Socket Solutions, LLC v. Import Global, LLC

Socket Solutions, LLC v. Import Global, LLC The Federal Circuit held that the district court’s likelihood-of-success analysis rested on erroneous constructions of “backplate” and “pin.” It vacated the preliminary injunction and remanded, also noting that any presumption of irreparable harm for patent injunctions is unavailable after eBay. The decision reinforces that preliminary injunctions in patent cases remain vulnerable when claim construction is unsettled or incorrect, and that irreparable harm must be proven without any patent-specific presumption. Vacated and remanded; costs awarded to Import Global. The asserted claim covered an apparatus for hiding an indoor electrical wall outlet while allowing continued use, with disputed limitations involving a “backplate” and electrical “pin.” The court rejected both the district court’s and Import Global’s spatial-reference constructions of “backplate,” construing it by reference to the cover structure and the maximum cover thickness at the central portion. The court held “pin” was not a § 112(f) means-plus-function term because the claim did not use “means,” the specification described pins structurally, and the parties did not dispute that skilled artisans would understand “pin” as structure. The court declined to adopt a purely functional or “mechanical system” construction for “pin,” instead giving the term its plain and ordinary meaning. Because the likelihood-of-success analysis depended on erroneous claim constructions, the court vacated the preliminary injunction and did not reach the merits of irreparable harm, except to reject reliance on any post-eBay presumption. claim construction § 112(f) infringement injunction / stay remand precedential claim construction § 112(f) infringement injunction / stay precedential remand claim construction § 112(f) injunction / stay remand