "longitudinal length"

• Context and Importance: This term is critical because it defines one of the two explicit numerical boundaries of the claim. The infringement analysis for sub-part (i) will depend entirely on whether the measured length of the accused products is "less than 2.0 inches" according to the court's construction of this term.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent does not provide a special definition for the term, which may support giving it a plain and ordinary meaning as understood by a person of ordinary skill in the art.
  • Evidence for a Narrower Interpretation: Claim 1 specifies the length as "extending between the front wall and the rear end" of the housing ('794 Patent, col. 13:50-52). The patent's figures and description of the "front wall" (the face with the prongs) and "rear end" (the face with the DC connector) could be used to argue for a specific, constrained method of measurement that excludes or includes certain features ('794 Patent, Fig. 1).

• The Term: "outer profile having no interference with an adjacent receptacle"

• Context and Importance: This functional limitation is a cornerstone of the patent's asserted novelty over bulky prior art. Its construction will determine the standard of proof for infringement of sub-part (ii). Practitioners may focus on this term because its breadth is debatable—is any physical overlap "interference," or must it prevent the use of the adjacent outlet?

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: One could argue the plain meaning requires only that the charger's physical body does not physically obstruct the openings of an adjacent standard outlet.
  • Evidence for a Narrower Interpretation: The claim language continues, stating this condition applies "when a like charger plug is mounted in all available orientations in any of the other receptacles" ('794 Patent, col. 13:59-14:3). This could be argued to set a specific, testable standard: the "outer profile" must be small enough not to interfere with the use of adjacent outlets, even when those outlets are also occupied by identical chargers.

VI. Other Allegations

Indirect Infringement

• The complaint includes only one count for direct infringement (Compl. p. 7). While some paragraphs contain boilerplate language referencing acts that could support indirect infringement, the pleading does not set forth specific factual allegations required for such a claim, such as providing instructions to end-users that would cause infringement.

Willful Infringement

• The prayer for relief requests a determination that Defendant's infringement was willful, warranting treble damages (Compl. p. 8, ¶C). The body of the complaint, however, does not plead specific facts to support a claim of pre-suit knowledge of the patent or egregious conduct, which are typically foundational for a willfulness finding.

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

This dispute appears to hinge on a combination of factual measurement and claim interpretation, focusing on the physical size of the accused chargers. The central questions for the court will likely be:

• A core issue will be one of measurement and fact: Can the plaintiff prove, by a preponderance of the evidence, that the "longitudinal length" and "width" of the accused chargers, as these terms are construed by the court, fall within the precise numerical limitations of "less than 2.0 inches" and "less than 1.75 inches" recited in Claim 1?
• A key legal and evidentiary question will be one of functional scope: What is the proper construction of "no interference with an adjacent receptacle"? The answer will define the standard the plaintiff must meet to prove infringement of this functional limitation, potentially requiring evidence of how the accused chargers perform in various standard multi-outlet configurations.