DCT
4:24-cv-00668
Voltstar Tech Inc v. Samsung Electronics America Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Voltstar Technologies, Inc. (Illinois)
- Defendant: Samsung Electronics America, Inc. (New York)
- Plaintiff’s Counsel: Sriplaw, PLLC.
- Case Identification: 4:24-cv-00668, E.D. Tex., 07/23/2024
- Venue Allegations: Venue is alleged based on Defendant’s commission of infringing acts and its maintenance of a regular and established place of business within the Eastern District of Texas.
- Core Dispute: Plaintiff alleges that Defendant’s wall chargers and wireless chargers infringe patents related to the physical dimensions of charger housings and energy-saving circuitry that reduces "phantom load."
- Technical Context: The technology concerns the design of external power adapters for consumer electronics, focusing on compact form factors that do not obstruct adjacent wall outlets and internal circuitry to automatically cease power draw when not in use.
- Key Procedural History: The complaint asserts U.S. Patent No. RE48,794, which is a reissue of U.S. Patent No. 9,024,581, with amended claim language to further limit the claimed dimensions of the charger housing. U.S. Patent Nos. 7,910,833 and 7,960,648 have undergone post-grant proceedings, including Inter Partes Reexamination and Inter Partes Review, resulting in the disclaimer, cancellation, or amendment of numerous claims. The survival of the asserted claims through these proceedings may be presented by the Plaintiff to suggest their validity.
Case Timeline
| Date | Event |
|---|---|
| 2008-05-21 | Priority Date for U.S. Patent No. RE48,794 E |
| 2008-05-27 | Priority Date for U.S. Patent No. 7,910,833 and U.S. Patent No. 7,960,648 |
| 2011-03-22 | Issue Date for U.S. Patent No. 7,910,833 |
| 2011-06-14 | Issue Date for U.S. Patent No. 7,960,648 |
| 2015-05-05 | Issue Date for U.S. Patent No. 9,024,581 (original of RE48,794 E) |
| 2017-09-26 | Disclaimer of claims 1-3, 6-10, and 56-58 of U.S. Patent No. 7,910,833 published |
| 2017-11-03 | Inter Partes Reexamination Certificate (C1) issued for U.S. Patent No. 7,910,833 |
| 2021-10-26 | Issue Date for U.S. Reissue Patent No. RE48,794 E |
| 2022-01-21 | Inter Partes Review Certificate (K1) issued for U.S. Patent No. 7,910,833 |
| 2024-07-23 | Complaint Filing Date |
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 addresses issues with prior art power adapter plugs, which are often bulky and can block adjacent electrical outlets, or have an increased length that makes them protrude inconveniently from the wall (Compl. ¶11; ’794 Patent, col. 1:41-57). The patent also notes the high cost and complexity of manufacturing prior art plugs, which often require insert molding and manual soldering of components (’794 Patent, col. 2:1-32).
- The Patented Solution: The invention proposes a charger with a reduced physical size and a specific construction that simplifies assembly. The solution involves using slidably mounted blades and spring contacts to connect the external prongs to the internal printed circuit board (PCB), which obviates the need for insert molding and soldering, thereby reducing size and cost (’794 Patent, Abstract; col. 3:1-12). The complaint focuses on the resulting compact dimensions that prevent interference with adjacent outlets (Compl. ¶11).
- Technical Importance: This design approach enables the creation of smaller, less expensive, and more user-friendly power adapters in a market where device portability and convenience are paramount (’794 Patent, col. 2:45-49).
Key Claims at a Glance
- The complaint asserts independent Claim 1 (Compl. ¶40).
- Key elements of Claim 1 include:
- A charger plug for converting 120V input power to DC output power.
- A housing containing separate blade members with prong portions.
- A DC connector for a power cord.
- The housing being sized so its longitudinal length is less than 2.0 inches and the width of its outer profile is less than 1.75 inches.
- The outer profile having no interference with an adjacent receptacle.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 7,910,833 - Energy-Saving Power Adapter/Charger
Issued: March 22, 2011
The Invention Explained
- Problem Addressed: The patent addresses the problem of "phantom load," which is the residual power consumed by chargers and power adapters even when the connected electronic device is fully charged, shut off, or disconnected entirely (’833 Patent, col. 2:1-4). This continuous power draw is described as wasteful and environmentally impactful (’833 Patent, col. 2:5-12).
- The Patented Solution: The invention is a power device with internal circuitry that automatically cuts power to the charger when it detects that the connected electronic device is no longer drawing power (’833 Patent, Abstract). The patent describes several methods for detecting this state, including a "load sensing device" that can monitor power draw by measuring the width and frequency of electrical pulses within the circuitry, rather than just voltage or current levels (’833 Patent, col. 9:16-35).
- Technical Importance: This technology allows a charger to enter a true "zero-energy" state, significantly reducing wasted electricity compared to conventional chargers that continuously draw power when plugged in (’833 Patent, col. 2:55-60).
Key Claims at a Glance
- The complaint asserts independent Claims 24, 33, and 36 (Compl. ¶45).
- Key elements of Claim 24 (as amended by the C1 Reexamination Certificate) include:
- A power device for supplying power to an electronic device.
- Power circuitry for converting input voltage to output voltage.
- Switching circuitry to activate the power circuitry to an "on" state.
- A load sensing portion operable to sense one or more pulses.
- The load sensing portion determines the power or load being drawn by measuring the frequency of the pulses.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 7,960,648 - Energy Saving Cable Assemblies
Issued: June 14, 2011
- Technology Synopsis: As a continuation of the '833 patent, this invention also targets "phantom load" in chargers (Compl. ¶21). It discloses a cable assembly with integrated switch circuitry that recognizes the "on" and "off" states of a connected device (e.g., a laptop connected via USB) and automatically disconnects power from the wall outlet when the device is off or not drawing power, thereby consuming substantially no power (’648 Patent, Abstract; col. 5:26-40).
- Asserted Claims: The complaint asserts Claims 31, 32, and 39, which were amended during Inter Partes Reexamination (Compl. ¶50; ’648 Patent C1 Certificate).
- Accused Features: The complaint alleges that the "internal monitoring and switch circuitry features" of the Samsung Super Fast Wireless Charger infringe the ’648 Patent (Compl. ¶35, ¶49-50).
III. The Accused Instrumentality
Product Identification
The complaint identifies two accused product lines: the "25 W Super Fast Wall Charger" and the "Super Fast Wireless Charger" (Compl. ¶22, ¶29).
Functionality and Market Context
- The 25 W Super Fast Wall Charger is a wired AC-to-DC power adapter for charging mobile devices like phones (Compl. ¶23). The complaint alleges it employs a "reduced plug-size" design such that it "does not block or interfere with the use of adjacent outlets" (Compl. ¶24). An image of the accused wall charger is provided in the complaint. (Compl. p. 6).
- The Super Fast Wireless Charger is a Qi-compliant wireless charging pad and accompanying power adapter (Compl. ¶30). It is alleged to contain "internal monitoring circuitry to detect when a mobile electronic device requires charging or is fully charged" (Compl. ¶34). The complaint specifically alleges this circuitry "senses the frequency of pulses rather than sensing the magnitude of a voltage and/or current, to determine the load being drawn, and to determine an 'off' state for the device" (Compl. ¶34). Images of the accused wireless charger and its packaging are included. (Compl. p. 8).
- The complaint asserts that Samsung makes, uses, offers for sale, and sells these products in the United States, but provides no further detail on their specific market positioning (Compl. ¶22, ¶29).
IV. Analysis of Infringement 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 received from the power source to DC output power... | The Super Fast Wall Charger is a charger connected between an AC power source (wall outlet) and a device (mobile phone) to provide DC power. | ¶23 | col. 13:16-21 |
| 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 Super Fast Wall Charger has an alleged longitudinal length of "approximately 1.996 inches" and a width of "approximately 1.626 inches." | ¶28 | col. 14:46-50 |
| the outer profile having no interference with an adjacent receptacle of the power source... | The complaint alleges that upon plugging the charger into a wall outlet, it "does not block or interfere with the use of adjacent outlets." | ¶24 | col. 14:51-56 |
| 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 to the receptacle. | The complaint alleges that a power cord can be easily inserted and removed while the charger is plugged in, and removal of the cord can be done without removing the charger from the outlet. | ¶25 | col. 14:57-64 |
7,910,833 Infringement Allegations
| Claim Element (from Independent Claim 24, as amended) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A power device for supplying power to an electronic device... | The Samsung Wireless Charger is a device that supplies power to a mobile phone. | ¶30 | col. 6:30-33 |
| power circuitry for converting the input power voltage to the output power voltage and for determining an “off” state of the power device; | The charger has internal circuitry that controls current flow based on the charge-status of the battery, and determines an "off" state for the device. | ¶34 | col. 9:1-15 |
| switching circuitry operable to electrically activate the power circuitry to the “on” state; | The wireless charger has internal switches that control the flow of current. | ¶34 | col. 9:45-50 |
| a load sensing portion operable to sense one or more pulses and determine the power or load being drawn from the power device by the electronic device based thereon, the load sensing portion determining the power or load being drawn from the power device by measuring the frequency of the pulses. | The complaint alleges the wireless charger has a "novel load sensing portion, which senses the frequency of pulses rather than sensing the magnitude of a voltage and/or current, to determine the load being drawn, and to determine an 'off' state for the device." | ¶34 | col. 9:16-24; col. 13:41-44 |
Identified Points of Contention
- Scope Questions (’794 Patent): The infringement analysis may turn on how the term "outer profile" is construed. The parties may dispute the precise method of measuring the "width" and "longitudinal length" to determine if they meet the claimed dimensional limitations.
- Technical Questions (’833 Patent): A central question will be whether the accused Qi-compliant wireless charger's method of determining load—which involves a standardized communication protocol between the charger and the device—functions in the same way as the claimed "load sensing portion" that determines load by "measuring the frequency of the pulses." The defense may argue that the Qi standard operates on a different technical principle than the specific pulse-frequency measurement described in the patent's embodiments.
V. Key Claim Terms for Construction
Term 1 (’794 Patent): "outer profile"
- Context and Importance: This term is critical because the claim requires the "width of the housing outer profile" to be less than 1.75 inches. The definition of what constitutes the "profile" and how its "width" is measured will be determinative of infringement, as the complaint alleges a specific measurement of 1.626 inches (Compl. ¶28).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification discusses the overall goal of reducing the plug's size to avoid interfering with adjacent receptacles, which may support interpreting "outer profile" as the maximum external boundary of the housing in any orientation (’794 Patent, col. 1:41-49).
- Evidence for a Narrower Interpretation: A defendant might argue that "profile" refers to a specific cross-section depicted in a figure (e.g., the cross-section shown in FIG. 10 or 15), potentially allowing for a measurement methodology that results in a different width. The term itself is not explicitly defined.
Term 2 (’833 Patent): "a load sensing portion operable to... determine the power or load being drawn... by measuring the frequency of the pulses"
- Context and Importance: This phrase captures the core of the patented solution to the "phantom load" problem. Plaintiff must prove that the accused wireless charger performs this specific function. Practitioners may focus on this term because the accused product operates under the Qi standard, and the case will likely involve a technical battle over whether the Qi protocol's method of load communication is equivalent to "measuring the frequency of the pulses" as taught in the patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the concept in general terms, stating the load sensing device "senses the pulse width and recognizes how slow or fast the pulse is repeated to determine the load" (’833 Patent, col. 9:32-35), which could be argued to encompass any system where load information is encoded in pulse timing.
- Evidence for a Narrower Interpretation: The patent provides specific circuit examples, such as monitoring pulses from a "transformer secondary winding" to drive a switch (’833 Patent, col. 11:8-14) or using a pulse-width modulation (PWM) switch (’833 Patent, col. 9:41-48). A defendant could argue these embodiments limit the claim's scope to these specific implementations, which may differ from the operation of a Qi-compliant charger.
VI. Other Allegations
- Willful Infringement: The complaint's prayer for relief seeks a determination that Defendant's infringement has been "willful, wanton, and deliberate" and asks for treble damages (Compl. p. 12, ¶C). However, the body of the complaint does not plead specific facts to support this claim, such as allegations of pre-suit knowledge of the patents or egregious conduct.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional and evidentiary scope for the ’794 patent: Can Plaintiff prove, and will the court agree, that the term "outer profile" is defined and measured in a way that brings the accused wall charger's alleged 1.626-inch width within the claim's "less than 1.75 inches" limitation?
- A key technical question will be one of functional operation for the '833 and '648 patents: Does the accused wireless charger, which operates according to the standardized Qi communication protocol, determine device load by "measuring the frequency of the pulses" as required by the claims, or does it use a technically distinct method? The outcome may depend on whether the patent's scope, narrowed by extensive post-grant proceedings, can reach the standardized technology used in the accused products.