Socket Solutions, LLC v. Import Global, LLC

Socket Solutions v. Import Global, decided August 4th, 2026. A precedential panel of the Federal Circuit, in an opinion by Chief Judge Moore, vacated a preliminary injunction in a patent case. The district court had misconstrued two claim terms, including treating the word pin as a means-plus-function term. And the court confirmed that, after eBay, irreparable harm may not be presumed at the preliminary-injunction stage. Here's the brief.

Socket Solutions owns the ’080 patent, directed to a cover for an indoor electrical wall outlet. The cover hides the outlet while still letting it be used: a thin frontplate and backplate, prongs that plug into the outlet, and a cord that carries power to a receptacle at its far end.

Socket Solutions sued Import Global, alleging that its Neat Socket product infringed claim 19, and moved for a preliminary injunction. A magistrate judge recommended constructions of the disputed terms and recommended granting the motion. The district court adopted both recommendations and enjoined Import Global from making, using, selling, or importing the accused product. Import Global appealed.

A preliminary injunction requires a showing that the movant is likely to succeed on the merits, is likely to suffer irreparable harm without relief, that the balance of equities tips in its favor, and that an injunction is in the public interest. Review is for abuse of discretion, but claim construction is reviewed de novo.

Import Global challenged the constructions of backplate and pin, which drove the likelihood-of-success analysis, and the district court's treatment of irreparable harm.

On backplate, the court rejected both sides' spatial definitions. Because the specification defines the cover's thickness by the distance between frontplate and backplate, the court construed backplate in those terms.

On pin, the district court had construed the term as a means for making an electrical connection. The Federal Circuit held that was error. Under its en banc decision in Williamson v. Citrix, a term that does not use the word means carries a rebuttable presumption that section 112(f) does not apply. The specification described pins in structural terms, and the parties agreed that skilled artisans understand a pin to be a structure.

The court also declined Socket Solutions' invitation to define pin purely by its function, because not everything that connects wires to prongs is a pin.

Because the likelihood-of-success analysis rested on those errors, the court vacated and remanded. It did not reach the merits of irreparable harm, but it addressed the governing rule.

The Supreme Court's 2006 decision in eBay rejected a general rule that an injunction follows a finding of infringement, and the Federal Circuit's 2011 decision in Robert Bosch confirmed that eBay jettisoned the presumption of irreparable harm.

Socket Solutions confirms two settled points in a precedential opinion. A claim term that names a structure, without the word means, is not converted into a means-plus-function limitation merely because it can be described by what it does. And the presumption of irreparable harm that eBay and Bosch eliminated for permanent injunctions is equally unavailable for preliminary injunctions. Irreparable harm must be shown, not presumed.

Socket Solutions, LLC v. Import Global, LLC, No. 2025-1121, decided August 4th, 2026. I'm John Goodhue. Thanks for watching.