DCT
1:23-cv-24517
Socket Solutions LLC v. Import Global LLC
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Socket Solutions, LLC (Texas)
- Defendant: Import Global, LLC (Florida)
- Plaintiff’s Counsel: Smith Gambrell & Russell LLP
- Case Identification: 1:23-cv-24517, S.D. Fla., 02/12/2024
- Venue Allegations: Venue is asserted as proper in the Southern District of Florida on the basis that Defendant Import Global, LLC resides in the district.
- Core Dispute: Plaintiff alleges that Defendant’s "Neat Socket" electrical wall outlet covers infringe a patent related to low-profile, functional outlet covers that conceal the wall socket.
- Technical Context: The technology concerns electrical outlet covers designed to be extremely thin, allowing furniture and other objects to be placed nearly flush against a wall while still providing access to power via an integrated extension cord.
- Key Procedural History: This First Amended Complaint alleges patent infringement alongside a Lanham Act claim for false advertising, asserting the accused products are misrepresented as safe. The complaint alleges that Defendant had pre-suit knowledge of the patent, acquired samples of Plaintiff's patented product, and intentionally copied the product and its packaging, which may form the basis for the willfulness and inducement claims.
Case Timeline
| Date | Event |
|---|---|
| 2016-04-14 | ’080 Patent Priority Date |
| 2016-11-29 | U.S. Patent No. 9,509,080 Issued |
| 2024-02-12 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,509,080 - "Functional Indoor Electrical Wall Outlet Cover," issued November 29, 2016
The Invention Explained
- Problem Addressed: The patent's background section identifies the problem that conventional electrical plugs extend several inches from a wall, which "wastes space" by preventing furniture from being positioned close to the wall and is "generally unattractive." It also notes that exposed outlets can pose a safety hazard to children. (’080 Patent, col. 1:20-38).
- The Patented Solution: The invention is a thin cover that plugs into and fully conceals a standard wall outlet. The core innovation is a functional electrical plug with connection pins "bent at approximately ninety degree angle," which minimizes the device's protrusion from the wall. (’080 Patent, Abstract; col. 2:15-20). An electrical cord extends from this low-profile plug to one or more receptacles, allowing continued use of the outlet's power while hiding the socket itself. (’080 Patent, col. 1:54-63).
- Technical Importance: This design provides an aesthetic and functional solution by hiding unsightly outlets and enabling furniture to be placed nearly flush against the wall, a feature of practical importance in interior design and space management. (’080 Patent, col. 1:49-54).
Key Claims at a Glance
- The complaint asserts independent claim 19. (Compl. ¶33).
- The essential elements of independent claim 19 are:
- An apparatus for hiding a standard indoor electrical wall outlet comprising a cover with a frontplate and a backplate.
- The backplate includes at least one set of electrical prongs (hot, neutral, optional ground) to plug into a first receptacle of the wall outlet.
- An electrical cord extends from the cover, connected to the prongs at its proximal end and having at least one receptacle at its distal end.
- The internal electrical pins connecting the prongs to the cord are positioned to minimize the distance between the frontplate and backplate.
- A key dimensional limitation: "the height of the hot pin, neutral pin, and any ground wire is approximately the same or less than the thickness of the cord."
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
- The accused products are the "Neat Socket" electrical wall outlet covers sold by Defendant Import Global, LLC. (Compl. ¶¶ 4, 8).
Functionality and Market Context
- The complaint alleges the accused "Neat Socket" is an "ultra-thin outlet cover/power strip" that plugs into and conceals a standard wall outlet, providing power through an attached extension cord terminating in a power strip with multiple receptacles. (Compl. ¶¶ 3, 15-16). The complaint includes a side-by-side visual comparison, alleging the accused product is "designed to look essentially identical" to the Plaintiff's "Sleek Socket®" product. (Compl. ¶29, p. 5). This image shows two very similar products: a flat white plate that covers a duplex outlet, with a thin white cord extending downwards from its base. (Compl. p. 5). Another visual shows the accused product's power strip has three "NEMA" outlets and two USB-A ports. (Compl. ¶41, p. 7).
- The complaint alleges the accused products are sold on Amazon.com and "compete directly with the patented Sleek Socket® products." (Compl. ¶¶ 27, 34).
IV. Analysis of Infringement Allegations
'080 Patent Infringement Allegations
| Claim Element (from Independent Claim 19) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a. a cover comprising: (i) a frontplate; and (ii) a backplate comprising at least one set of electrical prongs including a hot prong, a neutral prong, and optionally a ground prong, positioned to correspond to a first receptacle of the wall outlet; and | The accused "Neat Socket" is an outlet cover that plugs into a wall outlet and comprises a front-facing plate and a back structure with electrical prongs. | ¶¶3-4, 33 | col. 3:36-48 |
| b. an electrical cord extending from the backplate, or the cover, said cord comprising at the cord's proximal end: at least one hot pin, at least one neutral pin and optionally a ground wire positioned on or fastened or attached to the backplate of the cover in such manner as to minimize distance between the front plate and the backplate, ... and comprising at the cord's distal end at least one receptacle | The accused product has an electrical cord that extends from the cover to a power strip containing three NEMA outlets and two USB ports, which function as receptacles. A visual in the complaint depicts this power strip. | ¶¶3, 41-42, p. 7 | col. 5:6-10 |
| and wherein the height of the hot pin, neutral pin, and any ground wire is approximately the same or less than the thickness of the cord. | The complaint alleges the accused product is "ultra-thin" and infringes every limitation of claim 19. This implies an assertion that the internal pins meet this dimensional requirement, though no specific measurements or internal views of the accused product are provided to directly support this element. The complaint does specify the accused product uses a "16AWG" cord. | ¶¶16, 33, 42 | col. 4:7-14 |
- Identified Points of Contention:
- Technical Questions: A primary technical question is whether the accused product's internal construction meets the final limitation of claim 19. The complaint alleges infringement of all limitations but provides only external photographs. Discovery will be needed to determine if the height of the internal pins connecting the prongs to the 16AWG cord is, in fact, "approximately the same or less than the thickness of the cord." The plaintiff's ability to prove this fact will be critical to its infringement case.
V. Key Claim Terms for Construction
- The Term: "approximately the same or less than"
- Context and Importance: This term is central to the patent's claim of an "ultra-thin" design and is the most specific technical limitation in the asserted claim. The infringement case may turn on whether the internal dimensions of the accused product fall within the scope of this phrase. Practitioners may focus on this term because it introduces a degree of ambiguity into a critical dimensional relationship.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The use of the word "approximately" inherently suggests that the measurement does not have to be exact, allowing for some tolerance or variation. The patent does not define a specific numerical range for this approximation, which a party could argue supports a more flexible reading.
- Evidence for a Narrower Interpretation: The patent repeatedly emphasizes the objective of creating a thin, low-profile device to "avoid adding any significant bulk to the wall outlet." (’080 Patent, col. 2:15-20, col. 1:49-54). A party could argue that this stated purpose requires "approximately" to be construed narrowly to mean a very small, functionally insignificant deviation from being "the same or less than" the cord's thickness.
VI. Other Allegations
- Indirect Infringement: Count II of the complaint alleges induced infringement under 35 U.S.C. § 271(b). The complaint asserts that Defendant encourages its customers to use the accused products in an infringing manner. (Compl. ¶61). The allegations of knowledge are based on Defendant's alleged acquisition of Plaintiff's "Sleek Socket®" products, which bear patent markings, prior to selling the accused "Neat Socket." (Compl. ¶¶ 64, 66).
- Willful Infringement: The complaint alleges that Defendant's infringement has been willful, specifically pointing to "efforts to copy the patented Sleek Socket® products, product marketing, and packaging." (Compl. ¶70). This allegation of deliberate copying is presented as the basis for seeking enhanced damages. (Compl. ¶12(e)).
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this dispute may hinge on the answers to two central questions:
A key evidentiary question will be one of internal construction: Can Plaintiff produce evidence from discovery showing that the accused "Neat Socket" product's internal pin-and-cord assembly meets the specific dimensional limitation of claim 19, which requires the conductive pin height to be "approximately the same or less than the thickness of the cord"? The current allegations are based on external product similarities.
A core issue for willfulness and inducement will be one of knowledge and intent: What factual evidence will support the complaint's allegations, made upon "information and belief," that the Defendant knew of the '080 patent, deliberately copied the Plaintiff's patented product, and intended for its customers to use the product in an infringing manner?