Voltstar Tech Inc v. Motek Team Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Voltstar Technologies, Inc. (Illinois)
  • Defendant: Motek Team Inc. A/K/A Prodigee (California)
  • Plaintiff’s Counsel: Sriplaw, PLLC.
• Case Identification: 3:25-cv-01861, S.D. Cal., 07/22/2025
• Venue Allegations: Venue is alleged to be proper in the Southern District of California because the Defendant is a California corporation with its principal place of business in San Diego and has allegedly committed acts of infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s 20W Wall Charger infringes a reissue patent related to the compact physical design of electrical charger plugs.
• Technical Context: The technology concerns the design of small-footprint AC-to-DC power adapters, aiming to solve the common problem of chargers being too bulky and blocking adjacent electrical outlets.
• Key Procedural History: The patent-in-suit, RE48,794, is a reissue of U.S. Patent No. 9,024,581. The complaint notes that during the reissue process, Claim 1 was amended to narrow its scope by changing a longitudinal length limitation from "equal to or less than 2.0 inches" to "less than 2.0 inches" and by adding a new width limitation of "less than 1.75 inches."

Case Timeline

Date	Event
2008-05-21	Earliest Priority Date ('794 Patent)
2015-05-05	Original U.S. Patent No. 9,024,581 Issues
2021-10-26	U.S. Reissue Patent No. RE48,794 E Issues
2025-07-22	Complaint Filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Reissue Patent No. RE48,794 E - "Charger Plug With Improved Package"

The Invention Explained

• Problem Addressed: The patent's background section describes significant issues with prior art electrical chargers, noting that their size often causes them to block adjacent power outlets ('794 Patent, col. 1:42-49). Additionally, chargers with increased length can be unstable and susceptible to being knocked out of a wall socket ('794 Patent, col. 1:50-57). The patent also identifies the manufacturing process of insert-molding electrical blades and hand-soldering connections as costly, time-consuming, and requiring extra space within the charger housing ('794 Patent, col. 2:5-30).
• The Patented Solution: The invention is a "reduced plug-size charger plug" designed for improved manufacturability and a smaller physical footprint ('794 Patent, Abstract). The design uses blades that can be slidably mounted into the housing, which avoids the need for insert molding, and employs spring contacts to establish an electrical connection with the internal circuitry, reducing the space required for solder joints and hookup wires ('794 Patent, Abstract; col. 3:14-24). The complaint includes an image of an example charger embodying the patented design (Compl. p. 4). This construction allows for a housing with specific, compact dimensions that is claimed to not interfere with adjacent outlets ('794 Patent, col. 13:46-54).
• Technical Importance: This approach addresses the persistent consumer demand for smaller, more portable, and less obtrusive power accessories for the growing market of portable electronic devices (Compl. ¶11).

Key Claims at a Glance

• The complaint asserts infringement of at least Claim 1 of the U.S. Reissue Patent No. RE48,794 E ('794 Patent) (Compl. ¶23).
• The 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 with prong portions secured within a housing.
  • A DC connector for a removable power cord.
  • A housing with a specific configuration, including a front face, an outer profile, and a rear end.
  • The housing being sized with a longitudinal length of less than 2.0 inches and a width of the outer profile being less than 1.75 inches.
  • The outer profile having "no interference with an adjacent receptacle" when a similar charger is in an adjacent socket.

III. The Accused Instrumentality

Product Identification

The accused product is the "Prodigee 20W Wall Charger" ("20W Charger") (Compl. ¶14).

Functionality and Market Context

The 20W Charger is an AC-to-DC power adapter used to charge devices such as mobile phones from a standard wall outlet (Compl. ¶15). The complaint alleges the product employs a "reduced plug-size" design, which enables it to be plugged into a wall outlet without blocking or interfering with the use of adjacent outlets (Compl. ¶16). The complaint provides an image of the accused 20W Charger (Compl. p. 5). It further alleges the size and shape allow a power cord to be easily inserted and removed while the charger remains plugged in (Compl. ¶17).

IV. Analysis of Infringement Allegations

The complaint references a claim chart (Exhibit 2) that was not available for this analysis (Compl. ¶18, ¶23). The infringement theory is therefore summarized based on the narrative allegations in the complaint.

The core of the infringement allegation is that the accused 20W Charger meets the specific dimensional and functional limitations of Claim 1 of the '794 Patent. The complaint alleges that the 20W Charger's physical size falls within the claimed ranges, stating it has a longitudinal length of "approximately 1.723 inches" (which is less than the claimed 2.0 inches) and a width of "approximately 1.562 inches" (which is less than the claimed 1.75 inches) (Compl. ¶20).

Further, the complaint alleges that the 20W Charger meets the functional, non-interference limitation of Claim 1. It asserts that "upon plugging the 20W Charger into a source of AC power such as a wall outlet, the 20W Charger does not block or interfere with the use of adjacent outlets" (Compl. ¶16).

• Identified Points of Contention:
  • Factual Questions: The primary dispute may be factual, centering on whether the accused product's dimensions, when properly measured, are within the specific numerical limits recited in Claim 1. The complaint's use of "approximately" for its measurements (Compl. ¶20) suggests that the precise methodology for measuring the "longitudinal length" and "width of the housing outer profile" could become a point of contention.
  • Scope Questions: The case raises the question of how to interpret and test the functional limitation "the outer profile having no interference with an adjacent receptacle... when a like charger plug is mounted in all available orientations in any of the other receptacles" ('794 Patent, col. 14:49-54). The definition of "interference" and the scope of outlet types and orientations required for testing may be central to the dispute.

V. Key Claim Terms for Construction

• The Term: "longitudinal length extending between the front wall and the rear end"

• Context and Importance: This term is critical because infringement hinges on the accused product having a measured length of "less than 2.0 inches." Practitioners may focus on this term because the precise start and end points for this measurement on a contoured housing could be ambiguous and outcome-determinative.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The plain language "extending between the front wall and the rear end" could be argued to encompass the absolute maximum dimension along that axis, inclusive of any protrusions.
  • Evidence for a Narrower Interpretation: Parties may point to figures in the patent (e.g., Fig. 1) to argue that the "length" refers to the main body of the housing, potentially excluding minor features on the front or rear surfaces.

• The Term: "width of the housing outer profile"

• Context and Importance: This term, added during reissue, establishes the "less than 1.75 inches" limitation. Its construction is vital to the infringement analysis. The meaning of "outer profile" will dictate how the width is measured—for instance, whether it is an average width or the single widest point of the housing.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A party could argue "outer profile" refers to the overall silhouette of the device, meaning the measurement should be the maximum lateral dimension at any point along the housing's length.
  • Evidence for a Narrower Interpretation: The patent also refers to the "lateral width of the plug housing" ('794 Patent, col. 14:4-5). A party might argue this context implies a more specific or standardized measurement of the main housing body, separate from any flanges or tapered edges.

VI. Other Allegations

• Willful Infringement: The prayer for relief seeks a finding of willful infringement (Compl. p. 7, ¶C). However, the complaint body does not plead any specific facts, such as allegations of pre-suit knowledge of the '794 Patent, to support this claim.

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

• A central issue will be one of factual measurement: Does the accused Prodigee 20W Wall Charger, when measured according to a proper construction of the claim terms, possess a "longitudinal length" of less than 2.0 inches and a "width of the housing outer profile" of less than 1.75 inches, as required by Claim 1?
• A second core issue will be one of functional scope: What is the proper legal and technical definition of "no interference with an adjacent receptacle"? The case may turn on what evidence is required to prove or disprove that the accused product's design avoids such interference across the range of standard outlet configurations contemplated by the patent.