DCT
1:24-cv-03062
Voltstar Tech Inc v. Encased Products Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Voltstar Technologies, Inc. (Illinois)
- Defendant: Encased Products Inc (New York / New Jersey)
- Plaintiff’s Counsel: Sriplaw PLLC
- Case Identification: 1:24-cv-03062, E.D.N.Y., 04/24/2024
- Venue Allegations: Venue is alleged to be proper because Defendant has committed acts of infringement and is subject to personal jurisdiction in the district.
- Core Dispute: Plaintiff alleges that Defendant’s line of Galvanox compact wall chargers infringes a reissue patent directed to the dimensional and functional characteristics of power adapter packaging.
- Technical Context: The technology concerns the physical design of AC-to-DC power adapters, focusing on minimizing their size to prevent the obstruction of adjacent electrical outlets while simplifying manufacturing.
- Key Procedural History: The patent-in-suit, RE48,794, is a reissue of U.S. Patent No. 9,024,581. The complaint notes that the reissue process amended original Claim 1 to narrow the dimensional limitations of the charger housing, changing the longitudinal length 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 claim scope, which may be central to the infringement analysis.
Case Timeline
| Date | Event |
|---|---|
| 2008-05-21 | Priority Date for RE48,794 Patent (original application filing) |
| 2009-11-26 | Original patent application published |
| 2015-05-05 | U.S. Patent No. 9,024,581 Issues |
| 2021-10-26 | U.S. Reissue Patent No. RE48,794 E Issues |
| 2024-04-24 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
- 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 describes conventional charger plugs as often being too bulky, blocking adjacent wall outlets. It notes that prior art attempts to solve this by increasing the plug's length made the plugs protrude excessively, rendering them unstable and susceptible to being knocked out of the socket. The patent also identifies the high cost and complexity of manufacturing, particularly the processes of insert-molding electrical blades into the housing and then hand-soldering them to the internal circuitry. (’794 Patent, col. 1:42-2:12).
- The Patented Solution: The invention is a "reduced plug-size charger" with an improved mechanical design that simplifies assembly and reduces size. The design uses separate power blades that are slidably mounted into the housing, where they connect with spring contacts on the printed circuit board (PCB). This obviates the need for insert molding and direct soldering of the blades, which in turn allows for a more compact and cost-effective overall package that avoids obstructing nearby outlets. (’794 Patent, Abstract; col. 3:13-28).
- Technical Importance: This approach sought to resolve a persistent usability problem for consumers (obstructed outlets) while also addressing manufacturing cost and efficiency issues for producers of high-volume electronics accessories. (’794 Patent, col. 3:8-12).
- Key Claims at a Glance:
- The complaint asserts independent Claim 1. (Compl. ¶41).
- The essential elements of Claim 1 are:
- A charger plug for a standard power source.
- First and second separate blade members secured within a housing with prongs extending from a front wall.
- A DC connector to provide power to a rechargeable device via a power cord.
- A housing with specific sizing: a longitudinal length of less than 2.0 inches and a width of less than 1.75 inches.
- An outer profile that has "no interference with an adjacent receptacle" when plugged in.
- The complaint alleges infringement of "at least one claim," preserving the right to assert others. (Compl. ¶40).
III. The Accused Instrumentality
- Product Identification: The accused products are the "Galvanox Travel Charger," "Galvanox 20W Fast Charger," and "Galvanox 18W iPhone PD Charger." (Compl. ¶¶ 18, 25, 32).
- Functionality and Market Context: The accused products are AC-to-DC power adapters sold for charging portable electronic devices such as mobile phones. (Compl. ¶¶ 19, 26, 33). The complaint alleges their key feature is a "reduced plug-size" design which, upon being plugged into a wall outlet, does not block or interfere with the use of adjacent outlets. (Compl. ¶¶ 20, 27, 34). A visual provided in the complaint depicts the "Galvanox 20W Fast Charger" plugged into the top position of a duplex wall outlet, with the bottom outlet remaining unobstructed. (Compl. p. 7). The complaint also asserts that power cords can be inserted and removed from the accused chargers without needing to unplug the charger from the wall. (Compl. ¶¶ 21, 28, 35).
IV. Analysis of Infringement Allegations
Although the complaint references claim chart exhibits that were not attached to the filing, it provides narrative allegations for each accused product that map directly to the elements of Claim 1.
’794 Patent 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 accused products are described as chargers that connect to an AC power source, such as a wall outlet, to provide DC power for recharging a mobile phone. (Compl. ¶¶ 19, 26, 33). | ¶19, ¶26, ¶33 | col. 13:20-24 |
| first and second separate blade members secured within the housing... | The complaint does not provide sufficient detail for analysis of the internal construction of the accused products. | N/A | col. 4:37-39 |
| the charger plug including a DC connector having an aperture adapted to removably receive a corresponding power cord plug end... | The accused products are alleged to have a size and shape allowing a power cord to be easily inserted and removed while the charger is plugged in. Visuals show USB-C style ports. (Compl. p. 7). | ¶21, ¶28, ¶35 | col. 13:29-34 |
| 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 provides specific measurements for each accused product, alleging all fall within the claimed dimensional limitations (e.g., the Travel Charger is alleged to be ~1.981" long and ~1.722" wide). (Compl. ¶¶ 24, 31, 38). | ¶24, ¶31, ¶38 | col. 14:4-10 |
| 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 that the accused chargers do not block or interfere with adjacent outlets. (Compl. ¶¶ 20, 27, 34). A visual depicts the 'Galvanox 18W iPhone PD Charger' plugged into an outlet, leaving the adjacent outlet clear. (Compl. p. 8). | ¶20, ¶27, ¶34 | col. 12:10-15 |
Identified Points of Contention
- Technical Questions: A primary dispute may concern the specific measurements of the accused products. The complaint uses "approximately" when listing dimensions (e.g., Compl. ¶24), which suggests that the exact methodology for measuring the "longitudinal length" and "width" of the irregularly shaped chargers will be a point of factual contention.
- Scope Questions: The infringement case, as pled, rests on the external dimensions and functionality of the accused chargers. It does not provide any allegations regarding the internal construction. A key question for discovery will be whether the accused products meet the claim limitation requiring "first and second separate blade members secured within the housing," as this internal structure is a core element of the described invention. (’794 Patent, col. 13:25-26).
V. Key Claim Terms for Construction
The Term: "a longitudinal length... [and] a width of the housing outer profile"
- Context and Importance: Infringement of the reissue claim’s key limitation, section (i), is entirely dependent on the definition and measurement protocol for these terms. The complaint’s reliance on specific numerical values (e.g., "1.981 inches") makes the construction of these terms dispositive for the infringement analysis.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue for a definition based on the maximum extent of the housing along the primary axes, which is a common practice for dimensional measurements.
- Evidence for a Narrower Interpretation: The specification provides preferred, exemplary dimensions ("preferably approximately 1.75 inches" for length and "preferably approximately 1.35 inches" for width), which could be used to argue that the terms imply a compact form factor consistent with these examples. (’794 Patent, col. 14:4-8). Figures such as FIG. 15 include reference lines (150, 154) that may be argued to define the precise boundaries for these measurements.
The Term: "no interference with an adjacent receptacle"
- Context and Importance: This functional language in section (ii) of the limitation is open to interpretation. The definition of "interference" will determine whether the accused products infringe this element. Practitioners may focus on this term because it links the physical shape of the device to its real-world function in a crowded outlet.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A plaintiff may argue "no interference" means the charger housing cannot physically overlap any portion of the adjacent outlet's faceplate, as depicted in the complaint’s photographic examples. (Compl. pp. 5, 7, 8).
- Evidence for a Narrower Interpretation: A defendant may argue that "interference" should be defined more narrowly to mean only preventing the functional insertion and use of a standard plug in the adjacent outlet, even if the charger housing slightly overlaps the faceplate. The claim language "when a like charger plug is mounted in all available orientations in any of the other receptacles" may support a functional, rather than purely spatial, test of interference. (’794 Patent, col. 14:1-2).
VI. Other Allegations
Willful Infringement
- The complaint's prayer for relief seeks a determination that infringement was "willful, wanton, and deliberate" and asks for enhanced damages. (Compl. Prayer for Relief ¶C). The body of the complaint, however, does not plead a specific factual basis for willfulness, such as allegations of pre-suit knowledge of the patent.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of measurement and proof: Can the plaintiff prove, through discovery and expert testimony, that the accused products meet the precise dimensional limitations of "less than 2.0 inches" in length and "less than 1.75 inches" in width, particularly given the complaint’s use of approximate values?
- A second central question will be one of internal structure: As the complaint focuses on external characteristics, a key evidentiary burden for the plaintiff will be to demonstrate that the accused products’ internal assembly meets the structural limitations of Claim 1, such as the use of "separate blade members" connected via a non-molded, non-soldered mechanism, which is a key distinguishing feature described in the patent.
- Finally, the case may turn on a question of functional scope: How will the court construe the term "no interference with an adjacent receptacle"? The outcome will depend on whether this is interpreted as a strict prohibition on any physical overlap with the adjacent outlet’s faceplate or a more lenient standard that only prohibits the functional obstruction of a second plug.