DCT
7:26-cv-00008
Electrasense Tech LLC v. Eaton Corp
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Electrasense Technologies LLC (Texas)
- Defendant: Eaton Corporation (Delaware)
- Plaintiff’s Counsel: Ni, Wang & Massand, PLLC
- Case Identification: 7:26-cv-00008, W.D. Tex., 01/12/2026
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant maintains a regular and established place of business in the district and has committed acts of infringement there.
- Core Dispute: Plaintiff alleges that Defendant’s USB Power Delivery wall outlets infringe a patent related to technology for dynamically adjusting charging voltage based on an identification signal received from a connected electronic device.
- Technical Context: The technology addresses the need for "smart" charging solutions, enabling a single power outlet to negotiate and supply variable voltage and power levels to efficiently charge a wide range of modern electronics, such as smartphones and tablets.
- Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2015-06-18 | ’876 Patent Priority Date |
| 2017-11-07 | ’876 Patent Issue Date |
| 2026-01-12 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,812,876 - *"Wall socket with load detecting circuit"*
- Patent Identification: U.S. Patent No. 9,812,876, "Wall socket with load detecting circuit," issued November 7, 2017 (the "’876 Patent").
The Invention Explained
- Problem Addressed: The patent describes a problem with prior art USB wall sockets, which provided only a "fixed output voltage." This was "insufficient to satisfy the various charging requirements" of different modern electronic devices and led to "unnecessary energy loss" from power consumption during a standby state (’876 Patent, col. 1:16-27).
- The Patented Solution: The invention is a wall socket that incorporates a "load detecting circuit." This circuit is configured to receive an "identification signal" from a connected device, which indicates the device's specific voltage requirement. Based on this signal, the load detecting circuit generates a "control signal" that directs a "power converting circuit" to adjust the DC output voltage to the appropriate level, selecting from a "plurality of different voltage levels." (’876 Patent, Abstract; col. 4:11-20; Claim 1). This allows the socket to dynamically adapt its power output to the needs of the connected device.
- Technical Importance: This adaptive approach improves charging compatibility and efficiency for a variety of devices from a single outlet and can reduce standby power consumption, addressing key limitations of earlier fixed-voltage USB chargers (Compl. ¶11).
Key Claims at a Glance
- The complaint asserts infringement of at least independent claim 1 (Compl. ¶14).
- Essential elements of independent claim 1 include:
- A socket housing with an input terminal (for power grid connection) and an output terminal.
- A power converting circuit that converts input voltage to a DC output voltage based on a control signal.
- A load detecting circuit that receives an "identification signal" from a connected electronic device.
- The load detecting circuit outputs the control signal based on the identification signal to adjust the DC output voltage.
- The output voltage level is selected from a "plurality of different voltage levels" corresponding to the identification signal, and this voltage varies at the same output pin.
- The complaint reserves the right to modify its infringement contentions based on discovery (Compl. ¶14).
III. The Accused Instrumentality
Product Identification
- The complaint identifies the "Eaton 60W USB Power Delivery Type A/C" as an exemplary accused product, along with other "substantially similar products" such as the Eaton TRUSBPDAC20, TRUSBPDC15, and TRUSBPDC20 (collectively, the "Accused Products") (Compl. ¶13).
Functionality and Market Context
- The Accused Products are described as wall outlets that incorporate the functionality claimed in the ’876 Patent (Compl. ¶7). By identifying them as "USB Power Delivery" devices, the complaint alleges they possess the capability to negotiate with connected electronics to deliver variable levels of power and voltage, a key feature of the USB-PD charging standard designed for fast and efficient charging of a wide range of consumer electronics (Compl. ¶13).
IV. Analysis of Infringement Allegations
The complaint references a claim chart in an exhibit that was not provided with the filing (Compl. ¶14). The following table summarizes the infringement theory for Claim 1 based on the narrative allegations in the complaint.
’876 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a power converting circuit arranged in the socket housing and configured to convert the input voltage to the dc output voltage according to a control signal; | The Accused Products contain circuitry to convert standard AC wall voltage to a DC output voltage for USB charging, with the output level adjusted by internal control signals. | ¶¶11, 13 | col. 4:5-10 |
| a load detecting circuit configured to receive an identification signal outputted by an electronic device... and output the control signal... to adjust a voltage level of the dc output voltage | The Accused Products, as USB Power Delivery devices, necessarily include logic to communicate with a connected device, receive a signal indicating its power needs, and generate internal control signals to adjust the output voltage. | ¶¶11, 13 | col. 4:11-17 |
| in order to configure the dc output voltage of the output terminal to be the voltage level corresponding to the identification signal selected from a plurality of different voltage levels; | The Accused Products allegedly adjust their output voltage to one of several available levels (e.g., 5V, 9V, 15V, 20V) as specified by the USB Power Delivery standard, based on communication with the connected device. | ¶11 | col. 5:35-40 |
| wherein the voltage level of the dc output voltage outputted by the same output pin of the ouput terminal of the wall socket varies according to the identification signal. | The Accused Products allegedly vary the voltage supplied through their USB-C or USB-A ports based on the negotiated requirements of the connected device. | ¶¶7, 11 | col. 8:38-44 |
No probative visual evidence provided in complaint.
- Identified Points of Contention:
- Scope Questions: A potential dispute may arise over whether the communication protocol defined by the USB Power Delivery standard, as implemented in the Accused Products, constitutes an "identification signal" within the meaning of the ’876 Patent. The analysis will depend on how the patent’s specification and prosecution history define this term.
- Technical Questions: The complaint alleges infringement at a high level of functionality. A key technical question will be whether the specific hardware architecture of the Accused Products, which likely utilize a highly integrated controller chipset, maps onto the distinct "power converting circuit" and "load detecting circuit" elements as recited in Claim 1. The degree of integration in the accused circuitry compared to the architecture described in the patent may become a central point of dispute.
V. Key Claim Terms for Construction
The Term: "load detecting circuit"
Context and Importance: This term is central to the invention, representing the "brains" of the smart charging function. Its construction will determine whether the claim reads on a broad range of implementations, including highly integrated modern chipsets, or is limited to architectures more closely resembling the patent's diagrams. Practitioners may focus on this term because the Accused Products likely perform this function using a multi-purpose microcontroller rather than a discrete circuit block as depicted in the patent’s figures.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language defines the circuit functionally as being "configured to receive an identification signal... and output the control signal" (’876 Patent, Claim 1). This functional description could support an interpretation that covers any component or group of components performing these actions, regardless of their specific physical implementation.
- Evidence for a Narrower Interpretation: The specification depicts the "load detecting circuit (240)" as a distinct block separate from the "power converting circuit (220)" and "driving circuit (260)" (’876 Patent, Fig. 2). This could support an argument that the term requires a structurally distinct or separable circuit, not merely a functional capability within a single integrated controller.
The Term: "identification signal"
Context and Importance: The nature and form of this "signal" are critical to determining infringement. The dispute will likely focus on whether the complex, multi-step negotiation protocol of the USB Power Delivery standard can be characterized as the "identification signal" contemplated by the patent.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language is broad, not specifying a particular protocol or signal type. The specification notes the signal "may be received via the identification pin ID of the output terminal 290" (’876 Patent, col. 4:17-20), suggesting the signal is the information conveyed, not the physical means.
- Evidence for a Narrower Interpretation: The specification provides specific examples of pins that could carry the signal, such as "D+ and D- pins of the USB 2.0... CC1 and CC2 pins of the USB 3.1 type-C" (’876 Patent, col. 3:45-48). A defendant may argue that the term should be limited to the types of signaling mechanisms disclosed or known at the time, potentially excluding more advanced, bi-directional communication protocols developed later.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Defendant provides the Accused Products with "specifications, instructions, manuals, advertisements, marketing materials, and technical assistance" that instruct and encourage end users to use the products in an infringing manner (Compl. ¶15).
- Willful Infringement: The complaint alleges in its prayer for relief that Defendant's infringement has been willful (Compl. p. 5, C), but the body of the complaint does not plead specific facts regarding Defendant's pre- or post-suit knowledge of the ’876 Patent.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of technical mapping and claim scope: Does the highly integrated architecture of modern USB Power Delivery controllers, as likely found in the Accused Products, meet the limitations of the asserted claims, which describe a system with functionally distinct "load detecting" and "power converting" circuits? The case may turn on whether the claims are interpreted to cover a single-chip solution or require separate components as depicted in the patent.
- A second central question will be one of definitional interpretation: Can the term "identification signal," as described and enabled in the 2015-priority patent, be construed to read on the complex, bi-directional communication protocol of the modern USB Power Delivery standard allegedly used by the Accused Products? The outcome will likely depend on evidence presented during claim construction regarding the meaning of this term to a person of ordinary skill in the art at the time of the invention.