The dispute
According to the opinion, SnapRays, LLC, which does business as SnapPower, and O'Reilly Winship LLC, which does business as OWL, compete in lighted cover plates for outlets and light switches. After OWL began selling its BriteOWL active cover plates in 2019, SnapPower sent demand letters and submitted infringement notifications against the products' Amazon listings. OWL sued in the Northern District of Texas on November 2, 2021, No. 3:21-cv-02719, for a declaration of noninfringement, and SnapPower counterclaimed on the '324 and '180 patents. On November 18, 2024, Judge David C. Godbey granted OWL summary judgment of noninfringement and denied SnapPower's motion for partial summary judgment of infringement.
"Joined" in claim 1 of the '324 patent
Claim 1 recites an active cover plate with a face plate, an electrical load, and at least one clip extending rearward from the faceplate. The clip has a contact, "a resilient strip supporting a front side of the contact, wherein the contact is joined to the resilient strip and extends through an aperture in the resilient strip," and a rear insulator covering a rear side of the contact, and the claim requires an electrical connection between the clip and the load. The district court had declined to construe "joined," then held at summary judgment that OWL's contact, which rests inside a hole in the spring clip and is held in place by a separate rear cover attached to the resilient strip, was not joined, because being joined "requires more than just being inserted through a hole and supported from behind."
The panel of Judges Chen, Hughes, and Cunningham, in an opinion by Judge Hughes, disagreed. The claim does not specify how the contact is joined, and the specification says parts "may be joined" by adhesive, heat welding, press fit, snap fit, and other techniques, which the court read as supporting a broad meaning. Nothing in the '324 patent, the court said, suggests that "joined" and "support" are so distinct, and the dictionary definitions the district court cited could not narrow the claim when the specification did not. Under the plain and ordinary meaning, the court said, "there is no question" that the accused products meet the only disputed limitation. It reversed on claims 1, 2, 4, 8, 9, and 10, remanded with instructions to grant partial summary judgment of infringement on claims 1, 2, and 8, and remanded claims 4, 9, and 10, which were not part of SnapPower's motion, for further proceedings.
The affirmances
Claim 11 of the '180 patent requires a portion of the spring clip "configured to contact a wall of a receptacle box." Applying the parties' agreed meaning of "configured to," "designed to," the court agreed that a product designed to touch the wall "would do so for more than the narrowest outlier receptacle box"; OWL's clips, about 2 to 2.15 inches wide, do not contact the wall of a standard 2.25-inch box. It affirmed noninfringement of claims 11, 12, 13, and 15 of the '180 patent.
The court also upheld the construction of "sandwiched between" in claim 13 of the '324 patent as requiring both the front and rear insulators to come into some direct contact with the conductor, affirming as to claims 13, 14, and 15. It upheld "aperture" as a physical opening, so OWL's single opening covered by translucent plastic did not meet the "three spaced apertures" limitation of claim 17, affirming as to claims 17, 19, 20, 23, and 25 and rejecting SnapPower's doctrine of equivalents argument. And it affirmed as to claims 1, 2, 3, 5, and 6 of the '180 patent, of which claim 1 is representative and recites a spring clip with a flexible conductive portion, because the district court's analysis followed SnapPower's own mapping of the accused products' wire to that portion. The judgment line reads reversed-in-part, affirmed-in-part, vacated-in-part, and remanded, with no costs. The decision is nonprecedential.
What to watch next
Watch for any petition for rehearing, the mandate, and proceedings on remand, including entry of partial summary judgment of infringement on claims 1, 2, and 8 and further proceedings on claims 4, 9, and 10 of the '324 patent. The case can end at any time by settlement or dismissal.