In Socket Solutions LLC v. Import Global LLC, No. 2025-1121 (Fed. Cir. Aug. 4, 2026), the Federal Circuit vacated a preliminary injunction and remanded after concluding that the district court erred in construing two claim terms in its likelihood-of-success analysis.
Socket Solutions owns U.S. Patent No. 9,509,080, directed to an indoor wall outlet cover that conceals the outlet contacts and includes a cord and power strip so that furniture can be placed flush against the wall. Socket sued Import Global for infringement and moved for a preliminary injunction. The district court granted the injunction, based on in part on construing “backplate” as a component of the “cover” relative to the “frontplate” and construing “pin” as a means for making an electrical connection between the wires and prongs. Import Global appealed, arguing that the injunction analysis was flawed because both terms had been misconstrued.
On “backplate,” the Federal Circuit rejected both the district court’s construction and Import Global’s proposed construction because each imposed a spatial reference requirement that the specification does not require. Because the specification defines the thickness of the cover in relation to the backplate, the Federal Circuit construed “backplate” as “the component forming the cover with the frontplate, such that the maximum thickness of the cover is the distance … between the frontplate and the component.”
On “pin,” the Federal Circuit held that the district court erred in applying a means-plus-function construction. The Federal Circuit reasoned that term does not use the word “means,” giving rise to a rebuttable presumption against means-plus-function interpretation, that the written description defines “pin” in structural terms, and that the parties did not dispute that a skilled artisan would understand “pin” to denote structure. The Federal Circuit found that a purely functional definition of “pin” would be overly broad. The Federal Circuit also rejected Import Global’s proposed construction as unsupported by the specification. Finding no definition in the specification departing from the ordinary meaning and no prosecution history suggesting otherwise, the Federal Circuit held that “pin” carries its plain and ordinary meaning as understood by a skilled artisan.
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