DCT

2:22-cv-05808

Rivera v. Powrui LLC

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:22-cv-05808, E.D.N.Y., 09/29/2022
  • Venue Allegations: Venue is alleged to be proper as a substantial portion of the events giving rise to the claims, including the shipment of accused products to an address within the district, occurred there.
  • Core Dispute: Plaintiff alleges that Defendant’s multipurpose wall outlets, which include USB charging ports, infringe a patent related to power conversion circuitry within such devices.
  • Technical Context: The technology concerns electrical wall outlets that integrate AC-to-DC power converters and "smart" chips to manage power delivery to various outputs, such as standard receptacles and USB ports.
  • Key Procedural History: The complaint states that Plaintiff sent a cease-and-desist letter, which included a claim chart, to Defendants on February 23, 2022, placing Defendants on notice of the patent. Defendants subsequently denied infringement in correspondence.

Case Timeline

Date Event
2016-08-25 '640 Patent Priority Date
2020-05-05 '640 Patent Issue Date
2022-02-23 Plaintiff sends cease-and-desist letter to Defendant
2022-09-29 Complaint Filing Date

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

U.S. Patent No. 10,644,640 - Multipurpose Wall Outlet, Issued May 5, 2020

The Invention Explained

  • Problem Addressed: The complaint does not explicitly state a technical problem in a background section, but it describes the relevant field as "next generation technology 'smart' wall chargers" that consolidate multiple functions into a single device (Compl. ¶15). This suggests the patent addresses the need for integrated wall outlets that can power and charge a variety of modern electronic devices.
  • The Patented Solution: As described in the complaint, the patented invention is a multipurpose wall outlet containing a "smart chip" that converts AC power from a building's electrical system into DC power (Compl. ¶¶23, 28). This DC power is then distributed to various components, such as USB ports and a nightlight (Compl. ¶29). A diagram in the complaint illustrates this primary function, showing AC input from "building electricity" being converted by a "power chip voltage regulator" to "all DC (output)" for the device's features (Compl. p. 7). The invention also claims a "vice versa" capability, which the complaint alleges refers to the device's ability to receive AC power through its front-facing external plug and convert it to DC power for its other components (Compl. ¶¶30-32).
  • Technical Importance: The technology consolidates AC power distribution, DC power conversion, and USB charging capabilities into a standard wall outlet form factor, reflecting a trend toward integrated power solutions for consumer electronics (Compl. ¶15).

Key Claims at a Glance

  • The complaint asserts at least independent Claim 1 (Compl. ¶24).
  • The essential elements of Claim 1, as quoted in the complaint, include:
    • A multipurpose wall outlet comprising a smart chip, a passivated bridge, and a voltage controller.
    • The capability to "convert the electric power from the power source into a direct current (DC) and vice versa using the smart chip."
    • The passivated bridge "bridges the DC current to the voltage controller that divides the current into a negative and a positive components."
    • The divided current is "distributed to a plurality components of the circuit board and to the at least one electrical outlet."

III. The Accused Instrumentality

Product Identification

  • The primary accused product is the "Powrui LLC Smart USB Wall Outlet, 15A Duplex Receptacle with Dual USB Ports (5V/4.2A) (Product # B07T5CD2P1)" (Compl. ¶22). The complaint also lists several other multi-plug outlet and surge protector models sold by Defendants (Compl. ¶14).

Functionality and Market Context

  • The accused products are wall-mounted electrical outlets that provide standard AC receptacles alongside integrated USB charging ports and, in some cases, a nightlight (Compl. ¶¶14, 22). The complaint alleges these products contain "smart chips" (specifically, CX 2901 IS IC Linear Voltage Regulators) and a "glass passivated bridge rectifier" (part number ABS-210) to manage power conversion (Compl. ¶¶23, 26). A central allegation is that the products can be powered "vice versa" by receiving AC current through their own front-facing plugs to power the integrated USB ports and nightlight, a function Plaintiff allegedly tested and documented (Compl. ¶¶31-35). A photograph provided in the complaint shows the accused device operating in this manner, with its nightlight illuminated while receiving power only from its front plug (Compl. p. 8, ¶35).

IV. Analysis of Infringement Allegations

'640 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
convert the electric power from the power source into a direct current (DC) and vice versa using the smart chip The accused product allegedly uses a "smart chip" (CX 2901 IS IC Linear Voltage Regulator) to convert AC to DC. The "vice versa" function is allegedly met by the product's ability to receive AC power from its own front-facing plug and convert it to DC to power its USB ports and nightlight, as shown in a complaint diagram (p. 7). ¶¶23, 31-32, 38 The provided patent document (U.S. 10,644,640 B2, 'Kleinknecht') does not teach this limitation; its subject matter relates to heating brushless DC motors.
wherein the passivated bridge bridges the DC current to the voltage controller The accused product allegedly utilizes a "glass passivated bridge rectifier" (part number ABS-210) that corresponds to the claimed "passivated bridge" and a voltage controller. ¶¶23, 26 The provided patent document does not teach this limitation.
that divides the current into a negative and a positive components which are distributed to a plurality components of the circuit board and to the at least one electrical outlet The converted DC current is allegedly distributed to the USB ports, nightlight, and external-facing power plug. The complaint diagrams this distribution (p. 7). ¶¶24, 29 The provided patent document does not teach this limitation.
  • Identified Points of Contention:
    • Scope Questions: The complaint explicitly identifies the interpretation of "vice versa" as a point of contention (Compl. ¶24). The infringement case appears to hinge on whether Plaintiff's proposed construction—meaning the ability to accept power from an alternate input path (the front plug) and reverse the internal power flow—is adopted by the court.
    • Technical Questions: A key evidentiary question will be whether the specific components identified in the complaint (the CX 2901 regulator and ABS-210 rectifier) can be proven to perform the functions recited in the claim and operate in the manner required by the claim's "passivated bridge" and "voltage controller" limitations (Compl. ¶¶23, 26).

V. Key Claim Terms for Construction

  • The Term: "vice versa"
  • Context and Importance: Practitioners may focus on this term because its construction is presented as the central disagreement between the parties and is critical to Plaintiff's infringement theory (Compl. ¶¶24-26). Plaintiff’s entire argument for infringement of this limitation rests on construing "vice versa" to mean "the other way around" in a directional sense, referring to an alternative electrical input path (Compl. ¶¶26, 31).
  • Intrinsic Evidence for Interpretation: The provided patent document, which concerns a method for heating brushless DC motors, does not contain the asserted claims or the term "vice versa" in a relevant context. Therefore, no intrinsic evidence from the provided patent can be analyzed to support a broader or narrower interpretation of this term as it relates to the allegations in the complaint.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement, stating that Defendants make, sell, and import the products (Compl. ¶55). The basis for inducement appears to be that the products are marketed as chargers, and their intended and advertised use (e.g., to "detect your devices automatically and deliver the fastest charge speed") allegedly causes infringement (Compl. ¶37).
  • Willful Infringement: The complaint alleges willful infringement based on Defendants’ alleged knowledge of the ’460 patent since at least February 23, 2022, the date Plaintiff sent a cease-and-desist letter (Compl. ¶¶19, 20, 56).

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

  • A core issue will be one of claim construction: Can the term "vice versa," as used in the asserted patent, be properly construed to mean receiving and converting power from an alternate physical input, as Plaintiff alleges, or does it carry a different technical meaning that would not be met by the accused product's functionality?
  • A key evidentiary question will be one of technical proof: Assuming Plaintiff's claim construction is adopted, what is the factual evidence that the accused product's circuitry—specifically the identified voltage regulator and bridge rectifier—performs the exact functions of the "smart chip," "passivated bridge," and "voltage controller" as defined by the full language of the claim?