O’Reilly Winship v. SnapRays — Federal Circuit Revives Cover-Plate Patent Claims

Background

SnapRays LLC, doing business as SnapPower, and O’Reilly Winship LLC, doing business as OWL, compete in the market for powered electrical-outlet cover plates. SnapPower owns U.S. Patent Nos. 9,871,324 and 9,035,180, which describe cover plates that draw power from an outlet to operate built-in loads such as night lights. After OWL began selling its BriteOWL cover plates, SnapPower sent demand letters and submitted infringement notices concerning OWL’s Amazon listings.

OWL sued in the Northern District of Texas for a declaration that its products did not infringe. SnapPower counterclaimed for infringement. The district court granted summary judgment of noninfringement across the asserted claims and denied SnapPower’s motion for partial summary judgment of infringement. SnapPower appealed several claim-construction and infringement rulings.

The Court’s Holding

The Federal Circuit reversed the noninfringement ruling for claim 1 and several dependent claims of the ’324 patent. The district court had effectively required the claimed contact to be fastened to the resilient strip in some additional way before it could be “joined to” that strip. The appellate court found no support for that extra restriction in the claim language or specification. The specification used “joined” broadly and listed numerous attachment techniques, while the accused contact rested in a hole in the spring clip and was held there by a rear cover. Under the term’s ordinary meaning, that arrangement satisfied the disputed limitation.

Because the “joined to” limitation was the only remaining dispute for certain claims, the court directed entry of partial summary judgment that OWL infringed claims 1, 2, and 8 of the ’324 patent. It remanded claims 4, 9, and 10 for further proceedings because those claims had not been included in SnapPower’s partial-summary-judgment motion.

The court affirmed noninfringement for the other challenged claims. For the ’180 patent’s “configured to contact” limitation, evidence that the spring clips might touch an unusually narrow receptacle box showed capability, not that the product was designed to make that contact. It also upheld the construction of “sandwiched between” as requiring some direct contact with both insulators, rejected reliance on a patent drawing that was not stated to scale, and agreed that a translucent cover was not one of the claimed physical “apertures.” The result was a mixed disposition: reversed in part, affirmed in part, vacated in part, and remanded.

Key Takeaways

• A court should not add an unspecified fastening requirement to a broad relational term such as “joined” when the claims and specification do not impose it.
• When parties agree that “configured to” means “designed to,” proof that an accused product can perform the function only in an outlier setting may not establish infringement.
• Patent drawings that are not identified as drawn to scale are weak support for dimensional claim-construction arguments.
• A claim-by-claim appeal can produce an immediate infringement ruling for some claims while preserving noninfringement for others.

Why It Matters

The opinion illustrates how a seemingly ordinary word can decide infringement. A trial court’s unstated narrowing of “joined” eliminated liability at summary judgment; restoring the term’s ordinary breadth required judgment of infringement on three claims. Patent owners and accused infringers should therefore test proposed constructions against the full specification and identify whether an infringement argument depends on adding a mechanical detail that the patent never requires.

The decision also distinguishes design from mere capability. An accused product does not necessarily satisfy a “configured to” limitation simply because it can perform the recited function under an unusual condition. That distinction can be decisive for product designs intended to work across standardized physical environments.