Socket Solutions LLC v. Cai

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Socket Solutions, LLC (Texas)
  • Defendant: Guodong Cai (China)
  • Plaintiff’s Counsel: Law Office of Edward H. Rice, LLC
• Case Identification: 1:23-cv-15650, N.D. Ill., 11/03/2023
• Venue Allegations: Venue is alleged to be proper because the defendant, Guodong Cai, is not a U.S. resident and conducts business in the district by selling accused products to Illinois consumers via Amazon.com.
• Core Dispute: Plaintiff alleges that Defendant’s electrical wall outlet covers, sold on Amazon.com, infringe a patent related to a functional and aesthetic outlet cover with a thin-profile plug.
• Technical Context: The technology concerns consumer electrical accessories designed to conceal wall outlets for safety and aesthetic reasons while allowing furniture to be placed nearly flush against the wall.
• Key Procedural History: The complaint alleges that Plaintiff’s own products, which practice the patent-in-suit, are marked with the patent number in compliance with 35 U.S.C. § 287.

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 the problem of conventional electrical plugs protruding several inches from a wall outlet, which creates an unattractive appearance and prevents furniture from being positioned flush against the wall (’080 Patent, col. 1:20-30). This wastes space and can also pose a safety hazard for children (’080 Patent, col. 1:31-37).
• The Patented Solution: The invention is a thin cover that completely conceals a standard wall outlet. It incorporates a functional electrical plug with connection pins bent at an approximately ninety-degree angle, which allows the cover to sit nearly flat against the wall, minimizing its protrusion (’080 Patent, Abstract; col. 2:15-20). The cover is connected to an extension cord that provides one or more standard electrical receptacles at its other end, preserving the outlet's functionality (’080 Patent, col. 1:45-56). Figure 1 of the patent illustrates the complete assembly, showing the flat cover (15), the cord (16), and the power strip (29) at the distal end (Compl. ¶24).
• Technical Importance: This design allows users to hide unsightly outlets and place furniture closer to the wall than is possible with traditional plugs, addressing both aesthetic and practical space-saving concerns in homes and offices (’080 Patent, col. 1:49-54).

Key Claims at a Glance

• The complaint asserts independent Claim 19 (’080 Patent, col. 9:1-20) and reserves the right to assert other claims (Compl. ¶31).
• Claim 19 Elements:
  • 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) positioned to correspond to a first receptacle of the wall outlet.
  • An electrical cord extending from the backplate with at least one receptacle at its distal end.
  • At the cord's proximal end, at least one hot pin and one neutral pin are positioned on or attached to the backplate to minimize distance between the frontplate and backplate.
  • The height of the hot pin, neutral pin, and any ground wire is "approximately the same or less than the thickness of the cord."

III. The Accused Instrumentality

Product Identification

• "Accused Outlet Covers" sold by Defendant Guodong Cai on an Amazon.com storefront named "Humpptom GROUP" (Compl. ¶6, ¶28).

Functionality and Market Context

• The complaint describes the Accused Outlet Covers as "outlet cover/power strip products" (Compl. ¶28). An image from the Amazon product listing shows a flat, white cover designed to plug into a wall outlet, with an attached extension cord leading to a multi-receptacle power strip (Compl. ¶29). This image depicts one of the Accused Outlet Covers (Compl. ¶29). The complaint alleges that these products compete directly with the Plaintiff's patented "Sleek Socket®" products (Compl. ¶34).

IV. Analysis of Infringement Allegations

The complaint alleges that the Accused Outlet Covers infringe at least Claim 19 by practicing each limitation of that claim, but does not provide a detailed element-by-element analysis or an explicit claim chart (Compl. ¶31). The infringement theory must be inferred from the product images and general allegations.

’080 Patent Infringement Allegations

Identified Points of Contention

• Technical Questions: A central evidentiary question will be whether the internal construction of the Accused Outlet Covers meets the dimensional limitation of Claim 19, which requires the height of the internal pins to be "approximately the same or less than the thickness of the cord." The complaint's visual evidence is external and does not provide a basis to evaluate this internal structural feature.
• Scope Questions: The case may raise a question of whether the accused product's housing, which could be a single molded unit, satisfies the "frontplate" and "backplate" limitations. The patent specification describes these as components that fit together, which may support a narrower interpretation requiring two distinct pieces (col. 4:1-4).

V. Key Claim Terms for Construction

• The Term: "approximately the same or less than"

  • Context and Importance: This term is critical as it quantifies the core inventive concept of a "thin" cover. The patentability of the invention and the infringement analysis for the accused product may depend on the degree of tolerance afforded by "approximately." Practitioners may focus on this term because its construction will define the boundary between a standard, bulkier plug and the patented low-profile design.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The repeated use of "approximately" throughout the patent (e.g., col. 2:16, col. 8:40) could suggest that the patentee did not intend to be held to a precise numerical dimension, but rather to a functional outcome of being significantly thinner than prior art plugs.
    • Evidence for a Narrower Interpretation: The patent links the term to a specific physical relationship: "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. 4:8-11). A party could argue this ties the definition to the measurable thickness of the cord itself, implying a less flexible standard.

• The Term: "a frontplate; and ... a backplate"

  • Context and Importance: This structural limitation defines the cover assembly. If the Accused Outlet Covers are constructed from a single piece of molded plastic, the definition of these terms will be dispositive for infringement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party could argue that "frontplate" and "backplate" refer to the front and back surfaces or portions of the cover, regardless of whether they are separately manufactured.
    • Evidence for a Narrower Interpretation: The specification describes the backplate fitting "inside the frontplate" and the two components holding "together without fasteners, attachers, or adhesive," which is detailed in Claim 4 (’080 Patent, col. 8:49-52). This language, along with figures showing two distinct parts (e.g., Fig. 2), may support an interpretation requiring two separate, physically mating components.

VI. Other Allegations

The complaint does not provide sufficient detail for analysis of indirect or willful infringement.

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

This dispute appears to center on fundamental questions of proof and claim scope. The resolution of the case will likely depend on the answers to the following:

1. An Evidentiary Question of Internal Structure: Can the Plaintiff, through discovery, prove that the internal components of the Accused Outlet Covers meet the specific dimensional limitation of Claim 19 requiring the pin height to be "approximately the same or less than the thickness of the cord"? The current complaint lacks any direct evidence on this point.
2. A Definitional Question of Component Structure: Does the term "a cover comprising... a frontplate; and... a backplate" require two physically distinct components as depicted in the patent's embodiments, or can it read on a single, integrated housing as may be found in the accused device?
3. A Claim Construction Question of Scope: How much variance is permitted by the term "approximately"? The court's construction of this qualifier will be critical in determining whether the accused product's low-profile design, whatever its exact dimensions, falls within the scope of the patent's claims.