DCT
2:25-cv-00603
American Tack & Hardware Co v. Snaprays
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: American Tack 7 Hardware Co. Inc. (New York)
- Defendant: SnapRays, LLC DBA SnapPower (Utah)
- Plaintiff’s Counsel: Barnes & Thornburg, LLP
- Case Identification: 2:25-cv-00603, D. Utah, 07/23/2025
- Venue Allegations: Plaintiff alleges venue is proper in the District of Utah as Defendant is a Utah company with its principal place of business in the district.
- Core Dispute: Plaintiff alleges that Defendant’s line of powered electrical receptacle covers infringes four patents related to drawing power from an outlet’s internal terminals to power integrated features like lights and USB ports.
- Technical Context: The technology involves electrical outlet faceplates designed with integrated conductive prongs that contact an outlet’s side-screw terminals, enabling the faceplate itself to power features without using the plug sockets.
- Key Procedural History: The complaint alleges that in June 2020, Defendant engaged in discussions to purchase the asserted patents from the original inventor, allegedly with knowledge that its own products infringed, but the negotiations were unsuccessful.
Case Timeline
| Date | Event |
|---|---|
| 2010-09-16 | Earliest Priority Date for all Asserted Patents |
| 2014-03-11 | U.S. Patent 8,668,347 Issued |
| 2018-11-20 | U.S. Patent 10,136,534 Issued |
| 2020-06-16 | U.S. Patent 10,687,432 Issued |
| 2020-06-XX | Defendant allegedly discussed purchasing Asserted Patents |
| 2023-04-18 | U.S. Patent 11,632,844 Issued |
| 2025-04-16 | Plaintiff purchased Asserted Patents |
| 2025-07-23 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent 8,668,347 - "Receptacle cover," Issued March 11, 2014
The Invention Explained
- Problem Addressed: The patent background describes problems in the home environment, including falls due to poor lighting and safety hazards posed by electricity and plug-in nightlights to young children (’534 Patent, col. 1:31-col. 2:40).
- The Patented Solution: The invention is an improved electrical receptacle cover with integrated conductive tabs that securely form an electrical connection with the power terminals of the receptacle itself, such as the side screws (’347 Patent, col. 5:42-54). This allows the cover to power an integrated device, like an LED light, without occupying a plug socket, as illustrated in the patent’s figures (e.g., ’347 Patent, Fig. 2).
- Technical Importance: This design provides a safe, easy-to-install, and aesthetically integrated lighting solution that avoids the cosmetic and safety drawbacks of traditional plug-in nightlight appliances (’347 Patent, col. 4:5-20).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶16).
- Claim 1 requires:
- 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 in communication with the first and second transmission tabs;
- at least one of the tabs is configured as an elongated, rigid or semi-flexible tab extending from a back side of the faceplate; and
- the at least one transmission tab comprises one or more conductive surface structures configured to face a conductive portion of the electrical receptacle.
U.S. Patent 10,136,534 - "Receptacle cover," Issued November 20, 2018
The Invention Explained
- Problem Addressed: The patent addresses the same problems as the parent ’347 Patent, including home safety issues related to poor lighting and the unreliability and unattractiveness of conventional plug-in nightlights (’534 Patent, col. 1:31-col. 2:40).
- The Patented Solution: The invention is a receptacle cover with conductive tabs and integrated "circuitry" that enables a "plug-and-play" installation (’534 Patent, col. 4:16-24). The tabs are designed to make contact with the power supply terminals of an existing electrical receptacle, thereby powering the cover’s integrated features (’534 Patent, Fig. 4; col. 5:42-54).
- Technical Importance: The invention offers a method for adding powered functionality directly to an outlet cover, reducing power consumption and enhancing safety compared to external plug-in devices (’534 Patent, Abstract).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶32).
- Claim 1 requires:
- 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 circuitry in communication with the first and second transmission tabs; and
- at least one of the tabs is configured as an elongated, rigid or semi-flexible tab extending from a back side of the faceplate.
U.S. Patent 10,687,432 - "Receptacle cover," Issued June 16, 2020
Technology Synopsis
This patent, from the same family, is directed to an improved receptacle or switch cover that solves issues of safety and convenience associated with plug-in nightlights (’432 Patent, col. 1:17-24). The invention claims a cover with at least one elongated transmission tab extending from its backside, which includes a conductive surface structure to make contact with a power line of the electrical receptacle or switch (’432 Patent, Abstract; claim 1).
Asserted Claims
The complaint asserts independent claim 1 (Compl. ¶47).
Accused Features
Plaintiff accuses Defendant's receptacle covers, like the GuideLight 2, of infringing by using a faceplate with elongated transmission tabs that draw power from the receptacle’s internal power lines (Compl. ¶¶48-57).
U.S. Patent 11,632,844 - "Active Receptacle cover," Issued April 18, 2023
Technology Synopsis
This patent is directed to a receptacle cover that not only draws power but also adds external connectivity points (’844 Patent, col. 1:24-30). The invention claims a faceplate with power transmission tabs and a "port member" that extends outwardly from the faceplate's surface, providing an access point for an electrical connection (such as a USB port) that is separate from the main receptacle sockets (’844 Patent, claim 1).
Asserted Claims
The complaint asserts independent claim 1 (Compl. ¶59).
Accused Features
Plaintiff accuses the "SnapPower USB Charger Outlet Wall Plate Cover" of infringement, alleging its power transmission tabs contact the receptacle's power terminals to electrify an integrated, outwardly extending USB port member (Compl. ¶¶60, 66, 68). An image in the complaint shows the accused product with a "Port Member" that provides an "Access Point" for a charging cable (Compl. p. 14, Fig. C).
III. The Accused Instrumentality
Product Identification
The complaint names multiple accused products, with the "GuideLight 2" receptacle cover serving as the primary example for the ’347, ’534, and ’432 patents, and the "SnapPower USB Charger Outlet Wall Plate Cover" serving as the example for the ’844 patent (Compl. ¶¶16, 32, 47, 59-60). A broader list of accused products is also provided, including various models of GuideLight, StormLight, SwitchLight, and others (Compl. ¶16).
Functionality and Market Context
The accused products are described as covers for electrical receptacles that replace standard, non-powered faceplates (Compl. ¶¶17, 33). They incorporate electronic components, such as LED lights or USB charging ports, which are powered by a set of conductive prongs, or "transmission tabs," located on the back of the cover (Compl. ¶¶21, 37, 52). These tabs are designed to make physical and electrical contact with the screw terminals on the sides of a standard electrical receptacle, thereby drawing power for the integrated features without blocking the main outlet sockets (Compl. ¶¶21, 68). The complaint does not provide sufficient detail for analysis of the products' market positioning.
IV. Analysis of Infringement Allegations
’347 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a faceplate | The GuideLight 2 is a cover for an electrical receptacle that includes a faceplate. | ¶19 | col. 5:21-22 |
| a first transmission tab configured to be electrically connected to a first power line… | The GuideLight 2 has a first tab positioned to make electrical contact with a power line terminal of the receptacle. The complaint provides an image showing two such tabs on the back of the device, labeled "A first transmission tab" and "A second transmission tab" (Compl. p. 4). | ¶21 | col. 5:42-54 |
| a second transmission tab configured to be electrically connected to a second power line… | The GuideLight 2 has a second tab positioned to make electrical contact with a second power line terminal of the receptacle. | ¶23 | col. 5:42-54 |
| a device in communication with the first transmission tab and the second transmission tab | The GuideLight 2 has an integrated LED light source that is in electrical communication with the first and second tabs. | ¶25 | col. 7:1-12 |
| at least one of the…tabs…configured as an elongated, rigid or semi-flexible tab extending from a back side… | The transmission tabs of the GuideLight 2 are alleged to be elongated and extend from the backside of the faceplate. | ¶27 | col. 5:55-58 |
| the at least one transmission tab comprises one or more conductive surface structures configured to face a conductive portion of the electrical receptacle | The transmission tab of the GuideLight 2 has a conductive surface designed to face and make contact with a conductive portion of the receptacle. An image shows this feature, labeled "Conductive surface configured to face a conductive portion of electrical receptacle" (Compl. p. 5). | ¶29 | col. 6:65-col. 7:11 |
Identified Points of Contention
- Scope Questions: The patent specification describes "conductive surface structures" as potentially including "protrusions, hooks, teeth, and the like" to facilitate contact (’347 Patent, col. 7:8-11). A question for the court may be whether the accused product's apparently simpler contact surface, as depicted in the complaint (Compl. p. 5), meets the literal scope of this claim element, or whether Plaintiff will need to rely on the doctrine of equivalents.
- Technical Questions: The claim requires a "device" in communication with the tabs. The complaint identifies an LED (Compl. ¶25). The breadth of the term "device" will be a central question, particularly in comparison to the term "circuitry" used in the continuation patents.
’534 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a faceplate | The GuideLight 2 includes a faceplate that covers an electrical receptacle. | ¶35 | col. 5:21-22 |
| a first transmission tab configured to be electrically connected to a first power line… | The GuideLight 2 has a first tab designed to connect to a first power line of the electrical receptacle. | ¶37 | col. 5:42-54 |
| a second transmission tab configured to be electrically connected to a second power line… | The GuideLight 2 has a second tab designed to connect to a second power line of the electrical receptacle. | ¶39 | col. 5:42-54 |
| a circuitry in communication with the first transmission tab and the second transmission tab | The complaint alleges the GuideLight 2 has "circuitry that is in communication with the first and second transmission tabs." | ¶41 | col. 7:46-54 |
| at least one of the…tabs…configured as an elongated, rigid or semi-flexible tab extending from a back side… | The tabs of the GuideLight 2 are alleged to be elongated and semi-flexible, extending from the back of the faceplate. The complaint includes a labeled image identifying these features as "Elongated and semi-flexible tab extending from back side of the faceplate" (Compl. p. 8). | ¶43 | col. 5:55-58 |
Identified Points of Contention
- Scope Questions: Claim 1 of the ’534 Patent requires "circuitry," whereas the parent ’347 Patent requires a "device." This change in terminology raises the question of whether "circuitry" imposes a different and potentially higher standard than "device."
- Technical Questions: The complaint alleges the accused product "has circuitry" (Compl. ¶41) but does not detail its components. The patent specification discloses "voltage reducing circuitry" as an example ('534 Patent, col. 7:46-48). A key technical question will be what components are present in the accused product and whether they constitute "circuitry" as the term is construed, or if they are merely simple conductors connecting the tabs to an LED.
V. Key Claim Terms for Construction
The Term: "transmission tab"
- Context and Importance: This term defines the core inventive concept of drawing power from the receptacle's terminals. Its construction is critical because it dictates the structural requirements for an infringing device’s power-drawing prongs.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests a broad, functional definition, stating the tabs may be designed in "any suitable manner that provides a point of contact" and function to "transfer or conduct electricity from a power source" (’534 Patent, col. 4:50-53; col. 5:49-54).
- Evidence for a Narrower Interpretation: The specification describes specific embodiments where the tabs are "resilient and/or semi-flexible to provide the 'spring back' reaction" and may include "one or more reinforcement ribs" (’534 Patent, col. 5:60-61; col. 7:31-36). This could support an argument that the term is limited to structures possessing these physical characteristics.
The Term: "circuitry" (’534 Patent)
- Context and Importance: The meaning of "circuitry" is central to distinguishing the ’534 Patent from its parent and determining infringement. Practitioners may focus on this term because its interpretation will determine if the accused product's simple electronics meet this limitation, or if a more complex electrical arrangement is required.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term is used generally to describe the electrical pathway between the power-drawing tabs and the powered component, such as a "light source" or "sensor" (’534 Patent, col. 7:46-54).
- Evidence for a Narrower Interpretation: The specification repeatedly provides "voltage reducing circuitry" as a specific example and includes detailed circuit diagrams for functions like voltage conversion and battery backup (’534 Patent, col. 7:46-48; Figs. 25-29). This may support a narrower construction requiring more than a simple conductor, such as components for power conversion or control.
VI. Other Allegations
Willful Infringement
The complaint alleges that Defendant’s infringement has been and continues to be willful (Compl. ¶¶15, 31, 58, 81). The allegations are based on pre-suit knowledge, asserting that around June 2020, Defendant discussed purchasing the asserted patents from the original inventor, knew its products infringed, and continued its allegedly infringing activities after negotiations failed (Compl. ¶¶76-80).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim scope versus specification detail: can the asserted claims, which recite broad functional elements like a "transmission tab" and "circuitry", be read to cover the accused products, or will the more detailed embodiments described in the specification (e.g., tabs with "spring back" features, voltage-reducing circuitry) be used to narrow the claim scope and support a finding of non-infringement?
- A second central issue will be the evidentiary basis for willfulness. The case may turn on what discovery reveals about the 2020 patent acquisition discussions, specifically what knowledge Defendant possessed regarding the patents-in-suit and whether it formed a good-faith belief of non-infringement or invalidity before continuing to market its products.
- A third question will be the impact of claim differentiation, particularly between the term "device" in the ’347 patent and "circuitry" in the ’534 patent. The court’s interpretation of this distinction will be critical in determining whether the same accused product can infringe both patents, and what level of electronic complexity is required by the later patent.