Voltstar Tech Inc v. Shenzhen Huafengda Plastic Products Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Voltstar Technologies, Inc. (Illinois)
  • Defendant: Shenzhen Huafengda Plastic Products Co. Ltd. d/b/a Luoatip (China)
  • Plaintiff’s Counsel: Sriplaw, PLLC.
• Case Identification: 9:23-cv-80655, S.D. Fla., 04/14/2023
• Venue Allegations: Venue is alleged to be proper based on the defendant committing acts of infringement in the district, specifically through the sale of an accused product on Amazon.com which was purchased and shipped to Boca Raton, Florida.
• Core Dispute: Plaintiff alleges that Defendant’s USB-C power adapter infringes a reissue patent related to the design and construction of compact electrical chargers.
• Technical Context: The technology concerns small form-factor AC-to-DC power converters designed to avoid obstructing adjacent wall outlets while simplifying manufacturing.
• Key Procedural History: The patent-in-suit, RE48,794, is a reissue of U.S. Patent No. 9,024,581. The complaint notes that during reissue, Claim 1 was amended to narrow a dimensional limitation for the housing length from "equal to or less than 2.0 inches" to "less than 2.0 inches," and to add a new width limitation of "less than 1.75 inches." This prosecution history may focus the dispute on the precise dimensions of the accused product and the reasons for the amendment.

Case Timeline

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 describes issues with prior art electrical chargers, which were often bulky and could block adjacent receptacles in a wall outlet (Compl. ¶11; ’794 Patent, col. 1:42-57). Additionally, their manufacturing processes, such as insert molding of power blades and hand soldering of internal components, were described as expensive, time-consuming, and prone to error (’794 Patent, col. 1:58-col. 2:28).
• The Patented Solution: The invention claims a charger with a reduced package size achieved through a specific housing construction and internal component arrangement. The design utilizes separate, slidably mounted blades that connect to the internal circuitry via spring contacts, which is intended to obviate the need for insert molding and direct soldering to the blades (’794 Patent, Abstract; col. 4:37-55). This allows for a more compact and easily manufacturable design with specific dimensional limitations.
• Technical Importance: This approach sought to create smaller, less obtrusive, and more cost-effective power adapters for the growing market of portable electronic devices (Compl. ¶11; ’794 Patent, col. 2:41-48).

Key Claims at a Glance

• The complaint asserts independent Claim 1 (Compl. ¶23).
• Essential elements of independent Claim 1 include:
  • A charger plug for converting 120V input to DC output, connectable to a device via a power cord.
  • 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.
  • The housing being sized with a "longitudinal length... 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" when a "like charger plug" is mounted in any orientation in other receptacles of a power source.
• The complaint does not explicitly reserve the right to assert dependent claims, but infringement is alleged for "at least one of the claim" of the patent (Compl. ¶19).

III. The Accused Instrumentality

Product Identification

The "LUOATIP 20 W USB C Power Adapter" ("Power Adapter") (Compl. ¶14).

Functionality and Market Context

• The complaint alleges the Power Adapter is a charger that connects an AC power source to a DC-powered device, such as a mobile phone (Compl. ¶15).
• Its key accused functionality is its "reduced plug-size," which allegedly allows it to be plugged into a wall outlet without blocking or interfering with the use of adjacent outlets (Compl. ¶16).
• The complaint provides an image of the accused Power Adapter, showing a compact, white, rectangular charger with two prongs and a USB-C port (Compl. p. 5).
• The complaint alleges the Power Adapter has a longitudinal length of approximately 1.371 inches and a width of approximately 1.194 inches (Compl. ¶20).

IV. Analysis of Infringement Allegations

The complaint does not include the referenced claim chart exhibit (Compl. ¶18, ¶23). The following analysis is based on the narrative allegations in the complaint.

RE48,794 E Infringement Allegations

Identified Points of Contention

• Scope Questions: A central question may be the interpretation of "longitudinal length" and "width of the housing outer profile." The parties may dispute the precise measurement points on the accused product that correspond to these claim limitations.
• Technical Questions: The complaint's infringement theory focuses heavily on the external dimensions and non-interference function. A key factual question will be whether the accused product's internal construction meets the "first and second separate blade members" limitation, as the complaint provides no evidence on this point. Discovery into the internal design of the LUOATIP adapter will be critical.

V. Key Claim Terms for Construction

• The Term: "longitudinal length" and "width of the housing outer profile"
• Context and Importance: These dimensional terms are central to the infringement allegations and were the subject of a narrowing amendment during the reissue proceeding (Compl. ¶12-13, ¶20). The outcome of the case may depend on how these dimensions are defined and measured on the accused product. Practitioners may focus on these terms because the reissue history suggests a deliberate surrender of broader scope, potentially creating a significant boundary for the claim.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification provides examples of dimensions, stating the width is "preferably approximately 1.35 inches" and the length is "preferably approximately 1.75 inches" (’794 Patent, col. 14:4-8). A party could argue that the use of "preferably" and "approximately" suggests the terms should not be interpreted with excessive rigidity, so long as they fall under the hard limits of 1.75 and 2.0 inches respectively.
  • Evidence for a Narrower Interpretation: The claim language itself provides absolute upper limits ("less than 2.0 inches," "less than 1.75 inches"). A party could argue that the patentee, by amending the claims in reissue to add these specific numerical limits, defined the invention by these precise boundaries. Figures such as Fig. 15, which depicts dimensions "150" (vertical dimension/height) and "152" (longitudinal length), could be used to argue for specific measurement conventions for the claimed "length" and "width" (’794 Patent, Fig. 15).

VI. Other Allegations

• Indirect Infringement: The complaint does not contain a count for indirect infringement.
• Willful Infringement: The prayer for relief requests a determination that Defendant's infringement was "willful, wanton, and deliberate" and seeks treble damages (Compl., Prayer for Relief ¶C). However, the complaint body does not allege specific facts to support this claim, such as pre-suit notice or knowledge of the patent.

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

1. A core issue will be one of claim scope and measurement: How are the critical terms "longitudinal length" and "width of the housing outer profile," which were narrowed during reissue, to be construed and measured on the accused product? The case may turn on the precise methodology for these measurements.
2. A key evidentiary question will be one of structural correspondence: Does the accused LUOATIP adapter, beyond its external dimensions, incorporate the internal structure required by Claim 1, specifically the "first and second separate blade members"? The complaint is silent on the internal design, and this will be a primary focus for discovery and expert analysis.