Staying True to the Specification: Federal Circuit Vacates Preliminary Injunction Based on Unsupported Claim Constructions

In Socket Solutions, LLC v. Import Global, LLC, No. 2025-1121 (Fed. Cir. Aug. 4, 2026), the Federal Circuit vacated a preliminary injunction against defendant Import Global’s Neat Socket® electrical outlet cover product, holding that the district court erred in its claim construction analysis.

Socket Solutions sued Import Global, alleging that the accused product infringed its patent directed to an outlet cover apparatus that permits use of a wall outlet while concealing the outlet contact openings. Adopting the magistrate judge’s claim-construction recommendations, the district court issued a preliminary injunction enjoining Import Global from selling the accused product.

On appeal, the Federal Circuit vacated the preliminary injunction, finding that the district court’s likelihood-of-success analysis relied on erroneous constructions of the terms “backplate” and “pin.” As to the backplate term, the Federal Circuit rejected the district court’s construction that imposed an unsupported negative limitation regarding its location. Regarding the pin term, the Federal Circuit held that there was no basis in the record to depart from the plain and ordinary meaning of the term, and that a purely functional description would be overly broad. The Court further held that the district court erred to the extent that it applied a presumption of irreparable harm.