Voltstar Tech Inc v. Airport Retail Management LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Voltstar Technologies, Inc. (Illinois)
  • Defendant: Airport Retail Management LLC (Georgia)
  • Plaintiff’s Counsel: Sriplaw, PLLC.
• Case Identification: 1:23-cv-05043, N.D. Ga., 11/01/2023
• Venue Allegations: Venue is asserted based on the defendant allegedly committing acts of infringement and having a regular and established place of business in the Northern District of Georgia.
• Core Dispute: Plaintiff alleges that Defendant’s wall chargers infringe a patent related to the specific dimensional and functional characteristics of compact power adapters.
• Technical Context: The technology concerns the design of small-form-factor AC-to-DC power adapters, commonly used for charging mobile electronic devices, where the physical size is optimized to prevent obstruction of adjacent electrical 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 a key dimensional limitation in Claim 1, changing the required longitudinal length from "equal to or less than 2.0 inches" to "less than 2.0 inches," a narrowing amendment that may focus the infringement analysis on precise measurements.

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 AC-to-DC power converters (chargers) that are often bulky. This bulk can cause the charger to block adjacent receptacles on a power outlet or power strip, and their length may cause them to be unstable or unsightly when plugged in, particularly behind furniture (RE48,794 E Patent, col. 1:42-58). Manufacturing methods like insert molding for the electrical blades were also identified as being costly and time-consuming (RE48,794 E Patent, col. 1:62-65, col. 2:1-11).
• The Patented Solution: The invention claims to solve these problems through a charger with a specific housing construction and dimensional profile. The design uses slidably mounted blades that connect to the internal circuitry via spring contacts, which obviates the need for insert molding and soldering (RE48,794 E Patent, Abstract). The key aspect is the charger's compact outer profile, which is defined by specific length and width dimensions, ensuring it does not physically interfere with the use of adjacent outlets (RE48,794 E Patent, col. 13:45-54).
• Technical Importance: This approach addresses a practical usability problem for consumers by creating a charger that can be used in crowded power strips or outlets without sacrificing access to neighboring receptacles (RE48,794 E Patent, col. 12:10-15).

Key Claims at a Glance

• The complaint asserts at least independent Claim 1 (Compl. ¶30).
• 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.
  • A DC connector with an aperture to receive a power cord.
  • The housing being sized so that its longitudinal length is "less than 2.0 inches" and its width is "less than 1.75 inches."
  • The housing's "outer profile having 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 other claims, but infringement is alleged for "at least one claim" (Compl. ¶29).

III. The Accused Instrumentality

Product Identification

• The complaint identifies the "Ventev 12W Wall Charger" and the "Ventev 30W GaN Mini Wall Charger + Cable" as the accused instrumentalities (Compl. ¶14, ¶21).

Functionality and Market Context

• The complaint alleges both products are chargers that connect between an AC power source, like a wall outlet, and a mobile device to provide DC charging power (Compl. ¶15, ¶22).
• A central feature alleged is their "reduced plug-size," which purportedly ensures that when plugged into an outlet, the chargers do not "block or interfere with the use of adjacent outlets" (Compl. ¶16, ¶23). An image provided in the complaint shows the Ventev 12W product removed from its packaging, displaying its compact, two-prong form factor (Compl. p. 6). Another image depicts the Ventev 30W product, which has a similar compact design (Compl. p. 8).
• The complaint provides specific measurements for the accused products, alleging the Ventev 12W has a length of approximately 1.383 inches and a width of 1.373 inches, and the Ventev 30W has a length of 1.543 inches and a width of 1.266 inches (Compl. ¶20, ¶27).

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits that were not filed with the complaint; however, the narrative allegations in the complaint allow for a summary of the infringement theory for Claim 1.

RE48,794 E Infringement Allegations

• Identified Points of Contention:
  • Factual Question: The core of the dispute appears to be factual: do the accused products, as sold, consistently have the precise physical dimensions alleged in the complaint? The infringement case for the dimensional limitations rests on these measurements being accurate and falling "less than" the claimed values.
  • Scope Question: How will the functional limitation "no interference with an adjacent receptacle" be interpreted? The parties may dispute what constitutes "interference" and whether this limitation is met across all standard outlet configurations as required by the claim. The complaint’s allegations on this point are stated in a conclusory manner.

V. Key Claim Terms for Construction

• The Term: "outer profile having no interference with an adjacent receptacle"
• Context and Importance: This term is critical because it moves beyond simple dimensional requirements and introduces a functional performance standard. The definition of "interference" and the scope of "adjacent receptacle" will be central to determining infringement. Practitioners may focus on this term because it is less objective than a numeric dimension and may be susceptible to arguments of indefiniteness or require extrinsic evidence (e.g., industry standards for outlet spacing like NEMA) to interpret.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification broadly discusses the problem of chargers that "block or interfere with the use of adjacent outlets" (RE48,794 E Patent, col. 11:10-12), suggesting the term should be given its plain and ordinary meaning related to physical obstruction.
  • Evidence for a Narrower Interpretation: The claim language requires this condition to be met "on all sides of the first receptacle when a like charger plug is mounted in all available orientations in any of the other receptacles" (RE48,794 E Patent, col. 13:51-54). A defendant might argue this creates a very high and specific standard that requires testing against numerous outlet and plug configurations, potentially limiting the claim's scope to an idealized scenario.

VI. Other Allegations

• Indirect Infringement: The complaint does not contain specific allegations or a separate count for indirect infringement. The allegations focus on direct infringement by Defendant's acts of "making, uses, offers for sale and sells" the accused products (Compl. ¶14, ¶21).
• Willful Infringement: The complaint includes a request for a determination that infringement has been "willful, wanton, and deliberate" and seeks enhanced damages (Compl. p. 11, ¶C). The complaint does not, however, plead specific facts to support a claim of pre- or post-suit knowledge of the patent or a risk of infringement.

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

This dispute appears to center on straightforward, fact-intensive questions of direct infringement. The key questions for the court will likely be:

1. A core issue will be one of factual verification: Do the accused Ventev chargers, as manufactured and sold by the defendant, possess a "longitudinal length" and "width" that are, in fact, less than the specific 2.0-inch and 1.75-inch thresholds recited in Claim 1?
2. A secondary issue will be one of functional scope: What is the proper construction of the term "no interference with an adjacent receptacle"? The resolution will depend on whether this functional language is interpreted as a simple consequence of meeting the dimensional limitations or as an independent, and potentially more demanding, requirement for non-obstruction across a variety of outlet configurations.