Voltstar Tech Inc v. I Xtech LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Voltstar Technologies, Inc. (Illinois)
  • Defendant: I-Xtech LLC (New Jersey)
  • Plaintiff’s Counsel: Sriplaw PLLC
• Case Identification: 2:25-cv-02322, D.N.J., 04/04/2025
• 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 as a New Jersey company.
• Core Dispute: Plaintiff alleges that Defendant’s compact wall charger infringes a patent related to the physical design and dimensions of a charger plug that avoids interference with adjacent wall outlets.
• Technical Context: The technology concerns the mechanical design and packaging of AC-to-DC power adapters, a ubiquitous consumer electronics accessory where compact size and non-interference with other plugs are significant market differentiators.
• Key Procedural History: The patent-in-suit, RE48,794 E, is a reissue of U.S. Patent No. 9,024,581. The complaint notes that during the reissue process, Claim 1 was amended to narrow its scope by adding a specific dimensional limitation on the width of the charger housing, a fact that may focus the infringement analysis on precise physical measurements.

Case Timeline

Date	Event
2008-05-21	Priority Date for U.S. Patent No. 9,024,581
2008-05-21	Original inventors assign rights to Horizon Technologies, Inc.
2010-03-01	Horizon Technologies, Inc. changes name to Voltstar Technologies, Inc.
2015-05-05	U.S. Patent No. 9,024,581 issues
2021-10-26	U.S. Reissue Patent No. RE48,794 E issues
2025-04-04	Complaint filed

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

U.S. Reissue Patent No. RE48,794 E - Charger Plug With Improved Package

The Invention Explained

• Problem Addressed: The patent's background section describes issues with prior art charger plugs, noting that their size can block adjacent wall outlets and their length can prevent placement of furniture close to a wall (RE48,794 E Patent, col. 1:42-55). It also identifies the high cost and complexity of manufacturing, particularly the processes of insert-molding electrical blades into the plastic housing and then hand-soldering them to internal circuitry (RE48,794 E Patent, col. 2:1-31).
• The Patented Solution: The invention proposes a charger with a reduced package size achieved through a novel assembly method. Instead of insert-molding, the electrical blades are separate components that are slidably mounted into the housing (RE48,794 E Patent, col. 4:36-44). Electrical connection is made via solder-less spring contacts that are biased against the blades, simplifying assembly and reducing the internal space required for solder joints and wires (RE48,794 E Patent, col. 3:20-28; Abstract). This design allows for a smaller overall housing that is less likely to obstruct adjacent outlets.
• Technical Importance: The described approach sought to reduce both the physical footprint and the manufacturing cost of power adapters, two critical factors in the competitive market for consumer electronics accessories.

Key Claims at a Glance

• The complaint asserts at least Independent Claim 1 (Compl. ¶23).
• The essential elements of Independent Claim 1 include:
  • A charger plug for converting 120V input power to DC output power.
  • A housing containing first and second separate blade members with prong portions.
  • A DC connector with an aperture to receive a power cord plug.
  • The housing being sized with a longitudinal length less than 2.0 inches and a width of the housing outer profile less than 1.75 inches.
  • The housing's outer profile having no interference with an adjacent receptacle of a power source.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The "Xtech GaN 33w Smart Fast Charger" (the "Xtech 33W") (Compl. ¶14).

Functionality and Market Context

• The complaint alleges the Xtech 33W is a charger used to connect between an AC power source, like a wall outlet, and a device with a rechargeable battery, like a mobile phone (Compl. ¶15). An image provided in the complaint shows a compact, dark-colored wall charger with two parallel electrical prongs (Compl. p. 5).
• The complaint alleges the Xtech 33W employs a "reduced plug-size" design, which allows it to be plugged into a wall outlet without blocking or interfering with the use of adjacent outlets (Compl. ¶16). It is also alleged that the product has specific physical dimensions: a longitudinal length of approximately 1.338 inches and a width of approximately 1.238 inches (Compl. ¶20).

IV. Analysis of Infringement Allegations

The complaint references a claim chart in "Exhibit 2" that was not provided with the filed document (Compl. ¶18, ¶23). The infringement theory can be summarized from the complaint's narrative allegations.

Plaintiff alleges that the Xtech 33W infringes at least Claim 1 of the ’794 Patent. The core of the infringement allegation appears to rest on two main points. First, the complaint alleges that the Xtech 33W performs the same general function as the claimed invention: it is a charger that connects an AC source to a DC-powered device (Compl. ¶15). Second, and more specifically, the complaint alleges the Xtech 33W meets the key physical and functional limitations of Claim 1. It alleges the product has a "reduced plug-size" profile that "does not block or interfere with the use of adjacent outlets" (Compl. ¶16), which directly tracks the "no interference" limitation of the claim. Furthermore, the complaint provides specific measurements for the accused product's length (1.338 inches) and width (1.238 inches), alleging these dimensions fall within the explicit "less than 2.0 inches" and "less than 1.75 inches" limitations added to Claim 1 during reissue (Compl. ¶20; ’794 Patent, col. 14:46-51).

Identified Points of Contention:

• Scope Questions: A potential issue is whether the term "outer profile" as used in the patent has a clear and unambiguous meaning or if its measurement methodology will be disputed.
• Technical Questions: The complaint's allegation of "no interference with an adjacent receptacle" is a functional claim. A central question will be what evidence exists to demonstrate that the Xtech 33W’s physical shape, when "mounted in all available orientations in any of the other receptacles," actually achieves this non-interference outcome as required by the claim (’794 Patent, col. 14:52-59).

V. Key Claim Terms for Construction

• Term: "outer profile"

• Context and Importance: This term is part of the dimensional limitation "a width of the housing outer profile being less than 1.75 inches," which was added during reissue to narrow the claim (Compl. ¶12; ’794 Patent, col. 14:49-51). The definition of "outer profile" and how its "width" is measured will be critical to determining literal infringement, as the complaint alleges the accused product's width is approximately 1.238 inches (Compl. ¶20).

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification uses the term generally when describing the housing, referring to an "outer profile defined by a perimeter of the front wall" (’794 Patent, col. 14:35-37). This language could suggest the term refers to the overall maximum cross-sectional dimension of the main body.
  • Evidence for a Narrower Interpretation: The patent does not appear to provide an explicit definition that would narrow the term beyond its plain meaning. However, a defendant might argue that the term should be interpreted in light of the patent's figures, potentially excluding minor protrusions or requiring measurement at a specific point along the housing's length.

• Term: "having no interference with an adjacent receptacle"

• Context and Importance: This is a key functional limitation that defines the benefit of the invention's compact size. The parties will likely dispute what constitutes "interference" and what level of proof is required to show its absence "on all sides of the first receptacle when a like charger plug is mounted in all available orientations" (’794 Patent, col. 14:52-59).

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent background broadly discusses the problem of plugs that "provides little or no interference with use of an adjacent receptacle" (RE48,794 E Patent, col. 1:45-48). Plaintiff may argue this context supports a common-sense interpretation where "interference" means any physical obstruction that prevents a standard plug from being inserted into an adjacent outlet.
  • Evidence for a Narrower Interpretation: The patent itself does not set forth a specific test or standard for what constitutes "interference." A defendant could argue this term is indefinite or that it requires a specific type of obstruction that is not present. The claim language requiring testing "in all available orientations" may raise questions about the scope and practicality of the required proof.

VI. Other Allegations

• Indirect Infringement: The complaint does not contain allegations of indirect infringement.
• Willful Infringement: The complaint makes a demand for a finding of willful infringement in the prayer for relief (Compl. ¶C, p. 7). However, the body of the complaint does not allege any specific facts to support this claim, such as pre-suit knowledge of the patent or egregious conduct.

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

1. A central issue will be one of claim construction and measurement: How should the term "width of the housing outer profile" be construed and measured? The case may depend on whether the parties' experts agree on a methodology for measuring the accused product to verify if it meets the precise dimensional limits added during the patent's reissue.

2. A key evidentiary question will be one of functional proof: What evidence will be required to prove or disprove the functional limitation that the charger’s "outer profile" has "no interference with an adjacent receptacle"? The outcome may turn on physical demonstrations or expert testimony analyzing the accused product's interaction with various standard multi-receptacle wall outlets.