Voltstar Tech Inc v. LAX Gadgets Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Voltstar Technologies, Inc. (Illinois)
  • Defendant: LAX Gadgets, Inc. (New York)
  • Plaintiff’s Counsel: Sriplaw PLLC
• Case Identification: Voltstar Tech Inc v. LAX Gadgets Inc, 1:23-cv-09133, E.D.N.Y., 12/13/2023
• Venue Allegations: Plaintiff alleges venue is proper as Defendant has committed acts of infringement in the district and is subject to personal jurisdiction there.
• Core Dispute: Plaintiff alleges that Defendant’s compact wall charger infringes a reissue patent related to the dimensional and functional characteristics of small form-factor power adapters.
• Technical Context: The technology concerns the design of AC-to-DC power converters, commonly known as chargers, aiming to reduce their physical size to prevent the obstruction of adjacent electrical outlets.
• 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 the reissue process amended original Claim 1 to add a specific width limitation ("less than 1.75 inches"), thereby narrowing the claim scope. The complaint asserts that the reissued claim is "substantially identical" to the original, which may be relevant to the calculation of damages.

Case Timeline

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 identifies issues with prior art charger plugs, noting they are often bulky and block adjacent electrical outlets. It also describes manufacturing challenges, such as the time and cost associated with "insert molding" the electrical blades into the plastic housing and the manual soldering required to connect them to internal circuitry. (’794 Patent, col. 1:42-48, col. 2:1-24).
• The Patented Solution: The invention discloses a compact charger plug designed for improved manufacturability and a smaller physical footprint. The design utilizes a housing, typically a two-part clamshell, that slidably receives separate electrical blades. These blades connect to the internal printed circuit board (PCB) via solder-less spring contacts, which are biased to maintain a secure electrical connection. (’794 Patent, Abstract; col. 3:14-27). This construction method is described as simpler and less costly than prior art techniques and allows for a design that does not obstruct nearby outlets. An example of a charger embodying the invention is depicted in the complaint. (Compl. ¶11).
• Technical Importance: This approach sought to reduce manufacturing costs while addressing a common consumer frustration: the inability to use multiple outlets simultaneously due to oversized power adapters. (’794 Patent, col. 1:42-48).

Key Claims at a Glance

• The complaint asserts infringement of at least independent Claim 1. (Compl. ¶26).
• The essential elements of independent Claim 1 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.
  • A DC connector with an aperture for a power cord.
  • The housing has a face area, an outer profile, and a rear end.
  • The housing is sized with a longitudinal length less than 2.0 inches and a width of the outer profile less than 1.75 inches.
  • The outer profile has "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 does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• "20W Dual Port Fast Travel Wall Charger" ("Fast Travel Wall Charger"). (Compl. ¶17).

Functionality and Market Context

• The complaint describes the accused product as a charger used to connect an AC power source, such as a wall outlet, to a device with a rechargeable battery. (Compl. ¶18). A central allegation is that the product employs a "reduced plug-size" design which "does not block or interfere with the use of adjacent outlets." (Compl. ¶19). An image of the accused product is included in the complaint. (Compl. ¶17, p. 5). The complaint also alleges that the charger's design allows for easy connection and disconnection of a power cord without removing the charger from the wall. (Compl. ¶20).

IV. Analysis of Infringement Allegations

Although the complaint refers to a claim chart in an exhibit that was not provided, the following table summarizes the infringement theory based on narrative allegations in the complaint body.

RE48,794 E Infringement Allegations

Identified Points of Contention

• Scope Questions: Claim 1 requires the "outer profile" to have "no interference" with an adjacent receptacle "on all sides" and in "all available orientations." A central question will be how the court defines "interference." The absolute nature of the term "no interference" may create a high evidentiary bar for the plaintiff, as any documented instance of physical contact or obstruction with a standard plug could potentially defeat a literal infringement claim.
• Technical Questions: The complaint alleges specific dimensions for the accused product. (Compl. ¶23). A factual dispute may arise regarding the methodology of these measurements and whether they accurately represent all units of the accused product. Proving the negative limitation of "no interference" under all possible orientations in a standard duplex or quad outlet will likely require physical testing, simulations, or expert testimony, which is not present in the complaint itself.

V. Key Claim Terms for Construction

• The Term: "outer profile"

• Context and Importance: This term is critical to infringement as it defines the boundary for both the dimensional limitations (width less than 1.75 inches) and the functional limitation ("no interference"). The case may turn on how this profile is measured and what features of the housing it encompasses.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification does not provide an explicit definition, which may support adopting its plain and ordinary meaning. The term is used to define the overall shape and size of the plug body that extends rearward from the wall. (’794 Patent, col. 13:40-44).
  • Evidence for a Narrower Interpretation: The figures consistently depict a specific rounded, ovoid, or "squared-off circle" shape. (e.g., ’794 Patent, Figs. 1, 2A; col. 13:60-64). A party may argue that the "outer profile" is implicitly limited by these embodiments rather than encompassing any arbitrary shape that meets the dimensional constraints.

• The Term: "no interference"

• Context and Importance: This functional limitation is a cornerstone of Claim 1. The definition of what constitutes "interference" will be dispositive. Practitioners may focus on this term because its absolute language ("no") presents a clear line for infringement but also a significant proof challenge.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent's background contrasts the invention with prior art plugs that create "interference with use of an adjacent receptacle." (’794 Patent, col. 1:45-48). This context suggests "interference" means the inability to use an adjacent outlet, allowing for incidental physical contact that does not prevent a standard plug from being inserted and used.
  • Evidence for a Narrower Interpretation: The claim uses the absolute term "no" rather than "little" or "reduced." A party could argue this requires a complete absence of physical contact or obstruction between the accused charger's housing and any part of a standard plug being inserted into an adjacent outlet, a very strict standard.

VI. Other Allegations

• Willful Infringement: The complaint's prayer for relief seeks a finding of willful infringement and treble damages. (Compl., p. 7, ¶C). However, the complaint does not allege specific facts supporting pre-suit knowledge of the ’794 Patent by the Defendant, which is typically a predicate for a pre-suit willfulness claim.

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

• A central issue will be one of evidentiary proof: can Plaintiff provide factual evidence, likely through testing and expert analysis, demonstrating that the accused charger’s "outer profile" meets not only the precise dimensional limitations of Claim 1 but also the functional requirement of causing "no interference" with adjacent outlets under all specified conditions?
• The case will also turn on a question of claim construction: how will the court define the scope of the terms "outer profile" and "no interference"? The resolution of whether "no interference" means an absolute lack of physical contact or merely the absence of functional obstruction will be critical in determining infringement.