Socket Solutions, LLC v. Import Global, LLC, Appeal No. 2025-1121 (Fed. Cir. Aug. 4, 2026)

In its only precedential patent opinion last week, the Federal Circuit vacated a preliminary injunction that prohibited appellant Import Global from making or selling its “Neat Socket” low-profile extension cords.  The lower court had found Socket Solutions was likely to succeed on its claim that the Neat Socket infringed U.S. Patent No. 9,509,080, which is directed to an electrical outlet cover that conceals the outlet contact openings when in use.  The Federal Circuit found the lower court erred in its claim construction, vacated the injunction, and remanded for further proceedings.

Asserted claim 19 of the ’080 Patent is directed to an apparatus with a “cover” comprising a “frontplate” and a “backplate” with “at least one set of electrical prongs,” as well as an electrical cord with “at least one hot pin, at least one neutral pin and optionally a ground wire” coupled to the backplate.  On appeal, Import Global argued that the district court erred in its constructions of “backplate” and “pin,” and the reviewing panel agreed on both counts.

The lower court had construed “backplate” to mean “the component of the cover, opposing the front[]plate, that includes at least one set of electrical prongs.”  The Federal Circuit found this construction to improperly require a specific spatial relationship between the front plate and backplate (“opposing”), as well as adding a redundant “includes… electrical prongs” limitation that was already recited in the claims.  The Court also rejected Import Global’s proposed construction for requiring a specific spatial relationship with the wall outlet.  Instead, noting that “the written description explicitly defines ‘cover’ thickness in relation to the ‘backplate,’” the Court found that “a construction that focuses on ‘cover’ thickness most naturally aligns with the specification,” and construed “backplate” to mean “the component forming the cover with the frontplate, such that the maximum thickness of the cover is the distance, at the central portion of the cover, between the frontplate and the component.”

As for “pin,” the district court’s construction was “a means for making an electrical connection between the [hot/neutral] wire and the [hot/neutral] prong,” which Import Global argued improperly converted “pin” into a means-plus-function term under 35 U.S.C. § 112(f).  The Federal Circuit agreed, noting the parties did not dispute that the term “pin” is understood by skilled artisans to connote structure, in addition to being described as structure in the specification.  The Court also rejected Import Global’s construction of “pin” as being a “mechanical system for making” the recited “electrical connection,” noting it “may include complex interconnected systems that a skilled artisan would not understand to be a ‘pin.’”  Ultimately, the Court found that “pin” should be given its plain and ordinary meaning.

Import Global also argued that the district court erred in its finding of irreparable harm.  Having found the district court’s “likelihood of success” finding was based on an improper claim construction warranting vacatur of the injunction, the Federal Circuit did not reach that issue, except to re-affirm that there is no “presumption” of irreparable harm in patent cases following the Supreme Court’s decision in eBay Inc. v. MercExchange, L.L.C., 547 U.S. 388 (2006).  The panel proceeded to remand the case for further proceedings consistent with its opinion.

The opinion can be found here.

By Jason Wrubleski

This article summarizes aspects of the law and does not constitute legal advice. For legal advice with regard to your situation, you should contact an attorney.