DCT

1:25-cv-23736

Voltstar Tech Inc v. Xiamen Ouruoruite E Commerce Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-23736, S.D. Fla., 08/19/2025
  • Venue Allegations: Plaintiff alleges venue is proper because the defendant is not a resident of the United States and has committed acts of infringement in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s wall chargers for electronic devices infringe a reissue patent related to compact charger plug design and packaging.
  • Technical Context: The technology concerns the mechanical and electrical design of AC-to-DC power adapters, focusing on size reduction to prevent obstruction of adjacent wall outlets.
  • 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 narrow the claimed dimensions of the charger housing, specifically changing a length limitation from "equal to or less than 2.0 inches" to "less than 2.0 inches" and adding a width limitation of "less than 1.75 inches." This amendment may be presented by the plaintiff as evidence of the patent’s validity over the prior art.

Case Timeline

Date Event
2008-05-21 ’794 Patent Priority Date (Original Application Filing)
2015-05-05 Original U.S. Patent No. 9,024,581 Issues
2021-10-26 Reissue Patent No. RE48,794 E Issues
2025-08-19 Complaint Filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Reissue Patent No. RE48,794 E - "Charger Plug With Improved Package"

The Invention Explained

  • Problem Addressed: The patent’s background section describes issues with prior art electrical chargers, which are often bulky, blocking adjacent power outlets, or too long to fit in outlets behind furniture ('794 Patent, col. 1:42-56). The patent also identifies manufacturing inefficiencies, such as the high cost and time required for "insert molding" blades into the plastic housing and the space consumed by soldering wires to connect the blades to internal circuitry ('794 Patent, col. 2:1-41).
  • The Patented Solution: The invention is a compact charger plug design that uses slidably mounted blades and internal spring contacts to establish an electrical connection with the internal circuit board ('794 Patent, Abstract). This construction method is described as obviating the need for insert molding and soldering, which allows for a smaller, more cost-effective package that does not interfere with adjacent outlets ('794 Patent, col. 3:9-12; col. 4:4-18).
  • Technical Importance: The design addresses a persistent consumer demand for smaller, less obtrusive, and more portable power adapters for the growing market of electronic devices ('794 Patent, col. 1:12-19).

Key Claims at a Glance

  • The complaint asserts infringement of at least Claim 1 of the ’794 Patent (Compl. ¶29).
  • The essential elements of independent Claim 1 are:
    • A charger plug for converting 120V input power to DC output power for a rechargeable electronic device.
    • A housing containing first and second separate blade members with prong portions that extend from a front wall.
    • A DC connector with an aperture to receive a power cord plug end.
    • The housing being sized with a longitudinal length of less than 2.0 inches and a width of the housing outer profile of less than 1.75 inches.
    • The housing's outer profile having no interference with an adjacent receptacle when plugged in.
  • The complaint does not explicitly reserve the right to assert other claims, but infringement is alleged generally for "at least one of the claims" (Compl. ¶26).

III. The Accused Instrumentality

Product Identification

The complaint identifies a range of "SISSFO-US" branded charger products sold on Amazon.com, including "USB Charging Block 10W Power Adapter," "Fast Charger with 6Ft USB Type-C&Micro USB Cable," and numerous other wall chargers for tablets and e-readers (Compl. ¶21).

Functionality and Market Context

The accused products are described as chargers that connect between an AC power source, like a wall outlet, and a device with a rechargeable battery (Compl. ¶22). The complaint alleges the key infringing functionality is their "reduced plug-size" and compact shape, which ensures they "do not block or interfere with the use of adjacent outlets" (Compl. ¶23). The products are marketed for use with popular consumer electronics such as Amazon Fire tablets and Kindle e-readers (Compl. ¶21).

IV. Analysis of Infringement Allegations

The complaint references a claim chart in Exhibit 3 purporting to show infringement of Claim 1, but the exhibit was not included with the filed complaint (Compl. ¶25, ¶29). The narrative allegations state that the accused chargers practice the claimed invention by being AC-to-DC converters with a specific compact size and shape (Compl. ¶22, ¶24). The core of the infringement theory rests on the physical dimensions of the accused products. Specifically, the complaint alleges the accused chargers have a "reduced plug-size" such that they do "not block or interfere with the use of adjacent outlets" when plugged into a source of AC power (Compl. ¶23). This allegation mirrors the functional and dimensional limitations central to Claim 1 of the ’794 Patent.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

  • The Term: "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"
  • Context and Importance: This dimensional limitation is the central feature of independent Claim 1 and was the subject of a narrowing amendment during the reissue process (Compl. ¶12, fn. 1). The infringement analysis will depend entirely on how these dimensions are measured on the accused products and whether they fall within the claimed ranges. Practitioners may focus on this term because its construction will likely be dispositive of infringement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language recites "a width of the housing outer profile," which could be argued to mean the width at any point along the profile, not necessarily the maximum width, though this interpretation may be contested. The patent's general description focuses on the overall goal of creating a compact package without specifying a rigid measurement protocol in the summary of the invention ('794 Patent, col. 1:16-19).
    • Evidence for a Narrower Interpretation: The specification provides exemplary dimensions for a preferred embodiment: "the lateral width of the plug housing 14 is less than 1.75 inches, and preferably approximately 1.35 inches; the overall longitudinal length of the housing 14 is less than 2.0 inches, and preferably approximately 1.75 inches" ('794 Patent, col. 14:3-8). A defendant may argue that these specific examples guide how the "longitudinal length" and "width" should be measured, potentially excluding certain product shapes or features from the claim's scope. The figures, such as Figure 1, illustrate a specific embodiment whose proportions could be used to argue for a particular method of measurement.

VI. Other Allegations

  • Willful Infringement: The complaint alleges that the defendant had "actual or constructive knowledge" of the plaintiff's rights and requests a finding of willful infringement in its prayer for relief (Compl. ¶20; Prayer for Relief ¶C). However, the complaint does not plead specific facts to support pre-suit knowledge of the patent-in-suit.

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

  • A core issue will be one of metrology and claim scope: How are the "longitudinal length" and "width of the housing outer profile" to be measured on the accused products? The case will likely require a detailed claim construction to define the precise boundaries of these critical dimensional limitations, which were narrowed during patent reissue.
  • A key evidentiary question will be one of factual proof: Assuming a claim construction is adopted, what evidence will Plaintiff present to demonstrate that Defendant's various accused charger models in fact meet the specific dimensional requirements of "less than 2.0 inches" in length and "less than 1.75 inches" in width as required by Claim 1?