DCT
2:22-cv-00403
SnapRays v. Lighting Defense Group
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: SNAPRAYS, LLC d/b/a SNAPPOWER (Utah)
- Defendant: Lighting Defense Group LLC (Delaware)
- Plaintiff’s Counsel: Stoel Rives LLP
- Case Identification: 2:22-cv-00403, D. Utah, 06/16/2022
- Venue Allegations: Plaintiff alleges venue is proper in the District of Utah because Defendant directed its patent assertion campaign at Plaintiff, a Utah resident, by reporting Plaintiff to Amazon.com for alleged infringement, which has harmed Plaintiff's business originating in Utah.
- Core Dispute: Plaintiff seeks a declaratory judgment that its electrical outlet cover products do not infringe Defendant's patent related to outlet covers with integrated lighting.
- Technical Context: The technology concerns electrical outlet covers that incorporate a built-in light source, drawing power directly from the electrical receptacle to serve as a nightlight without occupying an outlet plug.
- Key Procedural History: The action was precipitated by Defendant reporting Plaintiff to Amazon.com on or around May 27, 2022, initiating an e-commerce patent enforcement action to terminate Plaintiff's sales on the platform. This created the "actual and justiciable case or controversy" that forms the basis for this declaratory judgment action.
Case Timeline
| Date | Event |
|---|---|
| 2010-09-16 | '347 Patent Priority Date |
| 2014-03-11 | '347 Patent Issued |
| 2014 | Plaintiff SnapPower founded |
| 2022-05-27 | Defendant allegedly reports Plaintiff to Amazon.com |
| 2022-06-16 | Complaint for Declaratory Judgment Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,668,347 - "Receptacle cover," issued March 11, 2014
The Invention Explained
- Problem Addressed: The patent background describes the risks of unintentional injuries from falls in poorly lit homes and the electrical hazards posed by conventional plug-in nightlights, which can attract the attention of young children and occupy a valuable outlet space (’347 Patent, col. 1:26-39, col. 2:3-25). It also notes the need for a product that is safe and easy for a "do-it-yourself consumer" to install (’347 Patent, col. 2:26-36).
- The Patented Solution: The invention is a cover for an electrical receptacle that includes an integrated light source powered directly from the receptacle itself. The key mechanism is a set of "transmission tabs" that extend from the back of the cover plate to make electrical contact with the power line screw terminals on the sides of the receptacle, eliminating the need for wires or occupying the plug sockets (’347 Patent, Abstract; col. 6:35-43). Figure 2 illustrates these transmission tabs (126, 128) positioned to engage the receptacle's fasteners (110) to draw power.
- Technical Importance: The invention provides a flush-mounted, integrated lighting solution that is presented as being safer and more aesthetically pleasing than traditional, removable nightlights (’347 Patent, col. 3:5-18).
Key Claims at a Glance
- The complaint seeks a declaratory judgment of non-infringement of all claims but specifically discusses claims 1-11 (based on independent claim 1) and 12-20 (based on independent claim 12) (Compl. ¶17).
- Independent Claim 1:
- A cover for an electrical receptacle comprising:
- a faceplate;
- a first transmission tab configured to be electrically connected to a first power line of the electrical receptacle;
- a second transmission tab configured to be electrically connected to a second power line of the electrical receptacle;
- a device (e.g., a light source) in communication with the tabs;
- wherein at least one tab is an "elongated, rigid or semi-flexible tab extending from a back side of the faceplate"; and
- wherein the tab comprises "one or more conductive surface structures configured to face a conductive portion of the electrical receptacle."
- Independent Claim 12:
- A cover for an electrical receptacle comprising:
- a faceplate;
- a first transmission tab and a second transmission tab;
- a device in communication with the tabs;
- wherein the faceplate is "configured to be received between the electrical receptacle and a decorative receptacle plate."
- The complaint notes that dependent claims add limitations such as removability of the tabs, which are also alleged to be absent from the accused products (Compl. ¶17).
III. The Accused Instrumentality
Product Identification
- The "Accused Products" are Plaintiff's electrical outlet covers with integrated lighting, including guide lights, safety lights, motion sensor lights, and USB charging technology (Compl. ¶12). The "SnapPower GuideLight" is identified as an exemplary product (Compl. ¶16).
Functionality and Market Context
- The products are outlet cover plates that replace standard plates and feature built-in lights or USB ports, drawing power in a way that "installs in seconds" without wires or batteries (Compl. p. 4). The complaint provides an image showing an installed product with a downward-facing light, leaving the main sockets free (Compl. p. 4). A second set of images shows various product configurations, including a standard guide light, one with a USB port, and one for a GFCI-style outlet (Compl. p. 5). The complaint alleges these products are the result of Plaintiff's own innovations, have been recognized by the USPTO through the issuance of 24 utility patents, and have received praise from media outlets (Compl. ¶15-16).
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement. Its theory of non-infringement is summarized in the table below, based on allegations in the complaint body.
’347 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first transmission tab configured to be electrically connected... a second transmission tab configured to be electrically connected... | The complaint alleges the Accused Products "lack such tabs." | ¶17 | col. 5:42-65 |
| wherein at least one of the first and the second transmission tabs is configured as an elongated, rigid or semi-flexible tab extending from a back side of the faceplate | The complaint states that the Accused Products do not have transmission tabs with this configuration. | ¶17 | col. 15:24-27 |
’347 Patent Infringement Allegations
| Claim Element (from Independent Claim 12) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a faceplate; wherein the faceplate is configured to be received between the electrical receptacle and a decorative receptacle plate | The complaint alleges the Accused Products "lack a faceplate to be received between the electrical receptacle and a decorative receptacle plate." | ¶17 | col. 16:17-20 |
- Identified Points of Contention:
- Technical Question: The central dispute for claims stemming from Claim 1 is factual and definitional: what specific mechanism do the Accused Products use to draw power, and does that mechanism meet the claim limitations of an "elongated, rigid or semi-flexible tab" that "extend[s] from a back side of the faceplate"? The complaint's assertion that the products "lack such tabs" suggests a fundamental structural difference in the power-drawing components (Compl. ¶17).
- Scope Question: For claims stemming from Claim 12, the dispute concerns the product's basic configuration. The claim requires an "under-plate" design that sits between the receptacle and a separate decorative plate (’347 Patent, Fig. 16A). The complaint alleges the Accused Products are not configured this way, raising the question of whether they are a single, integrated decorative plate rather than a component in a multi-plate assembly (Compl. ¶17).
V. Key Claim Terms for Construction
The Term: "transmission tab"
- Context and Importance: This term is the central structural element for drawing power in Claim 1. The Plaintiff's entire non-infringement argument for claims 1-11 hinges on its products lacking a structure that meets this definition (Compl. ¶17). Practitioners may focus on this term because its construction will determine whether the Plaintiff's power-drawing mechanism, which the complaint implies is structurally different, falls within the scope of the patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself is functional, requiring a tab "configured to be electrically connected" (’347 Patent, col. 15:16-18). The patent also mentions that the tabs "may be designed in any suitable manner that provides a point of contact" between the cover and the receptacle fasteners (’347 Patent, col. 6:41-44).
- Evidence for a Narrower Interpretation: The specification consistently depicts the tabs as specific structures (126, 128) that "extend outwardly away and at a right angle from the back of the rear surface" of the cover (’347 Patent, col. 6:45-48, Fig. 2). This specific embodiment, shown throughout the drawings, could be used to argue for a narrower construction limited to structures that press against the side screw terminals of the receptacle, potentially excluding other types of electrical contacts.
The Term: "faceplate configured to be received between the electrical receptacle and a decorative receptacle plate"
- Context and Importance: This limitation defines the entire structure of independent Claim 12. Plaintiff alleges its products lack this feature entirely (Compl. ¶17). The viability of any allegation of infringement of claims 12-20 depends on whether the accused product meets this "under-plate" description.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The complaint does not provide sufficient detail for analysis of arguments for a broader interpretation.
- Evidence for a Narrower Interpretation: The patent specification explicitly describes and illustrates this "under-plate" configuration as a distinct embodiment (’347 Patent, col. 10:32-54). Figure 16A shows a "cover member 250" positioned between the electrical receptacle 102 and a separate "wallplate 252," which appears to be the decorative plate. This clear depiction supports an interpretation that the claim is limited to this specific two-plate arrangement.
VI. Other Allegations
- Indirect Infringement: The complaint seeks a declaratory judgment that it has not infringed "directly or indirectly, any claim of the '347 Patent" (Compl. ¶24). However, as a complaint for declaratory judgment of non-infringement, it does not set forth the factual basis on which an indirect infringement claim might be asserted by the Defendant.
- Willful Infringement: Willful infringement is not at issue. However, the Plaintiff alleges that the Defendant's conduct makes this an "exceptional case" under 35 U.S.C. § 285, which would entitle Plaintiff to attorneys' fees (Compl. ¶28).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: does the power extraction mechanism used in Plaintiff’s products meet the definition of the "transmission tab" as described and claimed in the ’347 Patent? The case may turn on whether Plaintiff’s design is a distinct, non-infringing alternative or merely an equivalent implementation of the patented concept.
- A second key issue will be one of structural configuration: can the ’347 Patent’s "under-plate" claims (claims 12-20) read on Plaintiff's products, which the complaint alleges are integrated, single-piece decorative covers? This appears to be a direct comparison of the accused product's structure against the specific arrangement required by the claim language.
- Finally, the procedural posture of the case—a declaratory judgment action prompted by an enforcement attempt on a third-party marketplace (Amazon.com)—raises questions about the Defendant's pre-suit conduct, which the Plaintiff has put at issue by seeking a finding that this is an "exceptional case" (Compl. ¶28).