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Socket Solutions v. Yuyao Zhuoli: Outlet Cover Patent Infringement & Permanent Injunction | PatSnap
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Case ID1:23-cv-15594
FiledNov 2023
ClosedFeb 2024
Patent Litigation

Socket Solutions v. Yuyao Zhuoli: Default Judgment & Permanent Injunction in 110 Days

Socket Solutions, LLC secured a permanent injunction and full default judgment against Chinese manufacturer Yuyao Zhuoli Wire Cable Factory for infringing two outlet cover patents and falsely passing off products as genuine Sleek Socket® goods. The case resolved in just 110 days — the defendant never appeared in court.

Resolution time
110days
110 days from filing to permanent injunction — faster than the vast majority of contested patent cases
Patents asserted
2
US9509080B1 and US11450997B1 — single-cord and dual-cord wall outlet cover patents
Outcome
Injunction Granted
Default judgment and permanent injunction — Zhuoli barred from all U.S. sales and imports
Cost ruling
Full Judgment
Judgment entered on all claims; Zhuoli also found liable under the Lanham Act
Published by PatSnap Insights Team · Verified by PatSnap Eureka Data
Case overview

Swift default judgment in the electrical safety accessory IP space

Socket Solutions, LLC filed suit on November 2, 2023, in the U.S. District Court for the Northern District of Illinois against Yuyao Zhuoli Wire Cable Factory, a Chinese wire and cable manufacturer. The complaint alleged direct and induced infringement of U.S. Patent No. 9,509,080 (the ‘080 Patent) via single-cord wall outlet covers, and direct infringement of U.S. Patent No. 11,450,997 (the ‘997 Patent) via dual-cord outlet covers, both sold through Alibaba.com into the U.S. market. Socket Solutions also alleged Lanham Act violations for false safety certification markings and counterfeit Sleek Socket® branding.

Because Zhuoli never appeared, answered, or sought an extension, the court entered a default on December 27, 2023, and on February 20, 2024, issued a comprehensive judgment and permanent injunction. The injunction bars Zhuoli, its affiliates, officers, agents, and anyone acting in concert with them from manufacturing, selling, offering to sell, or importing the infringing outlet covers into the United States — covering products not more than colorably different from those at issue. The Lanham Act finding additionally prohibits Zhuoli from representing to any customer that it sells genuine Sleek Socket® products.

The 110-day timeline is consistent with default proceedings where a foreign defendant declines to engage with U.S. process. No contested merits briefing occurred, so the court’s infringement findings rest on Socket Solutions’ uncontested allegations and the complaint record. What remains unknown from the public docket is whether any damages were separately awarded or if enforcement proceedings have been initiated to block Zhuoli’s Alibaba storefronts — issues that frequently arise after cross-border default injunctions of this kind.

Case at a glance
Case no.1:23-cv-15594
CourtIllinois Northern
JudgeJeffrey I Cummings
FiledNovember 2, 2023
ClosedFebruary 20, 2024
Duration110 days
OutcomeInjunction Granted
Verdict causeInfringement Action
BasisInjunction Granted
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Case timeline

Filing to settlement in 110 days

110 days from filing to permanent injunction — faster than the vast majority of contested patent cases

Case timeline: Complaint filed May 13 2025, DEC–JAN — 110 days total Horizontal timeline showing the three key events in Socket Solutions, LLC v Yuyao Zhuoli Wire Cable Factory from filing to voluntary dismissal. Source: PACER, Illinois Northern District Court. NOV 2 2023 Complaint filed DEC–JAN 2023 Pre-trial proceedings FEB 20 2024 Resolved consent judgment 110 DAYS TOTAL
Court ruling

Default judgment and permanent injunction entered against Zhuoli on all claims

Default judgment

What a default judgment means — and its limits

A default judgment is entered when a defendant fails to appear or respond. The court accepts the plaintiff’s well-pleaded allegations as true and enters judgment without a contested merits trial. Here, Zhuoli’s non-appearance led to an uncontested finding of infringement on both patents. Importantly, the judgment is as legally binding as a litigated one — but enforcing it against a China-based entity involves distinct practical challenges.

Uncontested liability finding
Permanent injunction

Permanent injunction: scope and enforceability

The permanent injunction covers not just the named products but any outlet cover ‘not more than colorably different’ — a deliberately broad formulation that captures design-arounds. It binds Zhuoli’s parents, subsidiaries, officers, agents, and those acting in concert. Cross-border enforcement typically requires separate action: U.S. Customs recordation, ITC exclusion orders, or platform takedowns are common follow-on steps not visible in this docket.

Broad product scope
Lanham Act claim

False advertising and counterfeit branding compounds liability

Beyond patent infringement, the court found Zhuoli violated Section 43(a) of the Lanham Act by affixing false safety certifications, claiming ‘Enhanced Safety,’ and falsely representing products as genuine Sleek Socket® goods. This dual-track liability — patent plus trade dress/false advertising — is a common enforcement strategy against overseas counterfeiters, and can support additional remedies including damages and platform-level enforcement.

Lanham Act § 43(a) violation
Cross-border enforcement

Enforcing a U.S. judgment against a Chinese manufacturer

China does not automatically recognise or enforce U.S. civil judgments. Practical enforcement of this injunction is likely to rely on U.S. Customs recordation of the patents, e-commerce platform takedown requests directed at Alibaba, and potentially a Section 337 ITC complaint if infringing imports persist. The Alibaba.com sales channel identified in the complaint gives Socket Solutions a concrete platform enforcement avenue without requiring cooperation from Zhuoli.

Customs & platform enforcement
Legal analysis based on PACER docket records for case 1:23-cv-15594 and PatSnap Eureka litigation intelligence Search PatSnap Eureka ↗
Parties and representation

Full party and counsel information

RoleNameTypeDetail
PlaintiffSocket Solutions, LLCCompanyElectrical safety accessory IP holder — owner of outlet cover patents ‘080 and ‘997Search in Eureka ↗
DefendantYuyao Zhuoli Wire Cable FactoryCompanyYuyao Zhuoli Wire Cable Factory — Chinese wire and cable manufacturer selling via Alibaba.comSearch in Eureka ↗
Plaintiff counselEdward H. RiceAttorneyCounsel for Socket Solutions, LLCSearch in Eureka ↗
Plaintiff counselMarina N. SaitoAttorneyCounsel for Socket Solutions, LLCSearch in Eureka ↗
Presiding judgeJudge Jeffrey I CummingsChief JudgeIllinois Northern District Court — Chief JudgeSearch in Eureka ↗
Official verdict

Stipulation of dismissal — official text

“IT IS HEREBY ORDERED, ADJUDGED AND DECREED that: 1. This Court has jurisdiction over the subject matter of this patent infringement action under 28 U.S.C. §§ 1331 and 1338(a). This Court also has jurisdiction to enter and enforce this Judgment and Permanent Injunction. 2. This Court has jurisdiction over the parties, Plaintiff Socket Solutions, LLC, and Defendant Yuyao Zhuoli Wire Cable Factory (“Zhuoli”). 3. Venue is proper in this judicial district under 28 U.S.C. §§ 1400 and 1391(c)(3). 4. Socket Solutions is the assignee and owner of all right, title and interest in and to U.S. Patent Nos. 9,509,080 (“the ‘080 Patent”) and 11,450,997 (“the ‘997 Patent”). 5. The ‘080 Patent is valid and enforceable. 6. The ‘997 Patent is valid and enforceable. 7. In its Complaint (Dkt. 1), Socket Solutions alleged that Zhuoli directly infringed at least Claim 19 of the ‘080 Patent, in violation of 35 U.S.C. § 271(a), by importing, selling and offering to sell into the United States certain single-cord outlet covers (“Single-cord Infringing Wall Outlet Covers”) through product offerings on Alibaba.com. Case: 1:23-cv-15594 Document #: 24 Filed: 02/20/24 Page 1 of 4 PageID #:154 2 8. Socket Solutions also alleged that Zhuoli induced infringement at least Claim 19 of the ‘080 Patent in violation of 35 U.S.C. § 271(b) by, with actual knowledge of the ‘080 Patent, encouraging customers to sell, offer to sell, or use the Single-cord Infringing Wall Outlet Covers in the United States. 9. Socket Solutions also alleged that Zhuoli directly infringed at least Claim 1 of the ‘997 Patent, in violation of 35 U.S.C. § 271(a), by importing, selling and offering to sell into the United States certain outlet covers (“Dual-cord Infringing Wall Outlet Covers”) through product offerings on Alibaba.com. 10. Socket Solutions also alleged that Zhuoli includes false and misleading safety certification markings on its Single-cord Infringing Wall Outlet Covers, includes false and misleading statements promoting these Infringing Wall Outlet Covers as providing “Enhanced Safety,” and falsely represents to customers that it sells genuine Sleek Socket® products. 11. In the Complaint, Socket Solutions provided images depicting an example of the Single-cord Infringing Wall Outlet Covers (below, left) and an example of the Dual-cord Infringing Wall Outlet Covers (below, right): Case: 1:23-cv-15594 Document #: 24 Filed: 02/20/24 Page 2 of 4 PageID #:155 3 12. On November 8, 2023, the Court issued an order permitting Socket Solutions to serve the Summons and Complaint by email. (Dkt. 9.) 13. Socket Solutions served the Summons and Complaint on Zhuoli on November 8, 2023. (Dkt. 10.) 14. Defendant has not appeared in the case, responded to the Complaint, or sought an extension of time to respond. 15. On December 27, 2023, the Court entered a default against Zhuoli. (Dkt. 13.) 16. The Court finds that Zhuoli has infringed the ‘080 Patent, both directly under 35 U.S.C. § 271(a) and by inducing others to infringe under 35 U.S.C. § 271(b). 17. The Court finds that Zhuoli has infringed the ‘997 Patent directly under 35 U.S.C. § 271(a). 18. The Court further finds that Socket Solutions has suffered and will continue to suffer irreparable harm from Zhuoli’s continued infringement. 19. The Court finds that Zhuoli’s false and misleading representations violate the false advertising provision of Section 43(a) of the Lanham Act, 15 U.S.C. § 1125(a). 20. Zhuoli, together with its parents and subsidiaries, and their respective officers, agents, and employees, and those persons in privity, active concert or participation with them, are permanently enjoined from: (a) manufacturing, using, selling, offering to sell, and importing into the United States the Single-cord Infringing Wall Outlet Covers Outlet Covers, and other products that are not more than colorably different from them in the context of the ‘080 Patent claims; Case: 1:23-cv-15594 Document #: 24 Filed: 02/20/24 Page 3 of 4 PageID #:156 4 (b) inducing others to manufacture, use, sell, offer to sell or import into the United States the Single-cord Infringing Wall Outlet Covers and other products that are not more than colorably different from them in the context of the ‘080 Patent claims; (c) manufacturing, using, selling, offering to sell, and importing into the United States the Dual-cord Infringing Wall Outlet Covers Outlet Covers, and other products that are not more than colorably different from them in the context of the ‘997 Patent claims; and (d) representing to customers that it sells genuine Sleek Socket® products. 21. Judgment is hereby entered against Zhuoli in favor of Socket Solutions on all claims asserted in the Complaint.”
Source: PACER Docket, Case 1:23-cv-15594, Illinois Northern District Court · Filed February 20, 2024

The court’s February 20, 2024 order constitutes a comprehensive default judgment covering infringement of both patents under 35 U.S.C. §§ 271(a) and 271(b), a Lanham Act § 43(a) false advertising violation, and a permanent injunction of unusually broad scope. The ‘not more than colorably different’ language in the injunction is significant: it prevents Zhuoli from evading compliance through minor product modifications. Because the judgment was entered on default, Zhuoli retains a theoretical right to move to vacate under Fed. R. Civ. P. 60(b), though no such motion appears on the docket.

PACER case 1:23-cv-15594 · Public docket record Explore in Eureka ↗
Patent at issue

US9509080B1 & US11450997B1 — Wall Outlet Cover Patents

Publication No.US9509080B1
Application No.US15/099559
Patent details
AssigneeSocket Solutions, LLC
ProductUS9509080B1 — single-cord flush-fit wall outlet cover
Publication typeB2 — grant (with prior publication)
Cited in actionNovember 2, 2023

Publication No.US11450997B1
Application No.US17/175604
Patent details
AssigneeSocket Solutions, LLC
ProductUS11450997B1 — dual-cord flush-fit wall outlet cover
Publication typeB2 — grant (with prior publication)
Cited in actionNovember 2, 2023

U.S. Patent No. 9,509,080 (App. No. 15/099,559) and U.S. Patent No. 11,450,997 (App. No. 17/175,604) both protect wall outlet cover designs associated with the Sleek Socket® product line. The ‘080 Patent covers single-cord outlet configurations, with Claim 19 at issue in this litigation. The ‘997 Patent, a more recent grant filed in 2021, covers dual-cord outlet cover configurations with Claim 1 asserted. Both patents are in the consumer electrical safety accessory space — a sector where product differentiation is closely tied to patented form factors and safety-certification marks.

The strategic value of these patents lies in their coverage of a consumer safety product sold through mainstream e-commerce channels. The ‘080 and ‘997 Patents together create complementary protection for single- and dual-cord product formats, limiting a competitor’s ability to design around one grant without potentially infringing the other. The Alibaba.com sales channel targeted in this case is consistent with broader patterns of Chinese manufacturers exporting commodity electrical accessories into the U.S. market — a recurring enforcement challenge for domestic IP holders in this category.

Patent data sourced from USPTO via PatSnap Eureka patent database Search patent records in Eureka ↗
Freedom to operate

Should you run an FTO analysis against US9509080B1 and US11450997B1?

Any company designing, manufacturing, or importing wall outlet covers — particularly flush-fit or cord-management configurations — into the U.S. market should treat these patents as active freedom-to-operate risks. The ‘080 and ‘997 Patents cover both single-cord and dual-cord variants, and the injunction language in this case extends to products ‘not more than colorably different.’ That means incremental design changes may not provide safe harbour. E-commerce sellers listing outlet covers on U.S.-facing platforms, including Alibaba, Amazon, or direct DTC channels, face particular exposure given this enforcement precedent.

PatSnap Eureka’s FTO Search Agent can map your product’s technical features against the claim sets of both patents, flagging overlap at the claim element level and surfacing prior art that may be relevant to validity challenges. If you are actively marketing outlet cover products, setting up a claim monitoring alert for the Socket Solutions portfolio — including any continuation or divisional applications — will provide early warning of scope expansion before new grants issue.

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Related litigation

Similar patent infringement cases: outlet covers, electrical accessories, cross-border default judgments

PatSnap Eureka tracks related litigation across truck body equipment, vehicle accessories, and comparable infringement actions in the Georgia district system.

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Strategic implications

What this case signals for the electrical accessories IP enforcement landscape

This case illustrates a targeted, fast-track enforcement model that U.S. patent holders are increasingly deploying against Chinese e-commerce sellers.

Default judgment is a viable fast-track tool against non-appearing Chinese sellers

When a Chinese manufacturer sells infringing products through Alibaba or similar platforms but lacks U.S. operations, it may not engage with U.S. litigation. Socket Solutions obtained a permanent injunction in under four months by filing a well-documented complaint, securing email service, and moving efficiently to default. This model is replicable for other IP holders facing similar cross-border infringement.

Combining patent and Lanham Act claims strengthens e-commerce enforcement leverage

The addition of Lanham Act false advertising and counterfeit branding claims alongside patent infringement significantly widens the injunction’s practical scope. Platform operators like Alibaba and Amazon are more responsive to takedown requests that cite both IP infringement and counterfeit brand claims simultaneously. Companies holding patents on consumer safety products should audit whether competitor listings also trigger false certification or branding violations.

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Venue selection analysisSocket Solutions patent portfolioAlibaba enforcement patterns
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Frequently asked questions

Socket v Yuyao — key questions answered

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