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Federal Circuit Vacates Preliminary Injunction Over Claim Construction Errors And Rejects Presumption Of Irreparable Harm
08/18/2026In Socket Solutions, LLC, v. Import Global, LLC, No. 2025-1121(Fed. Cir. Aug. 4, 2026), the Federal Circuit vacated the district court's grant of a preliminary injunction barring Import Global from manufacturing, selling, or importing its Neat Socket product, holding that the district court erred in construing the patent claim terms “backplate” and “pin” and in relying on a presumption of irreparable harm. The decision confirms that the presumption of irreparable harm in patent cases does not survive eBay Inc. v. MercExchange, LLC, 547 U.S. 388 (2006), in the preliminary injunction context.
Plaintiff owns U.S. Patent No. 9,509,080, directed to an indoor electrical wall outlet cover that permits use of a wall outlet while concealing the outlet contact openings. Plaintiff alleged that the defendant’s accused product infringed claim 19 of the ’080 patent and moved for a preliminary injunction. The magistrate judge issued reports and recommendations on claim construction and on the preliminary injunction motion, both of which the district court adopted. The resulting injunction barred the defendant from manufacturing, using, selling, offering to sell, or importing the accused product and other products “not more than colorably different” in the context of the ’080 patent.
On appeal, the appellants challenged the district court’s construction of the claim terms “backplate” and “pin.” With respect to “backplate,” the district court had construed the term to mean “the component of the cover, opposing the frontplate, that includes at least one set of electrical prongs.” The appellants proposed that “backplate” should mean the “portion of the apparatus closest to the wall outlet when the apparatus is plugged into the wall outlet.” The Federal Circuit rejected both constructions, holding that each improperly imposed spatial reference requirements that the specification did not support. Instead, the Court adopted a construction focused on cover thickness, defining “backplate” as “the component forming the cover with the frontplate, such that the maximum thickness of the cover is the distance, at the central portion of the cover, between the frontplate and the component.” The Court reasoned that this construction was best aligned with the specification, which explicitly defines cover thickness in relation to the backplate.
Regarding “pin,” the Federal Circuit agreed with the appellant that the district court improperly construed the term as a means-plus-function limitation under 35 U.S.C. § 112(f). Because “pin” does not use the word “means,” a presumption against means-plus-function treatment applies. The Court found that the presumption was not overcome, noting that the written description defines “pin” in structural terms and that the parties did not dispute that “pin” is understood by skilled artisans to be a structure. The Court also rejected the appellee’s argument that “pin” should be construed in purely functional terms as “a structure that physically and electrically connects the electrical wires to the corresponding electrical prongs,” holding that such a definition would be overly broad. The Court concluded that “pin” should be given its plain and ordinary meaning as understood by a skilled artisan.
Finally, the Federal Circuit addressed the district court’s reliance on a presumption of irreparable harm, holding that such a presumption “cannot be justified” after the Supreme Court’s decision in eBay. The Court noted that although eBay and its progeny involved permanent injunctions, there is “no reason to depart from their holdings in the preliminary injunction context.” While the Court acknowledged it was unclear whether the district court actually applied the presumption or merely noted its existence, it instructed the district court to “analyze irreparable harm in a manner that does not rely on the presumption, if it reaches this issue on remand.”
The decision is notable for patent litigants in that the explicit extension of the eBay framework to the preliminary injunction context reinforces that all four traditional equitable factors must be separately established.
IP Litigation