DCT
2:23-cv-00051
Voltstar Tech Inc v. Premier Accessory Group LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Voltstar Technologies, Inc. (Illinois)
- Defendant: Premier Accessory Group, LLC (New York)
- Plaintiff’s Counsel: Sriplaw PLLC
- Case Identification: 3:23-cv-00051, D.N.J., 01/05/2023
- Venue Allegations: Venue is asserted based on Defendant allegedly committing acts of infringement in the district and having a regular and established place of business in New Jersey.
- Core Dispute: Plaintiff alleges that Defendant’s Energizer-branded dual USB wall chargers infringe a patent related to compact electrical charger design.
- Technical Context: The technology concerns the design and packaging of AC-to-DC power converters, specifically focusing on minimizing the physical footprint to avoid obstructing adjacent wall outlets.
- Key Procedural History: The patent-in-suit, U.S. Reissue Patent No. RE48,794 E, is a reissue of U.S. Patent No. 9,024,581. During reissue, Claim 1 was amended to narrow the claimed dimensional limitations, a fact that may be relevant to the scope of infringement and damages. The complaint alleges that the reissued claim is "substantially identical" to the original, which suggests Plaintiff will seek damages accruing 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 Issued |
| 2021-10-26 | U.S. Reissue Patent No. RE48,794 E Issued |
| 2023-01-05 | 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 addresses problems with prior art power adapter plugs that are often bulky (RE48,794 E, col. 1:41-57). This bulk can prevent the use of adjacent electrical outlets, and plugs that are excessively long can be easily dislodged or damaged, particularly when located behind furniture (RE48,794 E, col. 1:48-57). The patent also notes the high cost and complexity of manufacturing plugs using insert-molded blades and hand-soldered connections (RE48,794 E, col. 1:58-col. 2:30).
- The Patented Solution: The invention is a charger plug with a housing and internal components specifically designed to achieve a compact size defined by specific dimensional limitations (RE48,794 E, Abstract). The design utilizes separate blade members that are slidably mounted into the housing and connect to the internal printed circuit board (PCB) via spring contacts, obviating the need for insert molding and soldering (RE48,794 E, col. 4:36-51, FIG. 3). This construction method, combined with a specific component layout, allegedly enables a charger that does not interfere with adjacent outlets (RE48,794 E, col. 13:46-54).
- Technical Importance: The invention provides a method for manufacturing smaller, less obtrusive, and potentially less expensive power adapters at a time of increasing proliferation of portable electronic devices requiring frequent charging. (Compl. ¶12).
Key Claims at a Glance
- The complaint asserts infringement of at least Claim 1. (Compl. ¶29).
- Independent Claim 1 requires:
- A charger plug for converting 120V input power to DC output power.
- First and second separate blade members with prong portions extending from a front wall of the housing.
- A DC connector with an aperture to receive a power cord plug.
- A housing with a charger plug face area, an outer profile, and a rear end.
- The housing being sized with a longitudinal length between the front wall and rear end of less than 2.0 inches, and a width of the housing outer profile being less than 1.75 inches.
- The 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, but infringement is alleged for "at least one claim." (Compl. ¶28).
III. The Accused Instrumentality
Product Identification
The "Energizer Dual USB Wall Charger" (the "Accused Product"), which is made, used, offered for sale, and sold by Defendant Premier Accessory Group LLC. (Compl. ¶18). A photograph of the Accused Product is provided in the complaint. (Compl. p. 7).
Functionality and Market Context
The complaint alleges the Accused Product is a charger that connects between an AC power source (like a wall outlet) and a device to be charged (like a mobile phone) via DC power (Compl. ¶19). A key accused functionality is its "reduced plug-size," which allegedly ensures that the charger "does not block or interfere with the use of adjacent outlets" (Compl. ¶20). The complaint also asserts that the size and shape allow for a power cord to be easily inserted and removed while the charger remains plugged into the wall (Compl. ¶21).
IV. Analysis of Infringement Allegations
The complaint references a claim chart in Exhibit 2, but this exhibit was not included with the filing. (Compl. ¶22). The infringement theory can be constructed from narrative allegations in the complaint body.
RE48,794 E Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A charger plug capable of connecting with a two or three receptacle power source to convert 120V input power received from the power source to DC output power... | The Accused Product is advertised and sold as a wall charger that connects between an AC power source and a device to be charged using DC power. | ¶19 | col. 13:18-23 |
| first and second separate blade members secured within the housing so as to have prong portions of the blade members positioned in order to extend in a first direction from a front wall of the housing... | The complaint provides a photograph showing the Accused Product with two prongs extending from its housing for insertion into a wall outlet. | p. 7 | col. 13:26-32 |
| being sized so that the charger plug housing comprises a longitudinal length extending between the front wall and the rear end and the longitudinal length is less than 2.0 inches, a width of the housing outer profile being less than 1.75 inches... | The complaint alleges the Accused Product has a longitudinal length of approximately 1.117 inches and a width of approximately 1.281 inches. | ¶24 | col. 13:49-54 |
| the 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... | The complaint alleges the Accused Product employs a "reduced plug-size charger plug" that "does not block or interfere with the use of adjacent outlets." | ¶20 | col. 13:55-col. 14:3 |
Identified Points of Contention
- Scope Questions: The complaint's infringement theory rests heavily on specific dimensional measurements. A potential point of contention will be the precise methodology for measuring the "longitudinal length" and "width of the housing outer profile." The parties may dispute which features of the housing are included in these measurements.
- Technical Questions: The functional limitation "having no interference with an adjacent receptacle" may raise factual questions. The analysis could turn on what constitutes "interference" under a proper claim construction and what evidence (e.g., testing with various standard outlet configurations) is required to prove this element is met.
V. Key Claim Terms for Construction
The Term: "outer profile"
- Context and Importance: This term is critical because it defines the boundaries for the claimed width dimension ("less than 1.75 inches") and is central to the functional limitation of avoiding "interference" with adjacent outlets. Practitioners may focus on this term because its definition—whether it includes only the main body of the housing or also protruding features—will directly impact the infringement analysis.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the "outer profile" in the context of the overall physical size that could impede access to other outlets, suggesting it refers to the maximum extent of the housing in any given dimension. (RE48,794 E, col. 13:51-57). The patent contrasts its compact design with prior art plugs that are physically obstructive.
- Evidence for a Narrower Interpretation: The claims and figures distinguish between the "housing" and the extending "prong portions." A defendant may argue that "outer profile" refers only to the housing body itself, exclusive of any other features. Figure 1 shows the main body (14) as the primary component defining the profile. (RE48,794 E, FIG. 1).
The Term: "no interference with an adjacent receptacle"
- Context and Importance: This is a functional, results-oriented limitation. Its construction will determine the standard of proof for infringement. Practitioners may focus on this term because its breadth is debatable: does it require no interference with any conceivable adjacent plug, or merely with a standard, similarly sized plug?
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language "located on all sides of the first receptacle when a like charger plug is mounted in all available orientations" suggests a demanding standard that requires non-interference in multiple configurations. (RE48,794 E, col. 13:55-col. 14:3).
- Evidence for a Narrower Interpretation: The specification discusses the problem in the context of common wall outlets and power strips. (RE48,794 E, col. 1:41-48). A defendant could argue the term should be limited to avoiding interference in standard, commercially prevalent NEMA 5-15R duplex or quad receptacles, not every possible configuration.
VI. Other Allegations
Willful Infringement
The complaint alleges that Defendant "knew or should have known" that its product infringes, based on the patent's "clear dimension, size and orientation requirements." (Compl. ¶25, ¶26). The prayer for relief seeks a determination of willful infringement and treble damages. (Compl. p. 10).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction and measurement: How is the "outer profile" of the charger housing measured for the purposes of the patent's specific dimensional limitations, and does the Accused Product fall within those dimensions under the court's determined methodology?
- A key evidentiary question will be one of functional performance: What is the scope of the term "no interference," and what factual evidence will be required to prove that the Accused Product meets this negative limitation across all claimed orientations in a standard power source?
- A third question, pertinent to damages, will be whether the asserted reissued claim is "substantially identical" to the original patent claim despite the narrowing amendments. This will determine if Plaintiff can recover damages for infringement that occurred prior to the reissue date of October 26, 2021.