Voltstar Tech Inc v. Voice Comm LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Voltstar Technologies, Inc. (Illinois)
  • Defendant: Voice Comm, LLC (New Jersey)
  • Plaintiff’s Counsel: Sriplaw PLLC
• Case Identification: 1:25-cv-00778, D.N.J., 01/28/2025
• Venue Allegations: Venue is alleged to be proper in the District of New Jersey because the Defendant has committed acts of infringement there and is subject to personal jurisdiction.
• Core Dispute: Plaintiff alleges that Defendant’s compact wall chargers infringe a patent related to the structural design and dimensional characteristics of power adapter plugs.
• Technical Context: The technology concerns AC-to-DC power adapters for portable electronics, focusing on physical designs that reduce the product's footprint to avoid obstructing adjacent electrical outlets.
• Key Procedural History: The asserted patent, RE48,794 E, is a reissue of U.S. Patent No. 9,024,581. The complaint notes that the reissue process amended a key independent claim to narrow its dimensional limitations, a factor that may be relevant to both infringement and validity analyses. Plaintiff alleges that the reissued claim is substantially identical to the original, giving it continuous effect from the original patent's issue date.

Case Timeline

Date	Event
2008-05-21	Priority Date for U.S. Patent No. 9,024,581
2015-05-05	U.S. Patent No. 9,024,581 Issues
2021-10-26	U.S. Reissue Patent No. RE48,794 E Issues
2025-01-28	Complaint Filed

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

U.S. Reissue Patent No. RE48,794 E - "Charger Plug With Improved Package," issued October 26, 2021

The Invention Explained

• Problem Addressed: The patent's background describes prior art charger plugs as being bulky, often interfering with the use of adjacent electrical outlets, and protruding in a way that makes them susceptible to damage or accidental unplugging (’794 Patent, col. 1:42-59). Furthermore, it identifies the manufacturing processes for these plugs, such as insert molding of the electrical blades and hand soldering, as being costly, time-consuming, and requiring extra space within the housing (’794 Patent, col. 2:1-41).
• The Patented Solution: The invention claims to solve these problems through a charger with an improved mechanical package. It proposes a design using separate, slidably mounted electrical blades that connect to the internal printed circuit board (PCB) via solder-less spring contacts, which simplifies assembly and reduces internal space requirements (’794 Patent, Abstract; col. 4:17-28). This construction, combined with specific dimensional constraints, results in a compact housing with a small profile that is less likely to block other outlets (’794 Patent, col. 13:50-54; Fig. 1).
• Technical Importance: The described approach sought to enable the production of smaller, more convenient, and less expensive power adapters at a time of rapid growth in the portable electronics market (’794 Patent, col. 1:11-18).

Key Claims at a Glance

• The complaint asserts at least Claim 1 of the ’794 Patent (Compl. ¶30).
• Independent Claim 1 recites a charger plug with essential elements including:
  • A housing containing first and second separate blade members with prong portions.
  • A DC connector for a removable power cord.
  • The housing having a specific size, with a longitudinal length of less than 2.0 inches and a width of less than 1.75 inches.
  • The housing’s "outer profile" having "no interference with an adjacent receptacle of the power source located on all sides of the first receptacle when a like charger plug is mounted in all available orientations in any of the other receptacles."

III. The Accused Instrumentality

Product Identification

The complaint names the "Ventev 12W Wall Charger" and the "Ventev 30W GaN Mini Wall Charger + Cable" as the accused instrumentalities (Compl. ¶14, ¶21).

Functionality and Market Context

• The accused products are described as chargers that connect a source of AC power, like a wall outlet, to a rechargeable device, like a mobile phone (Compl. ¶15, ¶22).
• The complaint alleges the products feature a "reduced plug-size" design specifically intended to avoid blocking or interfering with the use of adjacent outlets (Compl. ¶16, ¶23).
• The complaint alleges specific dimensions for the products: the Ventev 12W is approximately 1.383 inches long and 1.373 inches wide, and the Ventev 30W is approximately 1.543 inches long and 1.266 inches wide (Compl. ¶20, ¶27).
• The complaint includes an image of the accused Ventev 12W charger, showing a compact white adapter with two prongs (Compl. ¶14). A similar image shows the accused Ventev 30W GaN Mini Wall Charger (Compl. ¶21).

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits (Exhibits 2 and 3) that were not filed with the public document; therefore, the infringement allegations are summarized below based on the complaint's narrative (Compl. ¶18, ¶25, ¶30).

The plaintiff’s theory of direct infringement is that the accused Ventev 12W and 30W chargers meet every limitation of at least Claim 1 of the ’794 Patent. The allegations are centered on the external form factor and functionality of the accused products. The complaint alleges that the chargers have a compact size designed not to block adjacent outlets (Compl. ¶16, ¶23) and, critically, that their measured physical dimensions fall squarely within the length and width limitations recited in Claim 1(i) (Compl. ¶20, ¶27). The complaint also alleges that the products function as chargers connecting AC outlets to DC-powered devices via a removable cord, mapping to other elements of Claim 1 (Compl. ¶15, ¶17, ¶22, ¶24). An image of the accused Ventev 30W charger depicts its compact, rectangular form factor relative to its electrical prongs (Compl. ¶21).

Identified Points of Contention

• Technical Question: Claim 1 requires "first and second separate blade members secured within the housing." The complaint's allegations are based on the external appearance and dimensions of the accused products and do not contain evidence regarding their internal construction. A central question will be whether discovery reveals that the accused products use this specific "separate blade" construction, which the patent contrasts with the "insert molded" blades of the prior art (’794 Patent, col. 2:62-65), or a different, potentially non-infringing assembly method.
• Scope Question: Infringement of Claim 1(ii) requires showing the charger’s outer profile has "no interference with an adjacent receptacle... on all sides... when a like charger plug is mounted in all available orientations in any of the other receptacles." This limitation sets a high bar. A potential dispute is whether this requires non-interference in every standard NEMA outlet configuration, and what evidence is sufficient to prove this complex geometric condition is met by the accused products.

V. Key Claim Terms for Construction

The Term: "outer profile having no interference with an adjacent receptacle"

• Context and Importance: This term captures the primary functional advantage of the claimed invention. The interpretation of "no interference" and the conditions under which it must be met ("on all sides," "in all available orientations") will be critical to the infringement analysis.
• Evidence for a Broader Interpretation: A party could argue the term should be understood in the practical context of the problem solved—avoiding the common frustration of a bulky charger blocking the second outlet in a standard duplex receptacle. The specification's background repeatedly frames the problem in this general sense (’794 Patent, col. 1:42-49).
• Evidence for a Narrower Interpretation: The claim language itself is highly specific and quantitative. A party could argue it creates a strict, geometric test that requires a showing of non-interference in a multitude of configurations, not just the most common one. The specificity of "on all sides" and "in all available orientations" suggests a meaning more demanding than a general goal of being compact (’794 Patent, col. 14:48-54).

The Term: "separate blade members secured within the housing"

• Context and Importance: This structural limitation is a key point of distinction from the prior art discussed in the patent. As the complaint lacks allegations on the internal build of the accused products, the construction of this term and the evidence required to meet it will be a focal point.
• Evidence for a Broader Interpretation: The specification's focus is on moving away from costly and complex "insert molded" blades (’794 Patent, col. 2:62-65). A party might argue the term should be construed broadly to encompass any construction where the blades are discrete components attached to the housing post-molding, as opposed to being molded into it.
• Evidence for a Narrower Interpretation: The patent's detailed description and figures show a specific embodiment where blades are slidably mounted into slots and held by spring contacts (’794 Patent, col. 4:37-43; Figs. 2A-2C). A party could argue "secured within" should be limited to this disclosed method of securement, or at least methods mechanically analogous to it.

VI. Other Allegations

Willful Infringement

The prayer for relief requests a determination that infringement was "willful, wanton, and deliberate" (Prayer ¶C). The body of the complaint, however, does not allege specific facts to support pre-suit knowledge of the ’794 Patent, such as a notice letter or evidence of copying. The basis for the willfulness allegation may therefore depend on conduct occurring after the filing of the lawsuit.

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

• A key evidentiary question will be one of internal construction: Will discovery show that the accused Ventev chargers are built with the "separate blade members" recited in Claim 1, or will they be shown to use a different internal assembly (e.g., insert molding) that falls outside the claim's scope, creating a fundamental mismatch with the patent's core structural invention?
• The case will also likely involve a question of functional scope: Can the plaintiff prove that the accused products meet the demanding "no interference" limitation of Claim 1, which requires a showing of non-obstruction relative to adjacent outlets "on all sides" and in "all available orientations"? The interpretation of this precise language will be central.
• A third issue may be the impact of reissue: Given that Claim 1 was amended during reissue, a potential question is whether the changes were "substantive" enough to afford the defendant intervening rights under 35 U.S.C. § 252, which could limit past damages even if infringement is found.