DCT

1:26-cv-07658

Electrasense Tech LLC v. Leviton Mfg Co Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:26-cv-07658, N.D. Ill., 06/30/2026
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a "regular and established place of business" within the district and has committed acts of infringement in the district.
  • Core Dispute: Plaintiff alleges that Defendant's Power Delivery Wall Outlets infringe a patent related to wall sockets that use a load detecting circuit to dynamically adjust their DC power output.
  • Technical Context: The technology addresses the need for efficient, variable-voltage charging for modern mobile electronics directly from a wall outlet, aiming to improve upon fixed-voltage USB chargers.
  • Key Procedural History: The complaint states that Plaintiff is the owner of the patent-in-suit by assignment. No other procedural events such as prior litigation or administrative proceedings are mentioned.

Case Timeline

Date Event
2015-06-18 '876 Patent Priority Date
2017-11-07 '876 Patent Issue Date
2026-06-30 Complaint Filing Date

II. Technology and Patent(s)-in-Suit Analysis

  • 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's background section notes that prior art USB wall sockets provided only a fixed output voltage, which was insufficient for the varied charging requirements of modern devices like smartphones and tablets, and also led to unnecessary power consumption during standby states '876 Patent, col. 1:15-27
  • The Patented Solution: The invention describes a wall socket containing a "load detecting circuit" that can communicate with a connected electronic device '876 Patent, abstract This circuit receives an "identification signal" from the device, determines the required voltage, and then generates a "control signal" to a power converting circuit, which in turn adjusts the DC output voltage to one of a plurality of different levels to match the device's specific needs '876 Patent, col. 4:11-19 '876 Patent, Fig. 2 This allows the socket to dynamically adapt its power output.
  • Technical Importance: The patented approach enables a single wall socket to efficiently charge a wide range of electronic devices by negotiating power requirements, while also reducing standby power waste. Compl. ¶17

Key Claims at a Glance

  • The complaint asserts infringement of at least Claim 1 of the '876 Patent Compl. ¶20
  • Independent Claim 1 of the '876 Patent recites the following essential elements:
    • A socket housing
    • An input terminal for receiving voltage from a power grid
    • An output terminal for outputting a DC voltage
    • A power converting circuit that converts input voltage to DC output voltage based on a control signal
    • A load detecting circuit that receives an "identification signal" from a connected device and outputs the "control signal" to adjust the DC output voltage to a level selected from a plurality of different voltage levels
    • The voltage level from the same output pin varies according to the identification signal.
  • The complaint notes that the provided infringement example is non-limiting, suggesting the potential to assert other claims during litigation Compl. ¶20

III. The Accused Instrumentality

Product Identification

  • The complaint identifies the "Accused Products" as the Leviton T5635 series, T5836 series, T5636 series, T5835 series, T5634 series, and T5834 series Power Delivery Wall Outlets Compl. ¶2

Functionality and Market Context

  • The complaint alleges these are "Power Delivery Wall Outlets" that incorporate Plaintiff's proprietary technologies Compl. ¶2 The core of the infringement allegation is that these outlets possess the functionality claimed in the '876 Patent, namely the ability to dynamically adjust voltage output based on a connected device's needs Compl. ¶13 Compl. ¶17 The complaint alleges these products are marketed, offered for sale, and distributed throughout the United States Compl. ¶2 The complaint does not provide specific technical details on the operation of the Accused Products, instead referencing an exemplary claim chart in Exhibit B, which was not attached to the publicly filed document Compl. ¶20

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

The complaint alleges infringement of Claim 1, but does not provide a detailed claim chart in the body of the complaint. The following table summarizes the infringement theory based on the allegations in the complaint.

'876 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a socket housing; an input terminal...; an output terminal... The Accused Products are wall outlets with a housing, an input for connecting to the power grid, and an output for charging devices. ¶2; ¶17 col. 3:20-22
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 allegedly contain a power converting circuit that converts AC input to a variable DC output. ¶17 col. 4:5-10
a load detecting circuit configured to receive an identification signal outputted by an electronic device... and output the control signal according to the identification signal to adjust a voltage level of the dc output voltage... The Accused Products allegedly contain a load detecting circuit that identifies the voltage requirements of a connected device and adjusts the DC output accordingly. ¶17 col. 4:11-19
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 DC output voltage of the Accused Products allegedly varies based on communication with the connected device. ¶17 col. 8:36-41
  • Identified Points of Contention:
    • Scope Questions: A central dispute may arise over the definition of "load detecting circuit." The court will need to determine if the circuitry within the Accused Products, which likely implements a standard like USB Power Delivery, falls within the scope of this term as it is defined and described in the '876 Patent.
    • Technical Questions: A key evidentiary question will be whether the accused outlets' method for varying voltage is functionally the same as that claimed. The analysis will focus on how the Accused Products receive an "identification signal" and generate a "control signal" to modify the output, and whether this process maps onto the patent's teachings.

V. Key Claim Terms for Construction

  • The Term: "load detecting circuit"

    • Context and Importance: This term is the core of the invention. The outcome of the case may depend on whether the circuitry in Leviton's products is found to be a "load detecting circuit." Practitioners may focus on whether the term is limited to the specific embodiments shown in the patent or if it can be read more broadly to cover any circuit that performs the stated function.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: Claim 1 defines the circuit functionally as something "configured to receive an identification signal...and output the control signal" '876 Patent, claim 1 This functional language could support a construction that is not limited to a specific implementation.
      • Evidence for a Narrower Interpretation: The specification discloses a specific implementation where the circuit (240) interacts with a driving circuit (260) and an isolating circuit (280) '876 Patent, Fig. 3 '876 Patent, col. 4:31-41 A defendant may argue that the term should be limited to a circuit with these or similar characteristics.

  • The Term: "identification signal"

    • Context and Importance: This term defines the input that triggers the inventive functionality. Its construction will be critical to determining whether the communication protocol used by the Accused Products (e.g., USB-PD) generates a signal that falls within the claim scope.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The claim describes the signal simply as being "outputted by an electronic device" '876 Patent, claim 1, suggesting any device-to-socket communication for power negotiation could qualify.
      • Evidence for a Narrower Interpretation: The specification provides specific examples, such as signals on the "D+ and D- pins of the USB 2.0, SSRX and SSTX pins of the USB 3.0, CC1 and CC2 pins of the USB 3.1 type-C" '876 Patent, col. 3:42-49 A party could argue the term should be construed as limited to signals transmitted via these or analogous physical pins and protocols.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, stating that Defendant provides "specifications, instructions, manuals, advertisements, marketing materials, and technical assistance" that direct and encourage end-users to use the Accused Products in an infringing manner Compl. ¶21
  • Willful Infringement: The complaint includes a prayer for a judgment that infringement has been willful, which could lead to enhanced damages Prayer for Relief, C However, the complaint does not plead specific facts establishing that Defendant had pre-suit knowledge of the '876 Patent.

VII. Analyst's Conclusion: Key Questions for the Case

The resolution of this dispute will likely depend on the answers to two central questions:

  1. A question of definitional scope: Can the term "load detecting circuit," as described and claimed in the '876 Patent, be construed to read on the standardized power negotiation circuitry likely used in Defendant's "Power Delivery Wall Outlets"?

  2. A question of technical equivalence: Assuming the claim terms are construed broadly enough, does the specific way in which the accused outlets communicate with devices and adjust voltage operate in a manner that is the same as or equivalent to the method claimed in the patent, particularly concerning the generation and use of the "identification signal" and "control signal"?

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