IP Law Daily, PATENT—Fed. Cir.: Preliminary injunction in infringement lawsuit over electrical outlet-cover patent vacated on appeal, (Aug 6, 2026)

By Mandavi Singh, LL.M.

The district court misinterpreted key claim terms in finding likely infringement and erroneously relied on a presumption of irreparable harm abolished by the eBay U.S. Supreme Court decision.

The U.S. Court of Appeals for the Federal Circuit has vacated a preliminary injunction prohibiting an electrical outlet-cover seller from manufacturing, selling, or importing its accused product. The district court applied erroneous constructions of two claim terms when determining that the patent owner was likely to establish infringement, the appellate court held. Although the Federal Circuit did not decide whether the accused product infringed, it required the district court to reconsider the patent owner’s likelihood of success under the correct constructions (Socket Solutions, LLC v. Import Global, LLC, No. 25-1121 (Fed. Cir. Aug. 4, 2026)).

Outlet-cover dispute. Socket Solutions, LLC owns technology for low-profile electrical outlet covers. Import Global, LLC offers the accused Neat Socket product, which allows consumers to conceal a standard indoor electrical outlet while continuing to use it.

Socket Solutions owns U.S. Patent No. 9,509,080 (the ’080 patent), which covers an apparatus designed to hide the contact openings of an indoor wall outlet. The cover incorporates electrical prongs that connect to the outlet, and a cord extending from the cover to one or more receptacles at a remote location. Asserted claim 19 requires a cover comprising a “frontplate” and a “backplate.” Socket Solutions sued Import Global for patent infringement in the Southern District of Florida and sought a preliminary injunction. The district court adopted recommendations concerning claim construction and preliminary relief and found that Socket Solutions was likely to prove infringement.

The resulting injunction prohibited Import Global from manufacturing, using, selling, offering to sell, or importing the Neat Socket product in the United States. It also covered products that were not more than colorably different from Neat Socket under the ’080 patent and barred Import Global from inducing others to engage in the prohibited conduct. Import Global appealed, challenging the district court’s constructions of claim terms “backplate” and “pin.” It also disputed the finding that Socket Solutions would suffer irreparable harm without preliminary relief.

Meaning of “backplate.” The district court construed “backplate” as the component of the cover opposing the frontplate and containing at least one set of electrical prongs. Import Global argued that the backplate instead meant the portion of the apparatus closest to the wall outlet when the apparatus was plugged in.

The Federal Circuit rejected both constructions. Neither the claim language nor the specification required the backplate to be defined spatially by reference to the frontplate or the wall outlet.

Citing Phillips v. AWH Corp., 415 F.3d 1303, 1316 (Fed. Cir. 2005) (en banc), the appellate court explained that the correct construction should remain faithful to the claim language and align naturally with the patent’s description of the invention. The specification repeatedly described the backplate in connection with the thickness of the cover formed by combining it with the frontplate.

The Federal Circuit therefore construed “backplate” as the component that forms the cover with the frontplate, with the cover’s maximum thickness measured at its central portion by the distance between those components. The district court also erred by incorporating electrical prongs into the definition because claim 19 separately imposed that requirement.

Meaning of “pin.” The district court construed “pin” as a means for making an electrical connection between a wire and the corresponding prong. According to Import Global, that construction improperly converted an identified structural component into a means-plus-function limitation governed by 35 U.S.C. §112(f).

The Federal Circuit agreed that the district court’s construction was erroneous. Under Williamson v. Citrix Online, LLC, 792 F.3d 1339, 1348–49 (Fed. Cir. 2015), a claim term that does not use the word “means” is presumed not to invoke Section 112(f). That presumption may be overcome if the term fails to identify a sufficiently definite structure or merely recites a function without adequate supporting structure.

The term “pin” did not use “means,” and the specification described pins structurally, including bent pins at approximately 90 degrees and pins connected via electrical prongs. The parties also agreed that a skilled artisan would understand a pin to constitute a structure. Nothing overcame the presumption against applying Section 112(f).

Socket Solutions proposed defining a pin functionally as any structure physically and electrically connecting the wires to the prongs. The court found the construction excessively broad because not every component performing that function would be understood as a pin. It also rejected Import Global’s proposed “mechanical system” construction as unsupported by the specification. The term instead received its plain and ordinary meaning as understood by a skilled artisan.

Irreparable harm. Because the erroneous constructions undermined the likelihood-of-success analysis, the Federal Circuit did not decide Import Global’s irreparable-harm challenge. It nevertheless instructed the district court not to presume irreparable harm from a strong showing of patent validity and infringement.

In eBay Inc. v. MercExchange, L.L.C., 547 U.S. 388, 393–94 (2006), the U.S. Supreme Court rejected a patent-specific rule favoring injunctive relief and required courts to apply traditional equitable principles. The Federal Circuit later confirmed in Robert Bosch LLC v. Pylon Manufacturing Corp., 659 F.3d 1142, 1149 (Fed. Cir. 2011), that eBay eliminated the presumption of irreparable harm.

Although those cases addressed permanent injunctions, the court found no reason to apply a different rule to preliminary injunctions. The district court’s order did not make clear whether it had actually relied on the presumption. If it revisited irreparable harm on remand, however, it had to evaluate the evidence without that presumption.

Thus, the Federal Circuit vacated the preliminary injunction, awarded appellate costs to the outlet-cover seller, and remanded for reconsideration without resolving the ultimate infringement dispute.

The Case is No. 25-1121.

Judge: Moore, K.

Attorneys: Edward H. Rice (Rice Technology Law Group) for Socket Solutions, LLC. Timothy W. Johnson (Mitby Pacholder Johnson PLLC) for Import Global, LLC.

Companies: Socket Solutions, LLC; Import Global, LLC

Cases: Patent FedCirNews