Voltstar Tech Inc v. InMotion Entertainment Group LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Voltstar Technologies, Inc. (Illinois)
  • Defendant: InMotion Entertainment Group, LLC (Delaware)
  • Plaintiff’s Counsel: Sriplaw, PLLC.
• Case Identification: 1:23-cv-05045, N.D. Ga., 11/01/2023
• Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Georgia because Defendant has a regular and established place of business in the district and has committed alleged acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s Micro USB Charger infringes a reissue patent related to the compact physical design of AC-to-DC power converters.
• Technical Context: The technology concerns the mechanical design and packaging of small, wall-pluggable power adapters used for charging portable electronic devices, a ubiquitous consumer product category.
• Key Procedural History: The patent-in-suit, RE48,794, is a reissue of U.S. Patent No. 9,024,581. The complaint notes that Claim 1 was amended during reissue to narrow a specific dimensional limitation, changing the requirement for the charger's longitudinal length from "equal to or less than 2.0 inches" to "less than 2.0 inches." This narrowing amendment may create a prosecution history estoppel that could limit the scope of the claim under the doctrine of equivalents for that element.

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 several problems with prior art power chargers. These include being bulky enough to block adjacent wall outlets, requiring complex and costly manufacturing processes like insert-molding electrical blades into the plastic housing, and using hand-soldering for internal connections, which is time-consuming and can introduce defects (’794 Patent, col. 1:41-47, col. 2:1-24).
• The Patented Solution: The invention proposes a charger with a reduced physical size and a simplified assembly method. It utilizes separate electrical blades that are slidably inserted into the housing, rather than molded in place, and establishes an electrical connection to the internal printed circuit board (PCB) via spring contacts (’794 Patent, Abstract; col. 3:14-24). This design purports to eliminate the need for insert molding and direct soldering to the blades, thereby reducing manufacturing cost and complexity while enabling a more compact form factor (’794 Patent, col. 13:57-67).
• Technical Importance: The described approach sought to address the market demand for smaller, less obtrusive, and more cost-effective power adapters for the growing number of portable electronic devices (’794 Patent, col. 1:12-19).

Key Claims at a Glance

• The complaint asserts independent Claim 1 (’794 Patent, col. 14:1-53; Compl. ¶23).
• Essential elements of independent Claim 1 include:
  • A charger plug for converting 120V input power to DC output power.
  • 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 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 dependent claims.

III. The Accused Instrumentality

Product Identification

• The "InMotion Micro USB Charger" (the "Micro USB") (Compl. ¶14).

Functionality and Market Context

• The complaint alleges the Micro USB is a charger that connects between an AC power source, like a wall outlet, and a mobile device to provide DC charging power (Compl. ¶15). The complaint includes a photograph of the accused product's retail packaging and the product itself (Compl. p. 6). This visual shows a standard wall charger with two prongs and a USB port. Plaintiff alleges the product's design incorporates a "reduced plug-size" which "does not block or interfere with the use of adjacent outlets" (Compl. ¶16). It is further alleged that the product's size and shape allow for easy insertion and removal of a power cord while the charger remains plugged into the wall (Compl. ¶17).

IV. Analysis of Infringement Allegations

RE48,794 E Infringement Allegations

• Identified Points of Contention:
  • Factual Questions: A central factual dispute will likely concern the specific dimensional measurements of the accused product. The complaint provides precise values for length and width (Compl. ¶20). The defense may challenge these measurements or the methodology used to obtain them.
  • Scope Questions: The interpretation of the "no interference" limitation will be critical. The parties may dispute whether this requires a complete absence of physical overlap with the space of an adjacent outlet or allows for some de minimis encroachment. The evidence required to prove or disprove "interference" across "all available orientations" may also be a point of contention.

V. Key Claim Terms for Construction

• The Term: "no interference with an adjacent receptacle"

• Context and Importance: This is a negative functional limitation that defines a key feature of the invention's compact size. The outcome of the infringement analysis for this element depends entirely on how broadly or narrowly the court defines "interference." Practitioners may focus on this term because its ambiguity could be outcome-determinative.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A party arguing for a broader interpretation (i.e., that more actions constitute "interference") might point to the patent's general statements about solving the problem of blocking adjacent outlets, suggesting any physical overlap that hinders use is sufficient (’794 Patent, col. 1:41-47).
  • Evidence for a Narrower Interpretation: A party arguing for a narrower interpretation (i.e., that only significant blockage constitutes "interference") could argue that the term should be understood in its practical context, where minor physical overlap that does not actually prevent the use of an adjacent plug is not "interference." The specification lacks a precise definition, which may lead parties to argue for a plain and ordinary meaning that requires a functional impediment, not just spatial proximity.

• The Term: "longitudinal length extending between the front wall and the rear end"

• Context and Importance: While seemingly straightforward, the specific points on the charger's body that define the "front wall" and "rear end" for measurement purposes could become a point of dispute, especially if the housing is tapered or has a non-planar geometry. The complaint's assertion of a specific length (1.654 inches) suggests this will be a contested factual element tied to claim construction.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The term could be interpreted broadly to mean the maximum overall dimension in the direction of the prongs, regardless of specific surface features.
  • Evidence for a Narrower Interpretation: The patent figures, such as FIG. 1, show a defined housing body (14) with a front and a tapered rear (40). A party could argue the "rear end" is a specific plane or surface on the main body, potentially excluding protrusions, which could result in a shorter measured length.

VI. Other Allegations

• Willful Infringement: The prayer for relief requests a finding of willful infringement and treble damages (Compl. p. 8, ¶C). However, the body of the complaint does not plead any specific facts to support this claim, such as allegations of pre-suit knowledge of the patent or deliberate copying.

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

• A core issue will be one of claim scope and factual proof: Can Plaintiff prove, by a preponderance of the evidence, that the accused charger's physical dimensions and profile meet the specific numerical and functional limitations of Claim 1? This will likely involve a "battle of the experts" on both measurement methodology and the functional meaning of "no interference."
• A second key question will be one of claim construction: How will the court define "no interference with an adjacent receptacle"? The resolution of this issue—whether it implies a strict geometric boundary or a more practical, functional standard—will significantly influence whether the accused product is found to infringe this critical limitation.
• Finally, the case presents a question regarding the impact of the reissue proceeding: The narrowing amendment to the "longitudinal length" limitation (from "equal to or less than" to "less than" 2.0 inches) raises the question of whether prosecution history estoppel will bar Plaintiff from asserting infringement under the doctrine of equivalents for this element, potentially limiting the infringement case to a literal, and very precise, dimensional comparison.