Voltstar Tech Inc v. Craig Electronics LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Voltstar Technologies, Inc. (Illinois)
  • Defendant: Craig Electronics LLC and Newtech Electronic Industries LLC (Florida)
  • Plaintiff’s Counsel: Sriplaw PLLC
• Case Identification: 1:23-cv-22284, S.D. Fla., 06/20/2023
• Venue Allegations: Venue is asserted on the basis that Defendants have committed acts of infringement in the district and are subject to personal jurisdiction there.
• Core Dispute: Plaintiff alleges that Defendants’ wall charger products infringe a patent related to the compact size and physical configuration of power adapters.
• Technical Context: The technology concerns the design of small-form-factor AC-to-DC power converters, commonly used for charging portable electronic devices, where physical size is a key feature for user convenience and compatibility with crowded power outlets.
• Key Procedural History: The patent-in-suit, RE48,794 E, is a reissue of U.S. Patent No. 9,024,581. The reissue process amended Claim 1 by narrowing a length dimension and adding a new width dimension. The complaint asserts that the reissued claims are "substantially identical" to the original claims, which may be relevant to the calculation of past damages and the potential for intervening rights defenses under 35 U.S.C. § 252.

Case Timeline

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 describes issues with prior art power adapter plugs, noting they are often bulky, which can block adjacent electrical outlets, and protrude excessively from the wall, making them susceptible to being struck or dislodged (RE48,794 E Patent, col. 1:42-59). The patent also identifies the high cost and complexity of manufacturing, particularly the processes of "insert molding" the electrical blades and hand-soldering internal connections, which are time-consuming and can introduce defects (’794 Patent, col. 2:1-31).
• The Patented Solution: The invention claims to solve these problems through a charger with specific, compact dimensional limitations and a housing that allows it to be plugged into a standard wall outlet without obstructing adjacent receptacles (’794 Patent, col. 13:46-54). To address manufacturing complexity, the patent discloses a design using slidably mounted blades and solder-less spring contacts that connect the blades to the internal printed circuit board (PCB), simplifying assembly and reducing cost (’794 Patent, col. 3:42-56).
• Technical Importance: The described solution sought to provide a charger that was not only smaller and more convenient for users in crowded spaces but also cheaper and more reliable to manufacture by eliminating common failure points in the assembly process (’794 Patent, col. 1:15-18).

Key Claims at a Glance

• The complaint asserts infringement of at least Claim 1 (Compl. ¶25).
• Independent Claim 1 requires:
  • A charger plug for converting 120V input power to DC output power.
  • A housing containing first and second separate blade members with prong portions that extend from a front wall of the housing.
  • A DC connector for providing power to a rechargeable device via a power cord.
  • The housing being sized with a longitudinal length of less than 2.0 inches and a width of the housing outer profile being less than 1.75 inches.
  • The housing's outer profile having "no interference with an adjacent receptacle" of a power source.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The "Newtech Wall Charger with Micro USB Cable" (the "Newtech Wall Charger") (Compl. ¶16).

Functionality and Market Context

• The complaint alleges the Newtech Wall Charger is an AC-to-DC power adapter used to charge devices like mobile phones (Compl. ¶17). Its key accused functionality relates to its physical dimensions and shape. The complaint alleges the charger employs a "reduced plug-size" design so that it "does not block or interfere with the use of adjacent outlets" when plugged into a source of AC power (Compl. ¶18). The complaint includes an image of the accused product. (Compl. p. 5). This visual shows a white, rectangular wall charger with two parallel prongs. (Compl. p. 5, Image). Additionally, the complaint alleges the charger's size and shape permit easy insertion and removal of a power cord without removing the charger from the wall outlet (Compl. ¶19).

IV. Analysis of Infringement Allegations

RE48,794 E Infringement Allegations

• Identified Points of Contention:
  • Technical Question: The complaint provides specific length and width measurements for the accused product (Compl. ¶22). A central factual question will be whether these measurements are accurate and how "longitudinal length" and "width of the housing outer profile" are properly measured on the accused device's physical body.
  • Scope Question: The claim requires "no interference with an adjacent receptacle." This functional language raises the question of what constitutes "interference." A dispute may arise over whether this limitation requires usability of any adjacent outlet in any standard configuration, or if there is a more specific technical meaning defined by the patent's specification.

V. Key Claim Terms for Construction

• The Term: "outer profile having no interference with an adjacent receptacle"
• Context and Importance: This term is a functional limitation that defines a key performance characteristic of the claimed invention. Its construction will be critical because infringement hinges on whether the accused product's physical shape meets this "no interference" standard. Practitioners may focus on this term to dispute whether it is sufficiently definite under 35 U.S.C. § 112 and, if it is definite, what objective boundaries define its scope.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The background section broadly states that a goal is to reduce plug dimensions so "the plug itself provides little or no interference with use of an adjacent receptacle" (’794 Patent, col. 1:46-49). A party might argue this supports a common-sense interpretation based on the ordinary use of standard NEMA outlets.
  • Evidence for a Narrower Interpretation: The patent does not appear to provide an explicit definition of "no interference." A party could argue that the term must be limited to the specific embodiments and dimensions disclosed, such as the exemplary dimensions provided in the specification: a lateral width less than 1.75 inches and a height less than 1.0 inches (’794 Patent, col. 14:4-10).

VI. Other Allegations

• Willful Infringement: The complaint includes a prayer for a determination that infringement has been "willful, wanton, and deliberate" and seeks treble damages (Compl., Prayer for Relief ¶C). However, the complaint pleads no specific facts to support an allegation of pre-suit knowledge of the patent or egregious conduct, which are typically required to substantiate a claim for willful infringement.

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

1. Definitional Scope: A central issue will be the construction of the functional limitation "outer profile having no interference with an adjacent receptacle." The case may turn on whether the court finds this term sufficiently definite and, if so, what objective standard or test will be used to measure "interference."

2. Factual Verification: The infringement case, as pleaded, relies heavily on specific physical measurements. A key evidentiary question will be whether discovery and expert analysis confirm that the accused "Newtech Wall Charger" has a "longitudinal length" and "width" that fall within the precise numerical limits recited in Claim 1.

3. Impact of Reissue: A third question relates to damages and the patent’s reissue history. Defendants may argue that the addition of the width limitation ("less than 1.75 inches") during reissue created new, narrowed claims, potentially entitling them to absolute or equitable intervening rights for any conduct that occurred before the reissue patent was granted. Plaintiff’s assertion that the claims are "substantially identical" (Compl. ¶15) will be a critical legal issue for the court to resolve.