DCT
1:22-cv-10167
Voltstar Tech Inc v. Adorama Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Voltstar Technologies, Inc. (Illinois)
- Defendant: Adorama Inc. (New York)
- Plaintiff’s Counsel: Sriplaw, PLLC.
- Case Identification: 1:22-cv-10167, S.D.N.Y., 12/01/2022
- Venue Allegations: Plaintiff alleges venue is proper because Defendant Adorama Inc. has committed acts of infringement and maintains a regular and established place of business in the Southern District of New York.
- Core Dispute: Plaintiff alleges that Defendant’s compact USB-C wall chargers infringe a reissue patent related to the specific size, shape, and construction of power adapter packaging.
- Technical Context: The technology concerns the design and manufacturing of small form-factor AC/DC power adapters, a market driven by consumer demand for portable and non-obtrusive charging accessories for mobile devices.
- 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 claim 1 to be more restrictive, changing a length limitation from "equal to or less than 2.0 inches" to strictly "less than 2.0 inches" and adding a new width limitation of "less than 1.75 inches." This amendment narrows the claim's scope and may have been made to distinguish the invention from prior art.
Case Timeline
| Date | Event |
|---|---|
| 2008-05-21 | Earliest Priority Date ('581 Patent Application Filing) |
| 2015-05-05 | U.S. Patent No. 9,024,581 Issued |
| 2018-12-04 | Reissue Application Filed for RE48,794 E |
| 2021-10-26 | U.S. Reissue Patent No. RE48,794 E Issued |
| 2022-12-01 | 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 describes significant issues with prior art power adapter plugs, namely that their size and shape often block the use of adjacent electrical outlets and their length can make them susceptible to damage or dislodging, particularly when used behind furniture (RE48,794 E, col. 1:42-59). The patent also notes that common manufacturing methods like insert-molding blades and hand-soldering connections were costly, time-consuming, and could lead to production waste (RE48,794 E, col. 2:1-27).
- The Patented Solution: The invention is a "reduced plug-size charger plug" with a specific housing construction and internal component layout designed to minimize its physical footprint and simplify manufacturing (RE48,794 E, Abstract). The design uses slidable blades that engage with internal spring contacts instead of being insert-molded, and a housing with specific dimensional limitations, which together allow for a more compact and easily assembled product (RE48,794 E, col. 2:11-23). An example of the plaintiff's charger is shown in the complaint (Compl. p. 3).
- Technical Importance: This design approach sought to meet market demand for smaller, more portable, and less obtrusive power adapters without compromising manufacturability or cost-effectiveness (RE48,794 E, col. 1:13-19).
Key Claims at a Glance
- The complaint asserts infringement of at least Claim 1 of the ’794 Patent (Compl. ¶46).
- Independent Claim 1 requires, in essence:
- A charger plug for converting 120V AC power to DC power.
- A housing containing first and second separate blade members (prongs).
- A DC connector (e.g., a USB port) to connect a power cord.
- A housing with a specific size, including a longitudinal length "less than 2.0 inches" and a "width of the housing outer profile being less than 1.75 inches."
- The housing's "outer profile" having "no interference with an adjacent receptacle."
- The complaint states Plaintiff "repeats, realleges, and incorporates by reference" all preceding paragraphs, which includes general infringement allegations, but only provides specific infringement analysis for Claim 1 (Compl. ¶44).
III. The Accused Instrumentality
Product Identification
- The complaint names three accused products: the "Gearpower Compact USB-C 20W Charger," the "Satechi 20W USB-C PD Wall Charger," and the "Satechi 30W USB-C GAN Wall Charger" (Compl. ¶18, 26, 35).
Functionality and Market Context
- The accused products are described as compact AC-to-DC power adapters designed to be plugged into a standard wall outlet to provide charging power to devices like mobile phones via a USB-C connection (Compl. ¶19, 27, 36). The complaint alleges that a key feature of these products is their "reduced plug-size," which is intended to prevent them from blocking or interfering with the use of adjacent outlets (Compl. ¶20, 28, 37). The complaint includes an image of the Gearpower charger, which shows a white, rectangular adapter with foldable prongs and a USB-C port (Compl. p. 5). It also includes similar images for the Satechi 20W charger (Compl. p. 7) and the Satechi 30W charger (Compl. p. 8).
IV. Analysis of Infringement Allegations
The complaint references claim chart exhibits that were not provided with the filed document (Compl. ¶22, 30, 39). However, the complaint body contains sufficient narrative allegations mapping features of the accused products to the elements of Claim 1 to construct the following representative summary for Accused Product #1.
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... to DC output power... | The Gearpower charger connects to a wall outlet to provide DC power for charging a mobile phone. | ¶19 | col. 13:17-24 |
| first and second separate blade members secured within the housing so as to have prong portions... | The accused product has two prongs for insertion into a wall outlet. This is depicted in an image of the Gearpower charger. | p. 5 | col. 13:25-31 |
| the charger plug including a DC connector having an aperture adapted to removably receive a corresponding power cord plug end... | The product has a USB-C port for connecting a power cord. | ¶19 | col. 13:32-36 |
| being sized so that the charger plug housing comprises a longitudinal length... less than 2.0 inches, a width of the housing outer profile being less than 1.75 inches... | The accused charger has an alleged longitudinal length of approximately 1.775 inches and a width of approximately 1.525 inches. | ¶24 | col. 13:46-51 |
| the outer profile having no interference with an adjacent receptacle of the power source... | Upon plugging the charger into a wall outlet, it "does not block or interfere with the use of adjacent outlets." | ¶20 | col. 13:52-59 |
| so that when space is limited... the power cord plug end can be conveniently removed from the DC connector while leaving the charger plug connected... | The size and shape of the charger are alleged to allow a power cord to be easily inserted and removed while the charger remains plugged in. | ¶21 | col. 14:1-9 |
- Identified Points of Contention:
- Scope Questions: A central question may be the proper construction of "no interference with an adjacent receptacle." The parties may dispute whether this requires zero physical contact with an adjacent standard plug, or whether it means only that the use of the adjacent outlet is not functionally impeded.
- Technical Questions: The infringement analysis will depend on factual evidence regarding the accused products' dimensions. A likely point of dispute is the precise methodology for measuring the "longitudinal length" and "width of the housing outer profile" and whether the Defendant's products, when measured appropriately, actually meet the specific dimensional limitations recited in the claim.
V. Key Claim Terms for Construction
The Term: "outer profile"
Context and Importance: The "less than 1.75 inches" width limitation of Claim 1 is measured on the "housing outer profile." The definition of this term is therefore critical to determining infringement, as the parties may dispute what features of the housing are included in the measurement. Practitioners may focus on this term because its ambiguity could be dispositive.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim describes the outer profile as being "defined by a perimeter of the front wall and defined by a plug body extending rearward" (RE48,794 E, col. 13:39-42). A party could argue this refers to the main, continuous body of the housing, potentially excluding small, non-continuous features like grips or seams.
- Evidence for a Narrower Interpretation: The figures generally depict a smooth, continuous housing shape (RE48,794 E, FIG. 1, 2A). A party could argue that "outer profile" should be construed as the maximum dimension at any point along the housing's body, consistent with the illustrated embodiments.
The Term: "no interference"
Context and Importance: This functional limitation is a cornerstone of the infringement allegation. Whether the accused products infringe may depend entirely on the legal standard set for "interference."
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The background section states that a goal is for the plug to provide "little or no interference with use of an adjacent receptacle" (RE48,794 E, col. 1:46-48). A plaintiff may argue that this supports a broad reading where any physical contact that makes using the adjacent outlet even slightly more difficult constitutes "interference."
- Evidence for a Narrower Interpretation: A defendant could argue that the term requires a material or functional obstruction of the adjacent outlet, not merely incidental physical contact. They might argue that if a standard plug can still be fully and safely inserted into the adjacent outlet, there is "no interference" as a matter of law.
VI. Other Allegations
- Indirect Infringement: The complaint does not contain a separate count for indirect infringement. However, it repeatedly alleges that Defendant "knew or should have known" that its products infringe Claim 1 (Compl. ¶25, 33, 42). While this allegation touches on the knowledge element for induced infringement, the complaint does not appear to plead specific facts regarding intent, such as alleging that Defendant's manuals or advertising instruct users in a manner that constitutes infringement.
- Willful Infringement: The prayer for relief seeks a determination that Defendant's infringement has been "willful, wanton, and deliberate" (Compl. p. 11, ¶C). The factual basis for this claim appears to rest on the "knew or should have known" allegations (Compl. ¶25, 33, 42). The complaint does not assert that Defendant had pre-suit knowledge of the patent, suggesting the willfulness claim may be predicated on post-filing conduct.
VII. Analyst’s Conclusion: Key Questions for the Case
This dispute appears to center on highly specific, fact-intensive infringement questions under a single patent claim. The outcome will likely depend on the court's resolution of two central issues:
A core issue will be one of measurement and fact: Do the accused chargers, when measured according to a proper methodology, actually possess a "longitudinal length" less than 2.0 inches and a "width of the housing outer profile" less than 1.75 inches as required by Claim 1?
A key legal and factual question will be one of functional scope: What is the proper construction of the term "no interference with an adjacent receptacle," and does the physical size and shape of the accused products meet that standard when plugged into a standard power outlet?