American Tack & Hardware Co v. Snaprays

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: American Tack & Hardware Co. Inc. (New York)
  • Defendant: SnapRays, LLC DBA SnapPower (Utah)
  • Plaintiff’s Counsel: Barnes & Thornburg LLP; BOYLE FREDERICKSON SC
• Case Identification: 2:26-cv-00078, D. Utah, 01/30/2026
• Venue Allegations: Venue is alleged as proper in the District of Utah because Defendant SnapPower is a Utah company with its principal place of business in the district.
• Core Dispute: Plaintiff American Tack seeks a declaratory judgment that seven of Defendant SnapPower's patents related to powered electrical outlet cover plates are invalid.
• Technical Context: The technology concerns electrical outlet cover plates that draw power from an outlet's side-mounted screw terminals to power integrated features, such as night lights.
• Key Procedural History: This declaratory judgment action follows a prior patent infringement lawsuit, SnapPower v. American Tack, filed on May 21, 2024, in the Northern District of Texas. In that case, SnapPower was ordered to reduce its asserted claims from 115 to 20. American Tack alleges it has been procedurally precluded from presenting a full invalidity defense in the Texas case and has filed this action to do so.

Case Timeline

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

U.S. Patent No. 9,035,180 - Active Cover Plates

The Invention Explained

• Problem Addressed: The patent describes that the placement of screw terminals on electrical receptacles can vary significantly between different models and that installing an active cover plate that draws power from these terminals presents a compatibility challenge U.S. Patent 9,035,180, col. 3:25-40
• The Patented Solution: The patent proposes an active cover plate with electrical contacts whose vertical or horizontal position can be adjusted to align with the electrified portions of various receptacle bodies '180 Patent, Abstract col. 4:5-13 This adjustability allows a single cover plate design to be compatible with multiple different outlet configurations ('180 Patent, Fig. 3A-3C).
• Technical Importance: This approach to adjustability allows a single powered cover plate product to be marketed for use with a wider range of standard and non-standard electrical outlets, increasing its utility and potential market.

Key Claims at a Glance

• The complaint broadly refers to "the claims of the ‘180 patent that SnapPower has asserted against American Tack" without identifying specific independent claims for analysis Compl. ¶18

U.S. Patent No. 9,899,814 - Active Cover Plates

The Invention Explained

• Problem Addressed: The background of the patent family notes that modern outlets like Ground Fault Circuit Interrupters (GFCIs) can be wider than standard outlets, creating a "relatively small gap" between the side of the outlet and the electrical box, which makes it difficult for the prongs of a powered cover plate to reach the side screw terminals (U.S. Patent 10,109,945 B2, col. 3:4-16, incorporated by reference in the '814 patent).
• The Patented Solution: The '814 patent discloses an active cover plate with a resilient prong that can compress to fit through a narrow gap and then rebound to make electrical contact with a screw terminal '814 Patent, col. 7:42-50 The prong includes an insulating wall to prevent the conductive part from shorting against the electrical box '814 Patent, Fig. 10A
• Technical Importance: This resilient prong design enables powered cover plates to be compatible with bulky GFCI outlets, which are common in modern construction for safety reasons.

Key Claims at a Glance

• The complaint broadly refers to "the claims of the ‘814 patent that SnapPower has asserted against American Tack" without identifying specific independent claims for analysis Compl. ¶23

U.S. Patent No. 10,109,945 - Active Cover Plates

• Technology Synopsis: This patent discloses an active cover plate with a prong having a resilient, bow-shaped contact. The contact is designed to flatten as it passes through the narrow gap beside an electrical outlet and then rebound, with the ends of the contact moving apart to establish a secure connection with a side screw terminal (US10109945B2, col. 16:8-14).
• Asserted Claims: The complaint seeks a declaratory judgment of invalidity for claims of the '945 patent previously asserted by SnapPower Compl. ¶¶ 28, 30
• Accused Features: The complaint alleges the claims of the '945 patent are invalid based on prior art, in the context of SnapPower's previous assertion against American Tack's LumiCover and GloCover products Compl. ¶7

U.S. Patent No. 10,373,773 - Active Cover Plates

• Technology Synopsis: This patent describes an active cover plate with a prong comprising a metal clip that includes a conductive upright element and a resilient contact. The resilient contact is configured to bow outward through an aperture in an insulating material that overlays the conductive upright, allowing it to make electrical connection with a screw terminal (US10373773B2, col. 16:1-12).
• Asserted Claims: The complaint seeks a declaratory judgment of invalidity for claims of the '773 patent previously asserted by SnapPower Compl. ¶¶ 33, 35
• Accused Features: The complaint alleges the claims of the '773 patent are invalid based on prior art, in the context of SnapPower's previous assertion against American Tack's LumiCover and GloCover products Compl. ¶7

U.S. Patent No. 10,381,788 - Active Cover Plates

• Technology Synopsis: This patent focuses on an active cover plate with prongs that include a non-conductive ramp portion at the free end. The ramp is configured to guide the prong over the receptacle body and prevent the conductive portion from contacting a wall of the electrical box, while the prong resiliently deflects to make contact with a screw terminal (US10381788B2, col. 28:56-65).
• Asserted Claims: The complaint seeks a declaratory judgment of invalidity for claims of the '788 patent previously asserted by SnapPower Compl. ¶¶ 38, 40
• Accused Features: The complaint alleges the claims of the '788 patent are invalid based on prior art, in the context of SnapPower's previous assertion against American Tack's LumiCover and GloCover products Compl. ¶7

U.S. Patent No. 10,381,789 - Active Cover Plates

• Technology Synopsis: This patent discloses an active cover plate with a prong that includes an insulating element with at least three solid sides defining an interior space. This insulating element covers portions of an electrical contact to prevent shorting, while allowing the contact to extend from an open side to interface with a screw terminal on a receptacle (US10381789B2, col. 28:1-10).
• Asserted Claims: The complaint seeks a declaratory judgment of invalidity for claims of the '789 patent previously asserted by SnapPower Compl. ¶¶ 43, 45
• Accused Features: The complaint alleges the claims of the '789 patent are invalid based on prior art, in the context of SnapPower's previous assertion against American Tack's LumiCover and GloCover products Compl. ¶7

U.S. Patent No. 10,404,045 - Active Cover Plates

• Technology Synopsis: This patent describes a cover plate with a prong configured to deflect outward when interfacing with an outlet terminal and to contact the wall of the electrical box. This contact with the wall is purported to increase the contact pressure between the prong's electrical contact and the screw terminal (US10404045B2, col. 30:56-62).
• Asserted Claims: The complaint seeks a declaratory judgment of invalidity for claims of the '045 patent previously asserted by SnapPower Compl. ¶¶ 48, 50
• Accused Features: The complaint alleges the claims of the '045 patent are invalid based on prior art, in the context of SnapPower's previous assertion against American Tack's LumiCover and GloCover products Compl. ¶7

III. The Accused Instrumentality

Product Identification

American Tack's "powered cover plate products sold under the LumiCover and GloCover brands" Compl. ¶7 These are the products that SnapPower accused of infringement in the prior N.D. Texas litigation.

Functionality and Market Context

The complaint states that these products feature a "metal clip" Compl. ¶13 It alleges that the structure of this clip is "nearly identical" to a prior art design known as the "Keystone Clip" Compl. ¶13 The complaint presents a side-by-side photographic comparison of the metal clip used in American Tack's product and the prior art 'Keystone Clip,' alleging they are 'nearly identical' Compl. ¶13 The complaint does not provide further technical detail on the operation of the LumiCover and GloCover products.

IV. Analysis of Invalidity Allegations

The complaint is a declaratory judgment action focused exclusively on invalidity and does not contain infringement allegations or claim charts. For each of the seven patents-in-suit, the complaint makes a substantively identical allegation of invalidity.

'180 Patent Invalidity Allegations

American Tack alleges that the asserted claims of the '180 patent are invalid under 35 U.S.C. § 103 for being obvious Compl. ¶¶ 18-19 The specific invalidity theory is based on the combination of U.S. Patent 8,668,347 ("the '347 patent") and a known prior art metal clip design embodied in the "Keystone Clip" Compl. ¶19 To support this, the complaint provides a composite image juxtaposing a diagram from the '347 patent, which illustrates a powered cover plate, with a photograph of the prior art Keystone Clip, which embodies a metal clip design Compl. ¶19 The complaint asserts that this combination renders the claims of the '180 patent invalid Compl. ¶20

'814 Patent Invalidity Allegations

The complaint raises the same invalidity contention against the '814 patent as it does for the '180 patent. It alleges the asserted claims are invalid as obvious under 35 U.S.C. § 103 based on the combination of the '347 patent and the Keystone Clip Compl. ¶24 The complaint uses the same composite visual evidence to support this allegation Compl. ¶24 American Tack alleges this combination is one of the invalidity defenses it was precluded from raising in the prior N.D. Texas case Compl. ¶¶ 13, 15

V. Analyst’s Conclusion: Key Questions for the Case

• A primary question will be jurisdictional and procedural: given the prior-filed infringement action in the Northern District of Texas, will the District of Utah exercise jurisdiction over this subsequent declaratory judgment action, or will it be dismissed, stayed, or transferred under the first-to-file rule? American Tack's stated purpose for filing is to overcome alleged procedural bars in the Texas case, making this a central threshold issue.
• A core substantive issue will be one of obviousness: does the combination of the general powered cover plate design taught by the '347 patent and the specific metal clip structure of the "Keystone Clip" prior art render the claims of the seven Asserted Patents obvious under 35 U.S.C. § 103? The case presented by American Tack hinges almost entirely on this technical and legal determination.