DCT
1:23-cv-04669
Socket Solutions LLC v. Huizhou Jishunkang Industrial Co Ltd
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Socket Solutions, LLC (Texas)
- Defendant: Huizhou Jishunkang Industrial Co. Ltd. (China)
- Plaintiff’s Counsel: Law Office of Edward H. Rice, LLC
- Case Identification: 1:23-cv-04669, N.D. Ill., 07/19/2023
- Venue Allegations: Venue is alleged to be proper because the defendant, Huizhou Jishunkang, is not a U.S. resident and has systematically targeted and sold the accused products into the United States, including specifically into the Northern District of Illinois, through e-commerce platforms like Alibaba.com.
- Core Dispute: Plaintiff alleges that Defendant’s ultra-thin electrical wall outlet covers infringe a patent related to a functional and aesthetic cover that conceals a wall outlet while providing power through an attached extension cord.
- Technical Context: The technology addresses the aesthetic and practical problems of traditional electrical plugs, which protrude from walls, prevent furniture from sitting flush, and can pose safety hazards.
- Key Procedural History: The complaint alleges that Defendant was put on notice of the patent-in-suit prior to the lawsuit. Specifically, it alleges a successful infringement claim was asserted on Amazon.com in November 2022 against a reseller of Defendant's products, and that Plaintiff submitted a notice-and-takedown request with a detailed infringement analysis directly to Alibaba.com in March 2023, which Alibaba allegedly shared with the Defendant.
Case Timeline
| Date | Event |
|---|---|
| 2016-04-14 | ’080 Patent Priority Date (Filing Date) |
| 2016-11-29 | ’080 Patent Issue Date |
| 2022-11-XX | Plaintiff asserts infringement claim on Amazon against a reseller |
| 2023-03-XX | Plaintiff submits notice-and-takedown request to Alibaba.com |
| 2023-07-19 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,509,080 - "Functional Indoor Electrical Wall Outlet Cover"
- Patent Identification: U.S. Patent No. 9,509,080, "Functional Indoor Electrical Wall Outlet Cover," issued November 29, 2016.
The Invention Explained
- Problem Addressed: The patent's background section describes how typical electrical plugs extend "several inches from the wall," which wastes space, prevents furniture from being placed flush against the wall, and is "generally unattractive" (’080 Patent, col. 1:21-30). It also notes that exposed outlets pose a "potential safety hazard for infants and children" (’080 Patent, col. 1:31-33).
- The Patented Solution: The invention is a thin cover that plugs into and completely hides a standard wall outlet. An electrical cord extends from the cover to a separate power strip, allowing use of the outlet's power from a more convenient location (’080 Patent, Abstract). The key feature enabling the thin profile is that the internal electrical connection pins are "bent at approximately ninety degree angle," which prevents the cover from adding significant bulk or extending far from the wall (’080 Patent, col. 2:15-20; Fig. 5).
- Technical Importance: This design allows for both child-proofing and improved room aesthetics by concealing the outlet and minimizing the gap between furniture and the wall (’080 Patent, col. 1:49-54).
Key Claims at a Glance
- The complaint asserts independent claim 1 and reserves the right to assert other claims (’080 Patent, col. 7:22-42; Compl. ¶41).
- Independent Claim 1 requires:
- A cover comprising a frontplate and a backplate.
- The backplate has at least one set of electrical prongs (hot, neutral, optional ground) positioned to correspond to a wall outlet receptacle.
- An electrical cord extends from the backplate/cover.
- The cord's proximal end has at least one hot pin and one neutral pin 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.
III. The Accused Instrumentality
Product Identification
- "Infringing Outlet Covers" manufactured by Jishunkang and sold under the brand name "Jeostorm" on platforms including Alibaba.com, Temu.com, and Etsy.com (Compl. ¶¶ 3, 7, 36, 44). The complaint identifies at least three versions, differing in the number and type of receptacles (e.g., standard 3-prong or USB port) (Compl. ¶¶ 36-37).
Functionality and Market Context
- The accused products are described as "ultra-thin outlet cover/power strips" that function to hide wall outlets while providing electrical receptacles via an extension cord (Compl. ¶25). The complaint includes an image of the accused Jeostorm products, showing a flat white or black cover with an attached electrical cord ending in a power strip. This image, obtained from an Alibaba.com product listing, depicts the external appearance and general function of the accused devices (Compl. ¶40). The complaint alleges these products compete directly with the Plaintiff's own "Sleek Socket®" products (Compl. ¶42).
IV. Analysis of Infringement Allegations
The complaint alleges that the accused products infringe at least claim 1 by "practicing each limitation of that claim" but does not provide a detailed, element-by-element breakdown (Compl. ¶41). The following chart summarizes the infringement theory based on the complaint's general allegations and descriptions of the accused product.
’080 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a. a cover comprising: (i) a frontplate; and (ii) a backplate comprising at least one set of electrical prongs including a hot prong, a neutral prong, and optionally a ground prong, positioned to correspond to a first receptacle of the wall outlet | The accused Jeostorm device is an outlet cover with a front and back that includes electrical prongs for plugging into a wall outlet, as depicted in the product image. | ¶¶ 36, 40, 41 | col. 7:25-31 |
| b. an electrical cord extending from the backplate, or the cover | The accused device has an electrical cord extending from the cover portion to a power strip. | ¶¶ 36, 40, 41 | col. 7:32-33 |
| said cord comprising at the cord's proximal end: at least one hot pin, at least one neutral pin... positioned at approximately right angles to the backplate; | The complaint does not provide detail on the internal construction of the accused product, but alleges it practices this limitation to achieve its ultra-thin profile. | ¶¶ 25, 41 | col. 7:34-40 |
| and respectively connected to or associated with the hot prong, neutral prong and any ground prong on the exterior of the backplate... as to minimize distance between the front plate and the backplate | The complaint describes the accused product as "ultra-thin," which suggests it incorporates a design that minimizes its depth, allegedly by practicing the claimed pin configuration. | ¶¶ 25, 41 | col. 7:35-37 |
| and comprising at the cord's distal end at least one receptacle. | The accused device's electrical cord terminates in a power strip containing one or more receptacles, including standard outlets and USB ports. Figure 1 from the patent is included to depict this claimed configuration. | ¶¶ 31, 36-37, 40, 41 | col. 7:41-42 |
Identified Points of Contention
- Technical Questions: A primary factual question will be whether the accused Jeostorm product contains internal electrical pins "positioned at approximately right angles to the backplate." The complaint provides no direct evidence (such as a teardown or internal diagram) of the accused product's internal construction, making this a central issue for discovery.
- Scope Questions: The infringement analysis will turn on the construction of key claim terms. For instance, what range of angles is covered by "approximately right angles"? Similarly, what is the standard for determining if the design achieves the functional goal to "minimize distance" between the plates?
V. Key Claim Terms for Construction
The Term: "positioned at approximately right angles to the backplate"
- Context and Importance: This term is the central technical feature that allegedly enables the invention's low profile. The entire infringement case may depend on whether the accused product's internal pin structure falls within the scope of this limitation. Practitioners may focus on this term because the complaint lacks direct evidence of the accused product's internal design, making this a critical area for discovery and expert testimony.
- 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, potentially encompassing a range of angles that achieve the same functional result of a thin profile.
- Evidence for a Narrower Interpretation: The specification repeatedly and specifically describes the pins as being bent at a "ninety degree angle" (’080 Patent, col. 2:17, col. 2:41-42). Figure 5, which depicts this feature, shows a sharp, 90-degree bend. A defendant may argue that "approximately" covers only minor manufacturing tolerances around 90 degrees.
The Term: "minimize distance between the front plate and the backplate"
- Context and Importance: This is a term of degree that defines the functional outcome of the right-angle pin structure. Its construction will determine the standard for infringement. The question is whether "minimize" implies an absolute standard (e.g., the thinnest possible design) or a relative one (e.g., thinner than prior art plugs).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification contrasts the invention with traditional plugs that "extend several inches" and "protrude as much as about two inches to even four inches," suggesting "minimize" means creating a profile significantly thinner than that prior art standard (’080 Patent, col. 1:21-22, col. 4:29-32).
- Evidence for a Narrower Interpretation: A defendant could argue that "minimize" requires a structure that reduces the distance to the smallest dimension physically permitted by the electrical components themselves, as suggested by the patent's statement that the cover's depth is no more than the "thickness of the combination of the frontplate... backplate... and the electrical pins" (’080 Patent, col. 4:35-40).
VI. Other Allegations
Indirect Infringement
- The complaint alleges inducement to infringe under 35 U.S.C. § 271(b) (Compl., Count II). The factual basis is that Jishunkang "actively encourages its customers to sell and offer to sell the Infringing Outlet Covers in the U.S." (Compl. ¶51). Knowledge, a required element for inducement, is alleged based on a November 2022 Amazon infringement claim against a reseller and a March 2023 Alibaba notice-and-takedown request that allegedly included a "detailed patent infringement analysis" and was communicated to Jishunkang (Compl. ¶¶ 53-54).
Willful Infringement
- While the complaint does not explicitly plead "willful infringement," it lays the factual foundation for such a claim. The allegations of pre-suit knowledge through the Amazon and Alibaba notices (Compl. ¶¶ 53-54) could be used to argue that any infringement after those dates was willful, potentially exposing the defendant to enhanced damages.
VII. Analyst’s Conclusion: Key Questions for the Case
An Evidentiary Question of Internal Structure: Does the accused "Jeostorm" product, which is alleged to be "ultra-thin," actually incorporate internal electrical pins "positioned at approximately right angles to the backplate" as required by claim 1? The resolution of this core factual issue, for which the complaint offers no direct proof, will be dispositive.
A Definitional Question of Scope: How broadly will the court construe the term "approximately right angles"? The case may turn on whether this phrase is interpreted narrowly to mean near-90 degrees, as depicted in the patent's figures, or more broadly to cover any non-linear pin configuration that achieves a thin profile.
A Factual Question of Knowledge and Intent: Assuming direct infringement is found, did the alleged Amazon and Alibaba notices provide Jishunkang with sufficient knowledge of infringement to support the claims for inducement and potential future claims for willfulness? The "complexity and difficulty of the patent case" response allegedly from Alibaba may be used by the defense to argue against a finding of knowing and intentional conduct (Compl. ¶54).