DCT
1:25-cv-23532
Voltstar Tech Inc v. Xiamen Weiyu Electronic Commerce Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Voltstar Technologies, Inc. (Illinois)
- Defendant: Xiamen Weiyu Electronic Commerce Co., Ltd, a/k/a Toniwa (China)
- Plaintiff’s Counsel: Sriplaw PLLC
- Case Identification: 1:25-cv-23532, S.D. Fla., 08/06/2025
- Venue Allegations: Venue is asserted on the basis that the defendant is a foreign resident not resident in the United States and has committed acts of infringement within the district.
- Core Dispute: Plaintiff alleges that Defendant’s "Toniwa" brand wall chargers infringe a reissue patent directed to the compact size and non-interfering shape of power adapters.
- Technical Context: The technology concerns the design of small AC-to-DC power adapters (chargers) intended to be compact enough not to obstruct the use of adjacent electrical outlets.
- Key Procedural History: The asserted patent, U.S. Reissue Patent No. RE48,794 E, is a reissue of U.S. Patent No. 9,024,581. The complaint notes that the reissue process amended the original patent's Claim 1 to add a specific width limitation, which may have implications for claim scope and potential intervening rights. The complaint also mentions that the Plaintiff has entered into licensing agreements with unspecified third parties.
Case Timeline
| Date | Event |
|---|---|
| 2008-05-21 | Earliest Priority Date (Application for original '581 Patent filed) |
| 2015-05-05 | U.S. Patent No. 9,024,581 Issued |
| 2018-12-04 | Reissue Application for '794 Patent Filed |
| 2021-10-26 | U.S. Reissue Patent No. RE48,794 E Issued |
| 2025-08-06 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Reissue Patent No. RE48,794 E - "Charger Plug With Improved Package" (Issued Oct. 26, 2021)
The Invention Explained
- Problem Addressed: The patent describes issues with prior art power adapter plugs, noting they are often bulky and can block adjacent receptacles in a wall outlet (RE48,794 E Patent, col. 1:42-49). It also identifies the high cost and complexity of manufacturing these plugs, particularly the process of "insert molding" the electrical blades into the plastic housing and the space required for internal soldering and wiring (RE48,794 E Patent, col. 2:1-41).
- The Patented Solution: The invention discloses a charger plug with a housing specifically dimensioned to be compact. A key aspect of the design is to ensure the plug's physical footprint does not impede access to adjacent outlets (RE48,794 E Patent, col. 13:52-59). The specification also describes an improved internal assembly method using slidably mounted blades and solder-less spring contacts to connect to the internal circuit board, which contributes to the reduced size and simplified manufacturing (RE48,794 E Patent, col. 3:40-56).
- Technical Importance: The design aims to satisfy consumer demand for smaller, more convenient electronic accessories while also reducing manufacturing costs and complexity for producers (RE48,794 E Patent, col. 1:12-19).
Key Claims at a Glance
- The complaint asserts at least Claim 1 (Compl. ¶29).
- Independent Claim 1 requires:
- A charger plug with a housing and first and second separate blade members secured within it.
- A DC connector with an aperture to receive a power cord plug.
- The housing defines a face area, an outer profile, and a rear end.
- The housing is sized to have a longitudinal length of less than 2.0 inches and a width of the outer profile of less than 1.75 inches.
- The outer profile must have "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 does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
- Defendant’s "Toniwa" brand charger products, identified by a list of Amazon Standard Identification Numbers (ASINs) (Compl. ¶21).
Functionality and Market Context
- The accused products are alleged to be AC-to-DC power adapters sold in the United States via e-commerce platforms like Amazon.com (Compl. ¶14, ¶18). The complaint alleges these chargers are designed to be connected between a wall outlet and an electronic device for charging (Compl. ¶22). A central allegation is that the chargers "employ a reduced plug-size" such that they do not block or interfere with the use of adjacent outlets (Compl. ¶23). The complaint includes a table listing the accused products, their brand, ASIN, and product names, such as "Rapid Charger Compatible Samsung Galaxy Tab" and "USB C Charger Compatible with Kindle Paperwhite" (Compl. p. 5). This table provides a non-exhaustive list of the instrumentalities at issue (Compl. ¶21, pp. 5-7).
IV. Analysis of Infringement Allegations
The complaint alleges infringement of at least Claim 1 of the '794 Patent and references an attached claim chart (Exhibit 3) that was not filed with the complaint (Compl. ¶25, ¶29). The following table summarizes the infringement theory based on the narrative allegations in the complaint.
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... | Defendant advertises the use of and sale of its chargers to be connected between a source of AC power, such as a wall outlet, and a device... | ¶22 | col. 13:17-24 |
| being sized so that the charger plug housing comprises a longitudinal length... less than 2.0 inches, a width of the housing outer profile being less than 1.75 inches... | The chargers distributed by Defendant employ a reduced plug-size charger plug... | ¶23 | col. 13:46-51 |
| the outer profile having no interference with an adjacent receptacle of the power source... | ...upon plugging the chargers into a source of AC power such as a wall outlet, the chargers do not block or interfere with the use of adjacent outlets. | ¶23 | col. 13:52-59 |
| a DC connector having an aperture adapted to removably receive a corresponding power cord plug end... | ...a power cord for the device to be charged may be easily inserted into and removed from the chargers while the charger is plugged into the source of AC power... | ¶24 | col. 13:30-35 |
- Identified Points of Contention:
- Evidentiary Questions: The complaint alleges the accused chargers have a "reduced plug-size" (Compl. ¶23) but does not provide specific measurements. A central question for discovery will be whether the accused products actually meet the precise dimensional limitations of Claim 1 (i.e., a length "less than 2.0 inches" and a width "less than 1.75 inches").
- Scope Questions: Claim 1 requires "no interference with an adjacent receptacle." The interpretation of what constitutes "interference" will be critical. This raises the question of whether any physical contact is prohibited, or if the term implies only contact that prevents the functional use of the adjacent outlet.
V. Key Claim Terms for Construction
The Term: "outer profile"
Context and Importance: The measurement of the "width of the housing outer profile" is a specific limitation in Claim 1. The definition of this term is therefore critical to determining literal infringement. Practitioners may focus on this term because its boundaries determine whether the accused products meet the "less than 1.75 inches" requirement.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Claim 1 defines the term functionally as being "defined by a perimeter of the front wall and defined by a plug body extending rearward from the front wall" (RE48,794 E Patent, col. 13:40-43). This language is not tied to a specific shape.
- Evidence for a Narrower Interpretation: The patent figures, such as Figure 1, depict a specific rounded rectangular shape. A party could argue that the term should be construed in light of these preferred embodiments.
The Term: "interference"
Context and Importance: This functional term is central to the non-obviousness argument and infringement analysis. Its meaning will define the performance standard the accused product must meet. The parties will likely dispute whether minor physical contact with an adjacent plug constitutes "interference" if that plug can still be inserted and function.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not provide a specific definition, which may support giving the term its plain and ordinary meaning, potentially allowing for incidental contact that does not prevent the use of an adjacent outlet.
- Evidence for a Narrower Interpretation: The patent states the goal is that "the plug itself provides little or no interference with use of an adjacent receptacle" (RE48,794 E Patent, col. 1:47-49). Plaintiff may argue this language supports a construction where any physical contact that makes use of the adjacent outlet more difficult constitutes "interference."
VI. Other Allegations
- Willful Infringement: The complaint alleges that Defendant had "actual or constructive knowledge of Plaintiff’s intellectual property rights" (Compl. ¶20) and seeks a determination of willful infringement in its prayer for relief (Prayer for Relief, ¶C). The complaint does not, however, plead specific facts supporting pre-suit knowledge, such as a cease-and-desist letter or prior litigation.
VII. Analyst’s Conclusion: Key Questions for the Case
- A primary issue will be one of proof and evidence: Can the Plaintiff produce evidence, such as physical measurements, demonstrating that the accused Toniwa chargers meet the specific length and width dimensions recited in Claim 1 of the '794 patent? The complaint makes the allegation but does not provide this data.
- The case will likely involve a significant dispute over claim construction: The court's interpretation of the terms "outer profile" and "interference" will be dispositive. How these terms are defined will determine whether the accused products' physical shape and size fall within the scope of the patent's claims.
- A third question may concern the impact of reissue: The complaint notes that the asserted claim was narrowed during reissue to add a width limitation (Compl. ¶12). This raises the possibility of an intervening rights defense for any accused products sold before the reissue date (October 26, 2021), should discovery reveal that to be the case.