8:25-cv-03167
Voltstar Tech Inc v. Lakhani
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Voltstar Technologies, Inc. (Illinois)
- Defendant: Salim Lakhani dba Ceatech, Verizon Value Inc., and Wireless World FL LLC (Florida, Delaware)
- Plaintiff’s Counsel: Sriplaw, PLLC.
- Case Identification: 8:25-cv-03167, M.D. Fla., 11/18/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendants have committed acts of infringement in the district and are subject to personal jurisdiction there.
- Core Dispute: Plaintiff alleges that Defendants’ compact wall chargers infringe a reissue patent related to the specific dimensional and non-interference characteristics of power adapters.
- Technical Context: The technology concerns the design and manufacturing of AC-to-DC power converters, commonly used as chargers for mobile phones and other portable electronics, where compact size is a key market differentiator.
- 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 Claim 1 to change the longitudinal length requirement from "equal to or less than 2.0 inches" to "less than 2.0 inches" and to add a new width limitation of "less than 1.75 inches." This amendment narrows the scope of the original patent, a fact that may be used to argue for the patent's validity over prior art considered during the reissue proceeding.
Case Timeline
| Date | Event |
|---|---|
| 2008-05-21 | Earliest Priority Date (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 |
| 2025-11-18 | Complaint Filing Date |
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's background section describes problems with prior art power chargers, which were often bulky. This bulk could cause the charger to interfere with the use of adjacent electrical outlets, protrude excessively from a wall, or make the charger unsightly. The patent also identifies the manufacturing process for prior art chargers, particularly the use of "insert molding" for the electrical blades and hand-soldering for internal connections, as expensive, time-consuming, and prone to error. (’794 Patent, col. 1:42-2:24).
- The Patented Solution: The invention proposes a charger with a reduced package size achieved through both specific external dimensions and an improved internal construction. The design simplifies manufacturing by, for example, using solder-less spring contacts to connect the blades to the internal circuit board, which obviates the need for insert molding and hand-soldering. (’794 Patent, Abstract; col. 3:13-24). This construction contributes to a smaller overall housing that is dimensionally claimed so as not to impede access to adjacent outlets. (’794 Patent, col. 4:66-68).
- Technical Importance: The claimed solution addresses the consumer demand for smaller, more portable, and less obtrusive electronic accessories, while also targeting cost and complexity reductions in the manufacturing process. (’794 Patent, col. 2:41-47).
Key Claims at a Glance
- The complaint asserts infringement of at least Claim 1 of the ’794 Patent (Compl. ¶26).
- The 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 for plugging into a power source.
- A DC connector for providing power to a rechargeable device.
- The charger plug housing being sized so that it has a longitudinal length of less than 2.0 inches and a width of less than 1.75 inches.
- The housing's outer profile having no interference with an adjacent receptacle of the power source.
- The complaint alleges infringement of "at least one of the claims" of the patent, suggesting the right to assert other claims may be invoked later (Compl. ¶22, 25).
III. The Accused Instrumentality
Product Identification
The accused product is the "CEATECH Dual Port Wall Charger," which is also identified as the "Brookstone PD 20W Charger" (the "CEATECH Charger") (Compl. ¶17).
Functionality and Market Context
The complaint alleges the CEATECH Charger is a reduced-size charger plug designed to be connected between an AC power source and a device like a mobile phone (Compl. ¶18). Its key accused functionalities are its compact size and its shape, which allegedly prevents it from blocking or interfering with adjacent wall outlets (Compl. ¶19). The complaint also alleges the design allows a power cord to be easily inserted and removed while the charger remains plugged into the wall (Compl. ¶20). The complaint includes a photograph of the accused CEATECH Charger, a white, rectangular wall adapter with two prongs. (Compl. p. 6).
IV. Analysis of Infringement Allegations
The complaint references a claim chart attached as Exhibit 2, but this exhibit was not provided (Compl. ¶21). The following summary is based on the narrative allegations in the complaint body.
’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 to convert 120V input power... to DC output power | The CEATECH Charger is a charger connected between a source of AC power, such as a wall outlet, and a device such as a mobile phone that includes a battery being rechargeable through the use of DC power. | ¶18 | col. 14:18-24 |
| 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 CEATECH Charger has a longitudinal length less than 2 inches, approximately 1.606 inches, and a width of less than 1.75 inches, approximately 1.490 inches. | ¶23 | col. 14:46-52 |
| 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 | ...upon plugging the CEATECH Charger into a source of AC power such as a wall outlet, the CEATECH Charger does not block or interfere with the use of adjacent outlets. A visual example of a similar charger from the patentee is provided. (Compl. p. 5). | ¶19 | col. 14:53-59 |
- Identified Points of Contention:
- Factual Questions: A primary point of contention may be the precise measurements of the accused product. The complaint provides specific dimensions ("approximately 1.606 inches" and "approximately 1.490 inches") (Compl. ¶23). The defense could challenge the methodology used to obtain these measurements or present conflicting measurements.
- Scope Questions: The interpretation of "no interference with an adjacent receptacle" will be critical. The dispute may center on whether this requires zero physical overlap with the space of an adjacent outlet or a more functional standard, such as not preventing a standard plug from being inserted and used in the adjacent outlet.
V. Key Claim Terms for Construction
The Term: "outer profile"
Context and Importance: This term is central to both the dimensional and non-interference limitations of Claim 1. The definition of "outer profile" will dictate how the "width" of the housing is measured and what part of the charger is assessed for "interference" with an adjacent outlet.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent repeatedly discusses the overall "package size" and "dimensional size" of the plug, which may support an interpretation that "outer profile" refers to the maximum dimensions of the housing body in any direction. (’794 Patent, col. 1:17-18; col. 12:11-12).
- Evidence for a Narrower Interpretation: The claim language links the "outer profile" to a "perimeter of the front wall" and a "plug body extending rearward." (’794 Patent, col. 14:38-41). This could support an argument that the "outer profile" is limited to the cross-sectional shape of the housing body itself, potentially excluding features like flanges or textured grips.
The Term: "interference"
Context and Importance: The infringement determination for a key limitation rests on whether the accused charger's "outer profile" has "no interference" with an adjacent outlet. This term is not explicitly defined and is susceptible to different interpretations.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A defendant might argue that any physical encroachment into the standardized space of an adjacent receptacle constitutes "interference," regardless of whether it actually prevents use. The term "no interference" could be argued to set an absolute, zero-tolerance standard.
- Evidence for a Narrower Interpretation: The patent's background describes the problem as the plug itself providing "little or no interference with use of an adjacent receptacle." (’794 Patent, col. 1:47-49). This language suggests a functional definition, where "interference" only occurs if the charger actually prevents or hinders the use of the adjacent outlet.
VI. Other Allegations
- Willful Infringement: The prayer for relief requests a determination that Defendants' infringement has been "willful, wanton, and deliberate" and seeks treble damages (Compl. p. 9, ¶C). However, the complaint's factual allegations do not specify a basis for this claim, such as asserting that Defendants had pre-suit knowledge of the ’794 Patent.
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this dispute appears to depend on three central questions:
A core issue will be one of factual verification: Can Plaintiff prove through expert measurement that the accused CEATECH Charger's "longitudinal length" and "width," as properly construed, fall within the precise numerical limitations of "less than 2.0 inches" and "less than 1.75 inches" as required by Claim 1?
A key question of claim scope will be the definition of "interference." The case may turn on whether the court adopts a strict, geometric definition (any physical overlap) or a functional one (preventing the use of an adjacent outlet), as the patent's own language could support either interpretation.
The impact of the reissue proceeding will be a significant undercurrent. By narrowing the claims during reissue, Plaintiff may have strengthened the patent against invalidity challenges but also created a narrower target for its infringement allegations, raising the question of whether the accused product's design avoids the patent's now more-defined boundaries.