Socket Solutions LLC v. Target Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Socket Solutions, LLC (Texas)
  • Defendant: Target Corporation (Minnesota)
  • Plaintiff’s Counsel: Law Office of Edward H. Rice, LLC
• Case Identification: 1:23-cv-00005, N.D. Ill., 01/02/2023
• Venue Allegations: Venue is alleged to be proper based on Defendant having regular and established places of business in the district and having committed acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s sale of certain outlet cover/power strip products infringes a patent related to low-profile electrical outlet covers.
• Technical Context: The technology concerns electrical outlet covers designed to be exceptionally thin, allowing furniture to be placed nearly flush against a wall while concealing the outlet for aesthetic and safety purposes.
• Key Procedural History: The complaint alleges that Plaintiff sent Defendant a notice letter on December 2, 2022, identifying the patent-in-suit and the accused products. Plaintiff alleges Defendant did not respond to the letter or a subsequent follow-up email before the complaint was filed.

Case Timeline

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

U.S. Patent No. 9,509,080 - Functional Indoor Electrical Wall Outlet Cover

The Invention Explained

• Problem Addressed: The patent describes a problem with conventional electrical plugs, which extend several inches from a wall outlet. This creates an unattractive appearance, prevents furniture from being positioned flush against the wall, and can pose a safety hazard for children (Compl. ¶13; ’080 Patent, col. 1:20-39).
• The Patented Solution: The invention is a thin cover that completely conceals a standard wall outlet. The cover contains a built-in electrical plug with pins bent at an approximately ninety-degree angle, allowing the cover itself to sit very close to the wall. An electrical cord extends from the cover to a separate power strip, relocating the functional receptacles to a more convenient or discreet location (’080 Patent, col. 2:15-20, Abstract). The complaint includes Figure 1 from the patent, which illustrates the complete assembly of the cover, cord, and remote power strip (Compl. ¶19).
• Technical Importance: This design provides a functional electrical connection while improving safety and aesthetics by hiding the outlet and minimizing the protrusion from the wall (’080 Patent, col. 1:45-55).

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 1 (Compl. ¶25, ¶36).
• The essential elements of independent claim 1 include:
  • A cover comprising a frontplate and a backplate.
  • The backplate comprises at least one set of electrical prongs (hot, neutral, optional ground) to connect to a wall outlet.
  • An electrical cord extends from the backplate.
  • The cord’s proximal end has at least one hot pin and one neutral pin that are positioned at approximately right angles to the backplate to minimize distance between the frontplate and backplate.
  • The cord’s distal end has at least one receptacle.
• The complaint does not explicitly reserve the right to assert dependent claims, but the phrasing "at least claim 1" suggests this possibility remains open.

III. The Accused Instrumentality

Product Identification

The complaint identifies "Accused Outlet Covers" sold by Target, including products described as "link-space-saving-power-strip-3-socket-3-usb-surge-protector-3-foot-cable-ultra-thin-outlet" and a "mini" version of the same (Compl. ¶23).

Functionality and Market Context

The complaint alleges these are "outlet cover/power strip products" (Compl. ¶23). A provided image depicts a flat, white rectangular cover with an attached electrical cord leading to a power strip, which is consistent with the general purpose of the patented invention (Compl. ¶24). The complaint asserts that these products compete directly with Plaintiff's own "Sleek Socket®" products (Compl. ¶28).

IV. Analysis of Infringement Allegations

The complaint makes a general allegation that the Accused Outlet Covers infringe claim 1 without mapping specific product features to each claim element (Compl. ¶25). The following chart summarizes the infringement theory based on the product's depicted functionality and the complaint's general allegations.

'080 Patent Infringement Allegations

Identified Points of Contention

• Technical Question: The complaint does not include evidence regarding the internal structure of the Accused Outlet Covers. A central factual question for discovery will be whether the accused devices actually contain electrical pins "positioned at approximately right angles to the backplate," as required by the claim, or if they achieve a low profile through an alternative technical means.
• Scope Question: The construction of the term "approximately right angles" will be critical. The litigation may explore how much deviation from a perfect 90-degree angle falls within the scope of the claim.

V. Key Claim Terms for Construction

The Term

"positioned at approximately right angles to the backplate"

Context and Importance

This limitation appears to be the central technical feature that enables the invention's low-profile design. The entire purpose of the device—to "minimize distance between the front plate and the backplate"—is accomplished by this specific geometric arrangement of the internal electrical pins (’080 Patent, col. 7:35-37). Whether the accused products have this specific structure will likely be a dispositive issue for infringement. Practitioners may focus on this term because it links a specific structure to the invention's primary functional advantage.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The use of the word "approximately" suggests the patentee did not intend to limit the claim to a precise 90-degree angle. A plaintiff may argue that any configuration that achieves the stated functional goal of minimizing the cover's depth by bending the pins relative to the backplate falls within the claim's scope. The specification states the goal is to "minimize distance" and avoid "bulk" (’080 Patent, col. 7:35-37, col. 2:18-19).
• Evidence for a Narrower Interpretation: The specification explicitly and repeatedly refers to a "ninety degree angle" when describing the preferred embodiment and its benefits (’080 Patent, col. 2:16-17; Fig. 5 heading). A defendant may argue that this specific geometric arrangement is not merely exemplary but is a defining characteristic of the invention that distinguishes it from other potential low-profile designs.

VI. Other Allegations

Indirect Infringement

The complaint alleges active inducement under 35 U.S.C. § 271(b) (Compl. ¶37). The factual basis is the allegation that Target "actively encourages customers to use the Accused Outlet Covers" in their intended, infringing manner, and that Target knew of the '080 patent at least as of its receipt of a notice letter dated December 2, 2022 (Compl. ¶38-39).

Willful Infringement

Willfulness is alleged based on Target’s continued offering for sale and sale of the Accused Outlet Covers after it "knew or had reason to know" of the '080 patent and the alleged infringement, with knowledge dating to its receipt of the December 2, 2022 letter (Compl. ¶43-45).

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

1. A central issue will be one of claim construction and scope: How narrowly will the court construe the limitation "positioned at approximately right angles to the backplate"? Will it be interpreted as requiring a specific geometric structure as depicted in the patent's figures, or as functionally covering any internal pin configuration that achieves a similarly low profile?
2. The case will also turn on a key evidentiary question: What is the actual internal construction of the Accused Outlet Covers? Discovery will be required to determine if their design incorporates the specific right-angle pin structure recited in claim 1, or if they utilize a different mechanism to connect the cord to the plug prongs.