DCT
2:24-cv-01271
Voltstar Tech Inc v. America Ugreen Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Voltstar Technologies, Inc. (Illinois)
- Defendant: America Ugreen Limited (Delaware)
- Plaintiff’s Counsel: Sriplaw, PLLC.
- Case Identification: 2:24-cv-01271, W.D. Wash., 08/16/2024
- Venue Allegations: Venue is alleged to be proper based on Defendant's commission of infringing acts within the district and its principal place of business being located in Bellevue, Washington.
- Core Dispute: Plaintiff alleges that Defendant’s compact USB wall chargers infringe a patent related to the specific dimensional and functional characteristics of charger plug housings.
- Technical Context: The technology concerns the design of small AC-to-DC power adapters, or "chargers," where market demand favors compact designs that do not obstruct adjacent electrical outlets.
- 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 a key dimensional limitation in Claim 1, narrowing it from "equal to or less than 2.0 inches" to "less than 2.0 inches." This amendment suggests a deliberate narrowing of the claim scope, likely to distinguish over prior art, which may become a central issue in the infringement analysis.
Case Timeline
| Date | Event |
|---|---|
| 2008-05-21 | Earliest Priority Date for RE48,794 Patent |
| 2015-05-05 | Issue Date of original U.S. Patent No. 9,024,581 |
| 2021-10-26 | Issue Date of Reissue U.S. Patent No. RE48,794 E |
| 2024-08-16 | 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's background section describes significant issues with prior art power chargers, noting that they are often bulky, protrude from the wall in a way that makes them "susceptible to being struck," and block the use of adjacent electrical outlets (RE48,794 E Patent, col. 1:42-51). It also identifies manufacturing complexities, such as expensive and time-consuming insert molding and hand soldering, as cost drivers that increase package size (RE48,794 E Patent, col. 2:11-32).
- The Patented Solution: The invention claims to solve these problems through a charger with a specific housing construction and dimensional profile. The abstract describes a "reduced plug-size charger plug" that uses slidably mounted blades and spring contacts to connect to internal circuitry, obviating the need for insertion molding (RE48,794 E Patent, Abstract). This construction, combined with specific dimensional limitations, results in a compact charger that does not interfere with adjacent outlets and is less costly to manufacture (RE48,794 E Patent, col. 12:51-58).
- Technical Importance: The described approach addresses a persistent consumer demand for smaller, more portable, and less obtrusive electronic device chargers by focusing on both the external form factor and the internal manufacturing method. (RE48,794 E Patent, col. 1:12-18).
Key Claims at a Glance
- The complaint asserts infringement of at least Claim 1 of the ’794 Patent (Compl. ¶27).
- Independent Claim 1 requires, in relevant part:
- A charger plug housing with blade members, a DC connector, a defined face area, and an outer profile.
- The plug must be configured to be plugged into a standard wall outlet.
- The housing must be sized so that its "longitudinal length" is "less than 2.0 inches" and its "width" is "less than 1.75 inches."
- The housing's "outer profile" must have "no interference with an adjacent receptacle of the power source... when a like charger plug is mounted in all available orientations in any of the other receptacles."
- The complaint asserts infringement of "at least one of the claims," reserving the right to assert other claims, including dependent claims (Compl. ¶23).
III. The Accused Instrumentality
Product Identification
- The complaint identifies the "UGREEN Nexode mini 45W Charger" as the accused instrumentality (Compl. ¶18).
Functionality and Market Context
- The complaint alleges the accused product is a compact "reduced plugsize charger" designed to connect between an AC power source and a device requiring DC power, such as a mobile phone (Compl. ¶19, ¶20). Its key accused functionality is its specific size and shape, which allegedly prevents it from blocking or interfering with adjacent outlets (Compl. ¶20). A promotional image of the accused product highlights features such as "Higher Efficiency & Less Heat" and its suitability for laptops, tablets, and phones (Compl. p. 5, "UGREEN Nexode mini 45W Charger" image).
IV. Analysis of Infringement Allegations
The complaint does not include its referenced claim chart exhibit. The following summary is constructed from the narrative allegations.
RE48,794 E Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a charger plug... including a housing... a DC connector... the charger plug housing forming... a charger plug face area... an outer profile... | The accused product is a charger with a housing, a USB-C port (a DC connector), and a specific physical form factor. A product image shows the housing and connector opening. (Compl. p. 4, "VOLTSTAR" image). | ¶19, ¶21 | col. 13:21-33 |
| 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 complaint alleges the Nexode 45W Charger has a longitudinal length of "approximately 1.927 inches" and a width of "approximately 1.559 inches," both of which fall under the claimed thresholds. | ¶24 | col. 13:46-49 |
| the outer profile having no interference with an adjacent receptacle of the power source located on all sides of the first receptacle when a like charger plug is mounted in all available orientations in any of the other receptacles... | The complaint alleges that due to its "reduced plugsize," the Nexode 45W Charger "does not block or interfere with the use of adjacent outlets." An image of the product shows its compact, generally rectangular shape. (Compl. p. 5, "Nexode mini 45W Charger" image). | ¶20 | col. 13:50-54 |
- Identified Points of Contention:
- Scope Questions: The claim requires "no interference with an adjacent receptacle." This raises the question of how "interference" will be defined. Does it mean no physical contact whatsoever, or no functional obstruction? The analysis may depend on the specific dimensions of various "standard" wall outlets.
- Technical Questions: Infringement of the dimensional limitations will be a central factual question. While the complaint alleges dimensions that fall within the claim scope (e.g., 1.927" < 2.0"), the defendant will likely perform its own measurements. The precise definition of "longitudinal length" and "width" as applied to the accused product's geometry will be critical. The reissue history narrowing the length limitation to "less than 2.0 inches" suggests that this boundary is a hard limit with no room for equivalence (Compl. ¶14, fn. 1).
V. Key Claim Terms for Construction
The Term: "longitudinal length"
Context and Importance: This term is part of a dispositive numerical limitation ("less than 2.0 inches"). The reissue history narrowing this very limitation makes its precise measurement and definition critical. Practitioners may focus on this term because infringement will depend on a purely objective, physical measurement of the accused device against this defined boundary.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The complaint does not provide sufficient detail for analysis of this element.
- Evidence for a Narrower Interpretation: The claim itself defines the term as "extending between the front wall and the rear end" of the housing (’794 Patent, col. 13:47-48). The specification consistently describes the invention’s benefits in terms of reducing the dimension that protrudes from the wall, suggesting the length measurement is strictly of the housing body itself, excluding the electrical prongs (’794 Patent, col. 1:49-51).
The Term: "no interference with an adjacent receptacle"
Context and Importance: This functional language could be a point of contention regarding indefiniteness or scope. The parties will likely dispute what level of physical or functional obstruction constitutes "interference." Practitioners may focus on this term because its interpretation will determine whether the accused product's compact form factor is sufficient to meet the claim limitation across all standard outlet configurations.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent states that a benefit of the design is that "the plug 10 does not interfere with use of an adjacent plug" (’794 Patent, col. 12:12-14), which could be argued to mean any configuration that allows a second standard plug to be used.
- Evidence for a Narrower Interpretation: The claim requires this condition to be met "when a like charger plug is mounted in all available orientations in any of the other receptacles" (’794 Patent, col. 13:51-54). This language suggests a stringent standard that must be met in a worst-case scenario (e.g., two identical chargers plugged into a standard duplex outlet), potentially supporting a narrower definition of what constitutes "no interference."
VI. Other Allegations
- Indirect Infringement: The complaint does not plead specific facts to support a claim for either induced or contributory infringement. The allegations are limited to direct infringement under 35 U.S.C. § 271(a) (Compl. ¶26, ¶28).
- Willful Infringement: The complaint seeks a determination that infringement has been willful (Compl., Prayer for Relief ¶C). However, the factual allegations in the body of the complaint do not assert pre-suit knowledge of the patent by the Defendant. The claim for willfulness appears to be predicated on the notice provided by the filing of the lawsuit itself.
VII. Analyst’s Conclusion: Key Questions for the Case
A core issue will be one of dimensional compliance: does the accused UGREEN charger's measured "longitudinal length" and "width" fall strictly within the numerical limits of "less than 2.0 inches" and "less than 1.75 inches" as required by Claim 1? The patent's reissue history, which specifically narrowed the length dimension, suggests this will be an issue of strict compliance with little to no flexibility.
A second key issue will be the scope of a functional term: can the accused product's physical shape be proven to cause "no interference with an adjacent receptacle" under all possible orientations as mandated by the claim? The court's construction of the term "interference" will be decisive in determining whether the product's compact design meets this specific functional requirement of the patent.