O’Reilly Winship v. Snaprays: briteOWL Outlet Cover Patent Battle Ends After 1,161 Days
O’Reilly Winship LLC (OWL) sought a declaratory judgment of noninfringement against SnapPower’s outlet cover backup-lighting patents — US9035180B2 and US9871324B2 — covering its briteOWL product. The Northern District of Texas granted OWL’s summary judgment motion, leaving SnapPower’s patent counterclaims dismissed with prejudice after more than three years of litigation.
Declaratory Judgment Win for briteOWL Maker After Three-Year Patent Fight
O’Reilly Winship LLC filed this declaratory judgment action on November 2, 2021 in the Northern District of Texas before Judge David C. Godbey, seeking a ruling that its briteOWL product — an electrical outlet cover providing backup lighting during power failures — did not infringe two patents held by Snaprays LLC, doing business as SnapPower: US9035180B2 and US9871324B2. Both patents relate to outlet cover plate technology that integrates electrical functionality, and SnapPower had asserted them as counterclaims against OWL’s product.
On November 19, 2024, the court granted OWL’s motion for summary judgment of noninfringement on both patents and partially granted SnapPower’s motion for partial summary judgment, resolving all claims except SnapPower’s Texas Citizens Participation Act (TCPA) counterclaim. On December 19, 2024, the parties stipulated to the dismissal of that remaining TCPA claim, enabling entry of final judgment. The judgment ordered SnapPower to take nothing on its patent infringement counterclaims — dismissed with prejudice — and OWL to take nothing on its tortious interference claim, also dismissed with prejudice. Court costs were taxed against SnapPower.
At 1,161 days, this case ran well beyond the median for patent declaratory judgment actions, suggesting hard-fought claim construction and infringement disputes. The stipulated dismissal of the TCPA counterclaim days before Christmas 2024 likely reflects a negotiated clean-up rather than a contested resolution of that issue. The public record does not disclose whether a commercial settlement accompanied the stipulation, nor what drove OWL to seek declaratory judgment rather than await enforcement — though SnapPower’s counterclaims confirm it would have sued.
Filing to Mixed Judgment in 1161 days
1,161 days — above average for a district court patent declaratory judgment case
Summary judgment for OWL: what the noninfringement ruling means for both parties
Summary judgment of noninfringement: no genuine dispute on the key facts
A summary judgment of noninfringement means the court found no genuine dispute of material fact — OWL’s briteOWL product, as a matter of law, does not meet every limitation of the asserted claims in US9035180B2 and US9871324B2. SnapPower could not survive this threshold, suggesting claim construction likely resolved one or more elements against it. The dismissal with prejudice forecloses any re-litigation of these counterclaims on the same facts.
Noninfringement as a matter of lawSnapPower exits with no damages and costs taxed against it
SnapPower’s patent infringement counterclaims on both outlet cover patents are dismissed with prejudice — it cannot reassert them against OWL for the briteOWL product. Court costs have been taxed against SnapPower, adding financial consequence to the substantive loss. Its TCPA counterclaim was disposed of by stipulation rather than adjudication, so no merits ruling exists on that claim. The patents themselves remain valid and potentially enforceable against other parties.
Counterclaims dismissed with prejudiceOWL secures noninfringement but loses its tortious interference claim
OWL achieved its primary objective: a final ruling that the briteOWL does not infringe SnapPower’s outlet cover patents, with SnapPower bearing court costs. However, OWL’s own tortious interference claim was also dismissed with prejudice, meaning it obtained no affirmative damages. The outcome clears OWL’s path to continue selling briteOWL without the overhang of these specific patent claims, though SnapPower’s patents remain a theoretical risk for design variants.
Noninfringement confirmed; no affirmative damagesOutlet cover tech sector: noninfringement ruling clarifies competitive space
The ruling is consistent with a narrower-than-expected claim scope for SnapPower’s outlet cover backup-lighting patents, which typically signals opportunity for competitors to design around the asserted claims. Companies developing smart or emergency-lighting outlet covers should note that the briteOWL’s specific architecture was found non-infringing — but SnapPower’s patents survive and could still be asserted against products with different designs. FTO analysis against US9035180B2 and US9871324B2 remains relevant for market entrants.
Design-around space confirmedFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | O’Reilly Winship LLC | Company | Backup-lighting outlet cover maker — holder of briteOWL product, declaratory judgment seekerSearch in Eureka ↗ |
| Defendant | Snaprays LLC | Company | SnapPower — outlet cover technology company asserting US9035180B2 and US9871324B2Search in Eureka ↗ |
| Plaintiff counsel | David W. Carstens | Attorney | Counsel for O’Reilly Winship LLCSearch in Eureka ↗ |
| Plaintiff counsel | James Andrew Reed | Attorney | Counsel for O’Reilly Winship LLCSearch in Eureka ↗ |
| Plaintiff counsel | Matthew Conner Hutchisson | Attorney | Counsel for O’Reilly Winship LLCSearch in Eureka ↗ |
| Plaintiff counsel | Theodore G. Baroody | Attorney | Counsel for O’Reilly Winship LLCSearch in Eureka ↗ |
| Plaintiff law firm | Carstens, Allen & Gourley, LLP | Law Firm | Representing O’Reilly Winship LLCSearch in Eureka ↗ |
| Plaintiff law firm | Think Differently Legal PLLC | Law Firm | Representing O’Reilly Winship LLCSearch in Eureka ↗ |
| Defendant counsel | Elliott James Williams | Attorney | Counsel for Snaprays LLCSearch in Eureka ↗ |
| Defendant counsel | Michael C. Smith | Attorney | Counsel for Snaprays LLCSearch in Eureka ↗ |
| Defendant law firm | Scheef & Stone, LLP | Law Firm | Representing Snaprays LLCSearch in Eureka ↗ |
| Defendant law firm | Stoel Rives LLP – Portland | Law Firm | Representing Snaprays LLCSearch in Eureka ↗ |
| Presiding judge | Judge David C. Godbey | Judge | Texas Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The final judgment is notable for its structural symmetry: both parties take nothing on their affirmative claims. OWL’s noninfringement win is clean and with prejudice, foreclosing re-litigation on the briteOWL product. The partial grant of SnapPower’s summary judgment motion — not detailed in the final judgment — suggests some claim limitations or defenses were resolved in SnapPower’s favor, even as the ultimate infringement determination went to OWL. The TCPA claim’s stipulated resolution adds a procedural layer not adjudicated on the merits.
US9035180B2 & US9871324B2 — Electrical outlet cover backup lighting technology
US9035180B2 (application no. US14/066621) and US9871324B2 (application no. US15/486273) both relate to electrical outlet cover plates that integrate active electrical components — specifically backup or auxiliary lighting — directly into the cover plate housing. This architecture allows the device to draw power from the wall outlet without requiring battery installation or separate wiring, a technically differentiated approach relative to conventional passive covers. The two patents likely represent continuation or improvement filings, with the later application building on the foundational claims of the earlier grant.
For the smart home and building safety sectors, these patents represent a strategically valuable position: outlet cover replacement products are a low-friction consumer installation category with a large installed base. Any entrant offering emergency lighting, USB charging, or smart control via an outlet cover must evaluate these patents carefully. The noninfringement ruling for briteOWL narrows — but does not eliminate — the risk these patents pose. SnapPower has demonstrated willingness to litigate, making FTO clearance essential for competing product launches.
Should you run an FTO against US9035180B2 and US9871324B2?
Any R&D team developing outlet cover products with integrated lighting, backup power, or smart home functionality — whether for residential, commercial, or hospitality markets — should treat these two SnapPower patents as live risks. The briteOWL noninfringement ruling is product-specific and fact-specific; a different outlet cover architecture could land on the wrong side of the claim construction that OWL survived. The patents remain in force.
PatSnap Eureka’s FTO Search Agent can map your product’s feature set against the asserted claims of US9035180B2 and US9871324B2, identify relevant prosecution history that shaped claim scope in this case, and flag continuation applications or related family members that SnapPower may hold. This is particularly valuable before a product launch or licensing negotiation in the outlet cover category.
Run a freedom-to-operate analysis on US9035180B2 to assess your product’s exposure
Run FTO in Eureka →Similar Patent Cases: Outlet Cover & Smart Home Hardware Disputes
Explore declaratory judgment and patent infringement cases involving smart home hardware and outlet cover technology litigated in Texas federal district courts.
What this case signals for the outlet cover and smart home IP landscape
A summary judgment win after 1,161 days clarifies noninfringement boundaries for backup-lighting outlet covers but leaves SnapPower’s patents standing.
Declaratory judgment as offensive IP strategy in hardware startups
OWL’s decision to file for declaratory judgment — rather than wait for SnapPower to sue — gave it control over venue and timing. Northern District of Texas can move slower than some districts, but the ultimate outcome vindicates the approach. Hardware companies facing informal patent threats from established players should weigh DJ filing carefully.
Summary judgment of noninfringement: what it takes and what it costs
Winning summary judgment on noninfringement after 1,161 days suggests claim construction battles were pivotal. The cost award against SnapPower is modest signaling, not fee-shifting under 35 U.S.C. § 285. Neither party sought — or obtained — an exceptional case finding based on the public record.
O’Reilly v Snaprays — key questions answered
The Northern District of Texas granted plaintiff OWL’s motion for summary judgment of noninfringement on SnapPower’s two outlet cover patents (US9035180B2 and US9871324B2). SnapPower’s patent infringement counterclaims were dismissed with prejudice, and court costs were taxed against SnapPower. OWL’s tortious interference claim was also dismissed with prejudice. Final judgment was entered January 6, 2025.
SnapPower asserted US9035180B2 (application US14/066621) and US9871324B2 (application US15/486273), both covering electrical outlet cover plates with integrated lighting or power delivery functionality. The court found OWL’s briteOWL — an outlet cover providing backup lighting during power failures — did not infringe either patent as a matter of law.
Summary judgment of noninfringement means the court found no genuine dispute of material fact — OWL’s product did not meet every limitation of the asserted claims as a matter of law. Critically, this ruling does not invalidate the patents; US9035180B2 and US9871324B2 remain valid and SnapPower can still assert them against other products or companies whose designs differ from the briteOWL.
The public record does not specify the exact pre-litigation communications, but filing a declaratory judgment action is a common strategy when a patent holder has signaled infringement concerns. By filing first, OWL secured its preferred venue — Northern District of Texas — and controlled the litigation timeline. The fact that SnapPower immediately asserted patent infringement counterclaims confirms that a lawsuit was effectively inevitable.
After the court’s November 19, 2024 summary judgment ruling resolved all other claims, the parties stipulated on December 19, 2024 to the dismissal of SnapPower’s remaining TCPA counterclaim. The public record does not indicate the terms of that stipulation or whether any consideration was exchanged. The TCPA claim was not adjudicated on the merits.
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