DCT
1:22-cv-23995
Voltstar Tech Inc v. Best Buy Co Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Voltstar Technologies, Inc. (Illinois)
- Defendant: Best Buy Co., Inc. and BBY Solutions, Inc. (Minnesota)
- Plaintiff’s Counsel: Sriplaw, PLLC.
- Case Identification: 1:22-cv-23995, S.D. Fla., 12/08/2022
- Venue Allegations: Venue is alleged to be proper because Defendants have committed acts of infringement and maintain a regular and established place of business in the Southern District of Florida.
- Core Dispute: Plaintiff alleges that Defendants’ Insignia-brand compact USB-C wall chargers infringe a patent related to the design and dimensional characteristics of small-form-factor power adapters.
- Technical Context: The technology concerns the mechanical design and packaging of AC-to-DC power converters (chargers) for consumer electronics, focusing on minimizing size to prevent obstruction of adjacent wall outlets.
- Key Procedural History: The patent-in-suit, RE48,794 E, is a reissue of U.S. Patent No. 9,024,581. The complaint notes that during reissue, Claim 1 was amended to narrow the claimed dimensions of the charger housing, a fact that may be relevant to claim scope and potential defenses like intervening rights.
Case Timeline
| Date | Event |
|---|---|
| 2008-05-21 | Priority Date for U.S. Patent No. 9,024,581 |
| 2015-05-05 | U.S. Patent No. 9,024,581 Issued |
| 2021-10-26 | Reissue Patent No. RE48,794 E Issued |
| 2022-12-08 | 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 significant issues with prior art power chargers, noting they were often bulky, which resulted in the charger blocking adjacent electrical outlets. (’794 Patent, col. 1:42-49). Additionally, manufacturing processes involving insert molding and manual soldering were described as costly, time-consuming, and prone to error. (’794 Patent, col. 2:1-29).
- The Patented Solution: The invention claims to solve these problems through a charger with a specific compact physical design and a simplified internal construction. The design features a housing with specific dimensional limitations intended to ensure it does not interfere with adjacent outlets. (’794 Patent, col. 13:1-8). The internal assembly uses slidable power blades that connect with the printed circuit board via spring contacts, which is described as obviating the need for soldering and insert molding. (’794 Patent, Abstract; col. 4:13-28). Figure 20 provides a schematic representation of the charger plug in relation to a NEMA outlet and a power cord. (’794 Patent, Fig. 20).
- Technical Importance: This approach sought to meet market demand for smaller and less obtrusive chargers for portable electronics, while also simplifying assembly and reducing manufacturing costs. (’794 Patent, col. 1:13-18).
Key Claims at a Glance
- The complaint asserts at least independent Claim 1. (Compl. ¶32).
- 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 for a removable power cord.
- The housing being sized with a longitudinal length less than 2.0 inches and a width less than 1.75 inches.
- The housing’s outer profile having no interference with an adjacent receptacle of a power source on all sides and in all available orientations.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
The "Insignia 25 W USB-C Compact Wall Charger" and the "Insignia 45 W USB-C Compact Wall Charger Kit" (collectively, the "Accused Products"). (Compl. ¶¶16, 23).
Functionality and Market Context
The Accused Products are described as compact wall chargers that convert AC power from a wall outlet to DC power for charging devices like mobile phones via a USB-C connection. (Compl. ¶¶17, 24). The complaint alleges that due to their "reduced plug-size," the chargers do not block or interfere with the use of adjacent outlets when plugged in. (Compl. ¶¶18, 25). The complaint includes an image of the 25 W Accused Product, showing a small, black, rectangular charger with two AC prongs. (Compl. p. 5, ¶16). A similar image is provided for the 45 W Accused Product. (Compl. p. 6, ¶23).
IV. Analysis of Infringement Allegations
The complaint references claim chart exhibits that were not attached to the publicly filed document; however, it provides narrative allegations for each key element of Claim 1. (Compl. ¶¶20, 27).
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... to DC output power | The Accused Products are wall chargers that connect to a source of AC power, such as a wall outlet, to provide DC power for charging a device such as a mobile phone. | ¶¶17, 24 | col. 13:17-25 |
| a housing | The Accused Products are contained within a housing. An image provided in the complaint shows the housing of the 25 W USB-C Wall Charger. (Compl. p. 5, ¶16). | ¶¶16, 23 | col. 8:55-61 |
| i) 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 complaint alleges the 25 W charger has a longitudinal length of approximately 1.440 inches and a width of 1.305 inches. The 45 W charger is alleged to have a length of 1.635 inches and a width of 1.478 inches. | ¶¶22, 29 | col. 14:45-53 |
| ii) 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 | The complaint alleges that upon plugging the Accused Products into an AC power source, they do not block or interfere with the use of adjacent outlets. | ¶¶18, 25 | col. 13:51-col. 14:2 |
- Identified Points of Contention:
- Technical Questions: A primary factual dispute may concern the measurements of the Accused Products. The infringement analysis will depend on whether Defendants' products meet the specific dimensional limitations of "less than 2.0 inches" in length and "less than 1.75 inches" in width, as defined by the patent.
- Scope Questions: The claim requires "no interference with an adjacent receptacle... on all sides... in all available orientations." This raises the question of whether this limitation requires absolute non-interference with any possible plug in any standard multi-receptacle outlet, or if it is limited to a more practical standard. The breadth of this "no interference" language may be a central point of dispute regarding both infringement and validity.
V. Key Claim Terms for Construction
The Term: "outer profile"
Context and Importance: This term is critical as it defines the boundary of the charger that is subject to the width and non-interference limitations. The construction of "outer profile" will dictate how the charger is measured and assessed for interference, directly impacting the infringement analysis.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification uses the term in a general sense, referring to "a perimeter of the front wall" and the "plug body extending rearward." (’794 Patent, col. 13:46-49). This could support a reading that encompasses the overall shape of the housing.
- Evidence for a Narrower Interpretation: A party could argue that the term is defined by the specific embodiments shown in the patent's figures, which depict a particular rounded-rectangular shape, potentially limiting the term to housings of that general configuration. (’794 Patent, Figs. 1, 2A).
The Term: "longitudinal length"
Context and Importance: The infringement allegation for both Accused Products relies on this dimension being less than 2.0 inches. Practitioners may focus on this term because its precise measurement methodology could be outcome-determinative.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent itself defines the term as "extending between the front wall and the rear end," suggesting a straightforward measurement along the axis of the prongs. (’794 Patent, col. 14:46-48).
- Evidence for a Narrower Interpretation: While the definition appears clear, a party might argue that protrusions or curved surfaces on the front or rear walls create ambiguity, or that the term should be interpreted in light of the specific embodiments shown in the patent's drawings. (’794 Patent, Fig. 1).
VI. Other Allegations
- Indirect Infringement: The complaint does not allege specific facts to support a claim for indirect infringement. Count I is titled "DIRECT INFRINGEMENT OF U.S. PATENT NO. RE48,794 E". (Compl. p. 7).
- Willful Infringement: The complaint's prayer for relief seeks a determination that infringement has been willful, wanton, and deliberate. (Compl. p. 8, ¶C). However, the complaint does not plead specific facts, such as allegations of pre-suit knowledge of the patent, to support this claim.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction and measurement: How are the terms "outer profile" and "longitudinal length" to be construed, and do the Accused Products, when measured according to that construction, meet the precise dimensional limitations of less than 1.75 inches in width and less than 2.0 inches in length as required by Claim 1?
- A second key issue will be one of evidentiary proof and scope: Can the plaintiff factually demonstrate that the Accused Products cause "no interference" with adjacent receptacles "on all sides" and in "all available orientations"? The interpretation of this absolute-sounding language will be critical to the infringement case.
- A third question relates to the patent's reissue history: The complaint notes that Claim 1 was narrowed during reissue to add specific dimensional limits. (Compl. ¶14, fn. 1). This raises the question of whether the doctrine of intervening rights may apply, potentially limiting Voltstar's ability to recover damages for any infringement that occurred before the reissue date, even if infringement of the reissued claims is established.