DCT
2:25-cv-02322
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 as Defendant is a New Jersey limited liability company with its principal place of business in the district.
- Core Dispute: Plaintiff alleges that Defendant’s Xtech GaN 33w Smart Fast Charger infringes a reissue patent related to the compact physical design and specific dimensions of electrical charger housings.
- Technical Context: The technology concerns the mechanical packaging of AC-to-DC power converters, aiming to reduce their physical footprint to prevent the obstruction of 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. The complaint notes that the reissue process amended the original patent's Claim 1 to be more dimensionally restrictive, changing a length limitation from "equal to or less than 2.0 inches" to "less than 2.0 inches" and adding a new width limitation of "less than 1.75 inches." This amendment narrows the asserted claim scope from the original patent.
Case Timeline
| Date | Event |
|---|---|
| 2008-05-21 | Priority Date (RE48,794 E Patent) |
| 2015-05-05 | U.S. Patent No. 9,024,581 Issued |
| 2021-10-26 | U.S. Reissue Patent No. RE48,794 E Issued |
| 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"
- Patent Identification: 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 section describes technical problems with prior art electrical chargers, including their physical bulk, which causes them to interfere with the use of adjacent electrical outlets, and their complex, costly manufacturing processes involving insert molding of electrical blades and manual soldering of internal components (RE48,794 E Patent, col. 1:42-49; col. 2:1-24).
- The Patented Solution: The invention claims to solve these problems through an improved mechanical package for the charger. The design features a multi-part housing and solder-less spring contacts that connect to slidably inserted blades, a construction intended to simplify assembly, reduce manufacturing costs, and enable a smaller overall product size (RE48,794 E Patent, col. 3:14-28). The patent emphasizes specific dimensional limitations and a shape that avoids obstructing other outlets (RE48,794 E Patent, col. 14:46-59).
- Technical Importance: This approach seeks to provide a charger that is not only less expensive to manufacture but is also more convenient for the end-user by virtue of its compact physical form factor (RE48,794 E Patent, col. 1:15-19).
Key Claims at a Glance
- The complaint asserts infringement of at least independent Claim 1 (Compl. ¶23).
- The essential elements of Claim 1 of the ’794 Patent are:
- A charger plug for converting 120V input power to DC output power.
- A housing containing first and second separate blade members with prong portions extending from a front wall.
- A DC connector for a removable power cord.
- A housing that forms a "charger plug face area" and an "outer profile."
- The housing is sized such that its "longitudinal length" is "less than 2.0 inches" and the "width of the housing outer profile" is "less than 1.75 inches."
- The "outer profile" has "no interference with an adjacent receptacle of the power source located on all sides... when a like charger plug is mounted in all available orientations in any of the other receptacles."
III. The Accused Instrumentality
Product Identification
- The accused product is 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 convert AC power from a wall outlet to DC power for devices like mobile phones (Compl. ¶15).
- The core accused functionality is the product's physical design. It is alleged to be a "reduced plug-size charger" that, when plugged into a wall outlet, "does not block or interfere with the use of adjacent outlets" (Compl. ¶16). The complaint alleges specific dimensions for the product: an approximate longitudinal length of 1.338 inches and a width of 1.238 inches (Compl. ¶20).
- The complaint provides an image of the accused Xtech 33W, depicting a black, rectangular wall charger with two prongs (Compl. p. 5).
IV. Analysis of Infringement Allegations
The complaint references a claim chart in an exhibit that was not provided; the following summary is based on the narrative allegations.
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... | The Xtech 33W is a charger for connecting to an AC power source, such as a wall outlet, to provide DC power to a mobile device. | ¶15 | col. 13:18-24 |
| 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 Xtech 33W is alleged to have a longitudinal length of approximately 1.338 inches and a width of approximately 1.238 inches. | ¶20 | col. 14:46-51 |
| 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 Xtech 33W allegedly "does not block or interfere with the use of adjacent outlets." | ¶16 | col. 14:52-59 |
- Identified Points of Contention:
- Scope Questions: A central issue may be the proper construction of "outer profile." The method of measuring the "width of the housing outer profile" will be critical to determining if the accused product meets the "less than 1.75 inches" limitation. The meaning of "no interference" also presents a scope question: does it require absolute avoidance of any physical contact with an adjacent plug, or does it mean only that the adjacent outlet remains functionally usable?
- Technical Questions: What evidence does the complaint provide to support the allegation of "no interference"? The claim requires this to be true for a "like charger plug" in "all available orientations," which suggests a complex testing requirement. The complaint's allegation is conclusory and does not appear to be supported by specific test data or diagrams within the document.
V. Key Claim Terms for Construction
The Term: "outer profile"
Context and Importance: This term is central to two limitations in Claim 1: the dimensional requirement for the "width of the housing outer profile" and the functional requirement that the "outer profile" causes "no interference." Practitioners may focus on this term because infringement of the reissue patent's key dimensional limitation depends entirely on how this profile is defined and measured.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not explicitly define "outer profile," which may support giving it a broad, plain, and ordinary meaning that encompasses the overall perimeter or footprint of the charger body as viewed from the front (RE48,794 E Patent, col. 13:41-43).
- Evidence for a Narrower Interpretation: A party might argue the term refers to a specific portion of the main housing, potentially excluding features like tapered edges or radiused corners, based on the patent's figures (RE48,794 E Patent, Fig. 1, Fig. 15). The specification also distinguishes the "outer profile" from the "charger plug face area," suggesting it is more than just the front surface (RE48,794 E Patent, col. 13:38-43).
The Term: "no interference"
Context and Importance: This negative functional limitation is a core element of the invention's purported benefit. Its interpretation will establish the standard of proof required to show infringement.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation (stricter for infringement): The claim's use of the absolute term "no" could support a strict interpretation requiring a complete lack of physical contact between the accused charger and an adjacent "like charger plug" in any orientation (RE48,794 E Patent, col. 14:52).
- Evidence for a Narrower Interpretation (less strict for infringement): The patent's background section describes the problem as plugs that provide "little or no interference with use of an adjacent receptacle," which could support construing "no interference" to mean that an adjacent outlet remains fully functional and usable, even if incidental physical contact occurs (RE48,794 E Patent, col. 1:45-47).
VI. Other Allegations
- Willful Infringement: The complaint's prayer for relief requests a determination that Defendant's infringement has been "willful, wanton, and deliberate" (Compl. p. 7, ¶C). The factual allegations in the body of the complaint, however, do not specify a basis for this claim, such as alleged pre-suit knowledge of the patent or a prior offer to license.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "outer profile," which is not explicitly defined in the patent, be construed in a way that brings the accused product’s measured width of approximately 1.238 inches within the scope of the claim language, and how will that definition impact the "no interference" analysis?
- A key evidentiary question will be one of demonstrating a negative limitation: what type of evidence will be required to prove that the accused charger causes "no interference" with a "like charger plug" in "all available orientations"? The resolution of this may depend on whether the court requires empirical testing data or accepts descriptive evidence of the product's compact nature.