Socket Solutions LLC v. Shenzhenshishiyidianzikejiyouxiangongsi

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Socket Solutions, LLC (Texas)
  • Defendant: Shenzhenshishiyidianzikejiyouxiangongsi (China)
  • Plaintiff’s Counsel: Law Office of Edward H. Rice, LLC
• Case Name: Socket Solutions, LLC v. Shenzhenshishiyidianzikejiyouxiangongsi
• Case Identification: 1:23-cv-04019, N.D. Ill., 06/23/2023
• Venue Allegations: Venue is alleged to be proper on the basis that the defendant is not a U.S. resident.
• Core Dispute: Plaintiff alleges that Defendant’s electrical wall outlet cover and power strip products infringe a patent related to a functional indoor electrical wall outlet cover designed to be ultra-thin.
• Technical Context: The technology addresses the market for aesthetic and space-saving electrical accessories that conceal wall outlets, allowing furniture to be placed nearly flush against a wall while still providing electrical power.
• Key Procedural History: The complaint alleges that the Defendant has had knowledge of the patent-in-suit and the Plaintiff’s infringement claims since at least January 2023, which may form the basis for an allegation of willful infringement.

Case Timeline

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

U.S. Patent No. 9,509,080 - "Functional Indoor Electrical Wall Outlet Cover", issued November 29, 2016

The Invention Explained

• Problem Addressed: The patent describes the problem of conventional electrical plugs extending several inches from a wall outlet, which creates wasted space, prevents furniture from sitting flush against the wall, is aesthetically unpleasing, and can pose a safety hazard to children ('080 Patent, col. 1:20-38).
• The Patented Solution: The invention is a thin cover that completely conceals a standard wall outlet. The cover contains a plug on its back side with electrical pins bent at approximately a ninety-degree angle, which minimizes the device's protrusion from the wall ('080 Patent, Abstract; col. 2:15-20). An electrical cord extends from this low-profile connection to a distal power strip or receptacle, allowing the outlet to remain functional while hidden ('080 Patent, col. 1:55-63; Fig. 1).
• Technical Importance: This design provides a safe and aesthetically pleasing way to use a wall outlet that is hidden behind furniture or in a conspicuous location, addressing shortcomings of both standard plugs and simple, non-functional safety covers ('080 Patent, col. 1:45-54).

Key Claims at a Glance

• The complaint asserts independent claim 19 ('080 Patent, col. 8:65 - col. 9:20).
• The essential elements of independent claim 19 are:
  • A cover comprising a frontplate and a backplate.
  • The backplate includes at least one set of electrical prongs (hot, neutral, optional ground) to plug into a wall outlet.
  • An electrical cord extends from the cover.
  • The cord's proximal end has internal electrical pins (hot, neutral, optional ground wire) connected to the external prongs.
  • The cord's distal end has at least one receptacle for use.
  • A key structural limitation wherein the height of the internal hot pin, neutral pin, and any ground wire is "approximately the same or less than the thickness of the cord."
• The complaint’s use of "at least claim 19" suggests it may assert additional claims, including dependent claims, later in the litigation (Compl. ¶30).

III. The Accused Instrumentality

Product Identification

The accused products are identified as "outlet cover/power strip product" sold on Amazon.com under the seller name "bllionn" and listed with Amazon Standard Identification Numbers B0BKKWLBWC, B0BKZJK1LP, B0BKKYV9FP, and B0BKZKYHRZ (Compl. ¶6, ¶27).

Functionality and Market Context

The complaint alleges these are "Ultra-Thin-Concealer-Extension-Outlets" that compete directly with the Plaintiff's own "Sleek Socket®" products (Compl. ¶28, ¶31). The complaint provides an image of the accused product, showing a white cover plate that plugs into a wall outlet and is attached to an extension cord ending in a power strip (Compl. ¶29). This product appears to serve the same function as the patented invention: hiding a wall outlet while providing extended access to its power.

IV. Analysis of Infringement Allegations

The complaint makes a general allegation of infringement without providing a detailed, element-by-element mapping of the accused product's features to the claim language. The following chart is based on the complaint's allegations and reasonable inferences from the product image provided. The complaint reproduces Figure 1 from the patent, which illustrates an embodiment of the invention including a thin outlet cover, an extension cord, and a power strip (Compl. ¶23).

’080 Patent Infringement Allegations

Identified Points of Contention

• Technical Question: The complaint does not provide any evidence (such as a product teardown or internal diagram) regarding the interior construction of the accused product. This raises a key evidentiary question: What evidence will support the allegation that the internal pins of the accused device have a height "approximately the same or less than the thickness of the cord" as required by the final limitation of claim 19?
• Scope Questions: The term "approximately" is a term of degree, the scope of which will be a central issue. This raises the question of whether the accused product's internal dimensions fall within a proper construction of this term, and what evidence is required to prove it.

V. Key Claim Terms for Construction

• The Term: "approximately the same or less than the thickness of the cord"
• Context and Importance: This limitation is critical as it quantifies the core inventive concept of a low-profile plug design. The entire purpose of the invention—to "avoid adding any significant bulk to the wall outlet" ('080 Patent, col. 2:65-67)—is captured in this dimensional relationship. The infringement analysis for claim 19 will likely depend heavily on the construction of "approximately."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party arguing for a broader scope may point to the overall purpose of the invention, suggesting that any internal configuration that achieves the functional goal of being very thin and allowing furniture to sit nearly flush with the wall would meet the "approximately" requirement. The specification repeatedly emphasizes the functional result over a single structure ('080 Patent, col. 1:49-54).
  • Evidence for a Narrower Interpretation: A party arguing for a narrower scope may cite the patent's specific embodiment, which teaches that the low profile is achieved by "electrical pins bent at approximately a ninety degree angle" ('080 Patent, col. 2:15-17; Fig. 5). The specification further states that "the height of the horizontal portion of each electrical pin...is approximately less or the same height (or thickness) as the electrical cord" ('080 Patent, col. 4:8-12), directly tying the claim language to this specific right-angle design. This could support an argument that "approximately" is constrained by the dimensions achievable through such a configuration.

VI. Other Allegations

• Indirect Infringement: The complaint alleges active inducement, stating that the Defendant "actively encourages customers to use the Infringing Outlet Covers" and that such use constitutes direct infringement of at least claim 19 (Compl. ¶35-36). The complaint does not cite specific evidence of inducement, such as user manuals or advertising copy.
• Willful Infringement: The complaint does not use the term "willful," but it alleges that Defendant "has known of Socket Solutions’ ‘080 Patent since at least January 2023" (Compl. ¶37). This allegation of pre-suit knowledge of the patent and infringement could be used to support a claim for enhanced damages for willful infringement.

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

1. A central issue will be one of claim construction: how the court construes the term of degree "approximately the same or less than". The outcome of the case may depend on whether this term is interpreted functionally to mean any design that achieves an ultra-thin profile, or is limited more narrowly to the specific dimensional relationships shown in the patent's right-angle pin embodiment.
2. The case will also present a key evidentiary question: can the Plaintiff produce evidence, likely through discovery and expert analysis, to prove that the accused product's internal components meet the specific dimensional limitations of claim 19? The current complaint makes this allegation without providing supporting factual detail.