Socket Solutions LLC v. Yuyao Zhuoli Wire Cable Factory

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Socket Solutions, LLC (Texas)
  • Defendant: Yuyao Zhuoli Wire Cable Factory (China)
  • Plaintiff’s Counsel: Law Office of Edward H. Rice, LLC
• Case Identification: 1:23-cv-15594, N.D. Ill., 11/02/2023
• Venue Allegations: Venue is alleged to be proper because the defendant is not a U.S. resident and has allegedly sold the accused products into the judicial district.
• Core Dispute: Plaintiff alleges that Defendant’s single-cord and dual-cord electrical outlet covers infringe patents related to ultra-thin, outlet-concealing power extension devices.
• Technical Context: The technology concerns electrical outlet covers designed to be extremely thin, allowing furniture to be placed nearly flush against a wall while still providing access to power through an attached extension cord, thereby improving aesthetics and safety.
• Key Procedural History: The complaint alleges that Defendant had actual pre-suit notice of the ’080 Patent because it used images of Plaintiff's product packaging, which included a patent marking notice, to promote its own products. This allegation forms the basis for the willfulness claim. The complaint also includes a count for false advertising under the Lanham Act.

Case Timeline

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 the problem of conventional electrical plugs extending several inches from a wall outlet. This creates wasted space, prevents furniture from being placed flush against the wall, is aesthetically "unattractive," and poses a safety hazard to children (’080 Patent, col. 1:21-38).
• The Patented Solution: The invention is a thin cover that plugs into and conceals a wall outlet. Its key feature is an electrical connection component with pins bent at an approximately ninety-degree angle, which minimizes the device's protrusion from the wall (’080 Patent, col. 2:16-20). This assembly connects to an electrical cord that terminates in one or more receptacles, effectively relocating the power access point while hiding the original outlet (’080 Patent, Abstract; Fig. 5).
• Technical Importance: This design allows for more flexible room arrangement by reducing the clearance needed for plugs behind furniture and improves home safety and aesthetics by covering exposed outlets (’080 Patent, col. 2:46-54).

Key Claims at a Glance

• The complaint asserts independent Claim 19 (Compl. ¶48).
• Essential elements of Claim 19 include:
  • An apparatus for hiding a standard indoor electrical wall outlet.
  • 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 first outlet receptacle.
  • An electrical cord extends from the backplate/cover.
  • The cord’s proximal end has pins (hot, neutral, optional ground) positioned to "minimize distance between the front plate and the backplate."
  • The cord’s distal end has at least one receptacle.
  • The height of the internal pins is "approximately the same or less than the thickness of the cord."
• The complaint does not explicitly reserve the right to assert other claims.

U.S. Patent No. 11,450,997 - Functional Indoor Electrical Wall Outlet Cover

• Patent Identification: U.S. Patent No. 11,450,997, "Functional Indoor Electrical Wall Outlet Cover," issued September 20, 2022.

The Invention Explained

• Problem Addressed: The patent identifies a limitation in prior art, such as the device in the ’080 Patent, where the outlet cover is designed to access electrical current from only one receptacle of a duplex wall outlet, leaving the second receptacle unused (’997 Patent, col. 1:52-61).
• The Patented Solution: The invention provides an outlet cover with two distinct electrical plugs that insert into both receptacles of a standard duplex outlet. These two plugs are connected to two separate electrical cords, which can extend in the same or different directions to provide power to multiple locations from a single outlet, thereby enhancing versatility (’997 Patent, Abstract; col. 2:1-19).
• Technical Importance: This innovation allows for the full utilization of a duplex outlet while maintaining the low-profile, outlet-concealing benefits, affording "enhanced versatility to the apparatus" (’997 Patent, col. 2:16-19).

Key Claims at a Glance

• The complaint asserts independent Claim 1 (Compl. ¶56).
• Essential elements of Claim 1 include:
  • An apparatus for hiding a standard indoor duplex wall outlet and affording continued use of both receptacles.
  • A cover with a frontplate and a backplate.
  • The backplate comprises a first set of electrical prongs for the first receptacle and a second set of electrical prongs for the second receptacle.
  • A first electrical cord extends from the cover, connected to the first set of prongs, and terminating in at least one receptacle.
  • A second electrical cord extends from the cover, connected to the second set of prongs, and terminating in at least one receptacle or a preparation for direct connection to a device.
  • The two sets of prongs are positioned so as not to interfere with each other or add bulk.
  • The two cords can extend from the same or different sides of the cover.
• The complaint does not explicitly reserve the right to assert other claims.

III. The Accused Instrumentality

Product Identification

• The complaint identifies the "Accused Single-Cord Outlet Covers" and the "Accused Dual-Cord Outlet Covers," collectively referred to as the "Accused Products" (Compl. ¶¶4, 6, 13).

Functionality and Market Context

• The Accused Single-Cord Outlet Cover is described as an electrical wall outlet cover that plugs into a standard outlet to conceal it while providing one or more receptacles via an extension cord (Compl. ¶¶3-4). An image from an Alibaba.com product listing shows a flat white cover, a single cord, and a three-outlet power strip at the end (Compl. ¶47).
• The Accused Dual-Cord Outlet Cover is described as a cover that plugs into both receptacles of a duplex outlet and connects to two extension cords (Compl. ¶¶5-6). An image from a product listing shows the device plugged into a duplex wall outlet, with two cords extending from the bottom of the cover (Compl. ¶53).
• The complaint alleges Defendant is a Chinese company that manufactures and sells the Accused Products into the U.S. through e-commerce platforms like Alibaba.com (Compl. ¶¶13-14, 20).

IV. Analysis of Infringement Allegations

The complaint does not contain detailed claim charts but alleges that the accused products practice each limitation of the asserted claims. The following tables summarize the allegations based on descriptions and visual evidence in the complaint.

’080 Patent Infringement Allegations

’997 Patent Infringement Allegations

Identified Points of Contention

• Technical Questions: A central evidentiary question for both patents will be whether the internal construction of the Accused Products meets the specific claim limitations. The complaint relies on external appearance, but infringement will depend on the internal arrangement, positioning, and dimensions of the electrical pins and wires, which are not detailed. For the ’080 Patent, a key question is whether the internal pin height is "approximately the same or less than the thickness of the cord."
• Scope Questions: For the ’080 Patent, a point of contention may be the construction of the phrase "in such manner as to minimize distance between the front plate and the backplate." The patent specification heavily emphasizes a 90-degree bend in the electrical pins as the mechanism for achieving this (’080 Patent, col. 2:16-20). The analysis will question whether the accused device achieves a "minimized distance" and if it does so in the manner claimed.

V. Key Claim Terms for Construction

• Term: "in such manner as to minimize distance between the front plate and the backplate" (’080 Patent, Claim 19)

  • Context and Importance: This term is central to the invention's core low-profile feature. The definition of "minimize distance" will be critical to the infringement analysis, as it dictates the required internal structure of the device. Practitioners may focus on this term to determine if it is limited to the specific embodiment shown or covers any design that is thinner than a conventional plug.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself does not explicitly require a specific angle or structure, only a functional outcome ("minimize distance"). Plaintiff may argue this covers any design that achieves a thin profile.
    • Evidence for a Narrower Interpretation: The specification repeatedly describes the solution as electrical pins "bent at approximately ninety degree angle so that the connection... does not add bulk" (’080 Patent, col. 2:16-19). Figure 5, showing the internal view, depicts this 90-degree bend. Defendant may argue that the claim should be construed in light of these specific disclosures.

• Term: "a first electrical cord extending from the backplate, or the cover" (’997 Patent, Claim 1)

  • Context and Importance: This term defines where the cords originate. Its construction is important for determining whether the physical attachment point of the cord within the accused product's housing meets the claim language.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The phrase "extending from" could be interpreted broadly to mean simply exiting the housing, regardless of the precise internal point of connection.
    • Evidence for a Narrower Interpretation: The patent specification shows the electrical cords are "respectively attached to the first electrical component... and to the second electrical component," which are themselves "fastened to the backplate" (’997 Patent, col. 7:42-47; Fig. 5). A party could argue "extending from the backplate" requires this more direct structural relationship.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducing infringement of the ’080 Patent. The factual basis is that Defendant "actively encourages customers to sell, offer to sell, and/or use the Accused Single-Cord Outlet Covers in the U.S." with actual knowledge of the patent (Compl. ¶¶99, 101).
• Willful Infringement: The complaint alleges willful infringement of the ’080 Patent. This is based on the allegation that Defendant had actual, pre-suit notice of the patent because it "displayed an image of the package that Socket Solutions uses for its genuine, patented Sleek Socket® product" and, while removing the branding, "did not remove Socket Solutions’ patent notice, which appears on the package and includes a notice for the ’080 Patent" (Compl. ¶¶90-93, 95).

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

• A central issue will be one of evidentiary proof: Can Plaintiff demonstrate, through discovery or reverse engineering, that the unseen internal construction of the Accused Products meets the specific claim limitations related to the arrangement and dimensions of the electrical pins (e.g., "minimize distance," pin height relative to cord thickness), which are foundational to the patents but not verifiable from the complaint's external images?
• The case will also likely involve a question of claim scope: How will the court construe the term "minimize distance" from the ’080 patent? Will it be limited to the 90-degree pin bend shown in the specification's preferred embodiment, or will it be interpreted more broadly to encompass any design that achieves a low profile, potentially altering the infringement analysis.
• A key question for damages will be willfulness: Can Plaintiff substantiate its allegation that Defendant possessed pre-suit knowledge of the ’080 patent by using altered images of Plaintiff’s packaging that still bore a patent marking, thereby exposing Defendant to potential enhanced damages?