Ningbo Gaotong Business Services Co Ltd v. SharkNinja Operating LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Ningbo Gaotong Business Services Co., Ltd., d/b/a GoodTend (China)
  • Defendant: SharkNinja Operating LLC (Delaware / Massachusetts)
  • Plaintiff’s Counsel: Glacier Law LLP
• Case Identification: Ningbo Gaotong Business Services Co., Ltd. v. SharkNinja Operating LLC, 5:26-cv-05028, W.D. Ark., 01/27/2026
• Venue Allegations: Plaintiff alleges venue is proper because Defendant directed patent enforcement activities at Plaintiff's product listing on Walmart.com, and actions by Walmart personnel in Bentonville, Arkansas, constitute a substantial part of the events giving rise to this action.
• Core Dispute: Plaintiff seeks a declaratory judgment that its air fryer products do not infringe Defendant's patent related to cooking device components and that the patent is invalid, following Defendant's infringement complaint to Walmart which resulted in the removal of Plaintiff's product listing.
• Technical Context: The technology concerns the mechanical and structural design of countertop air fryers, specifically the vessel, its supporting base, and handle assemblies.
• Key Procedural History: The dispute was initiated by Defendant's extra-judicial enforcement action, filing a patent infringement complaint with Walmart against Plaintiff. This action led to Walmart removing Plaintiff's air fryer listing on or about December 14, 2025, prompting Plaintiff to file this declaratory judgment lawsuit.

Case Timeline

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 12,426,739 - "Cooking Devices and Components Thereof"

• Patent Identification: U.S. Patent No. 12,426,739, "Cooking Devices and Components Thereof," issued September 30, 2025 (’739 Patent).

The Invention Explained

• Problem Addressed: The patent's background describes the general function of an air fryer, which cooks food by rapidly circulating hot air, implying a focus on improving the structural and functional aspects of such devices rather than addressing a novel problem ('739 Patent, col. 1:29-43).
• The Patented Solution: The invention, as described in the summary and abstract, is a cooking system comprising a removable cooking device (containing a heating element and fan) that is placed over a vessel to form a cooking chamber ('739 Patent, Abstract; col. 1:47-58). The claims focus on the specific mechanical arrangements of the vessel and its supporting base, including how the base attaches to the vessel and provides support and thermal insulation ('739 Patent, col. 41:50-61, col. 42:3-14).
• Technical Importance: The described technology pertains to the modular design and mechanical interface of components in modern countertop cooking appliances, potentially aiming to improve stability, user handling, and thermal management.

Key Claims at a Glance

• The complaint contests infringement of independent claims 1, 7, and 14 (Compl. ¶¶31-33).
• Independent Claim 1:
  • A vessel assembly comprising a unitary vessel with a top opening and closed bottom.
  • The vessel is configured to support a cooking device at its top opening.
  • A U-shaped base is fixed to opposed sidewalls of the vessel.
  • The base is configured to rest on a support surface and support the vessel's bottom without contacting the cooking device.
• Independent Claim 7:
  • A vessel assembly comprising a vessel with a cavity and an opening.
  • A handlebar is positioned under the vessel and extends upward along a portion of the vessel's height.
  • A gap, configured as a thermal break, is positioned between the vessel wall and the handlebar.
• Independent Claim 14:
  • A vessel assembly where the vessel has a sidewall with a first indent and a first detent.
  • A base is positioned below the vessel.
  • A flexible connector plate extends from the base and includes a second indent and a second detent.
  • The first detent is received by the second indent, and the second detent is received by the first indent, to connect the base to the vessel.
• The complaint explicitly denies infringement of dependent claims 2-6, 8-13, and 15-23 (Compl. ¶¶31-33).

III. The Accused Instrumentality

Product Identification

• Product Identification: Plaintiff's "Air Fryer" products sold on Walmart.com (Compl. ¶¶1, 10).

Functionality and Market Context

• The complaint alleges the accused Air Fryer has specific structural features that distinguish it from the patented invention. It is described as having a base that is a "continuous peripheral wall that encloses the bottom of the vessel on all sides," functioning as a "housing" or "bowl" (Compl. ¶31).
• Its handle structures are allegedly attached to the exterior of this base housing, positioned "laterally adjacent to the sidewalls of the vessel," not underneath it (Compl. ¶32).
• Instead of a thermal-break gap, the product allegedly uses "direct mechanical contact via reinforcing ribs" at its structural interfaces (Compl. ¶32).
• The connection mechanism is described as a single "protruding lock bolt" and a "rigid and non-flexible" handlebar assembly, which allegedly lacks the claimed reciprocal "indent and detent" features and "flexible" connector plate (Compl. ¶33).
• Walmart.com is alleged to be the Plaintiff's "primary sales channel in the United States," and the delisting of the product has allegedly caused "immediate and concrete harm" (Compl. ¶¶13-14).
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement. The following tables summarize the plaintiff's asserted distinctions between the accused product and the patent claims.

’739 Patent Infringement Allegations

’739 Patent Infringement Allegations

’739 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A primary dispute will concern the proper construction of claim terms. Key questions include: whether the term "U-shaped base" can be construed to read on a fully enclosed, bowl-like housing (Compl. ¶31); whether "positioned under the vessel" requires a location directly beneath the vessel's bottom surface or can include lateral positions below the vessel's top plane (Compl. ¶32); and what degree of movement is required for a component to be considered "flexible" (Compl. ¶33).
  • Technical Questions: A factual question is whether the accused product's structure performs the functions required by the claims. For instance, does the interface of "direct mechanical contact via reinforcing ribs" in the accused product achieve the function of a "thermal break" as claimed (Compl. ¶32), and does the "protruding lock bolt" meet the "indent and detent" limitation (Compl. ¶33)?

V. Key Claim Terms for Construction

• The Term: "U-shaped base" (Claim 1)

• Context and Importance: This term is central to the non-infringement argument for Claim 1. The Plaintiff contends its product's fully enclosed, four-sided housing cannot be "U-shaped," which it argues implies openness on two sides (Compl. ¶31). The case may turn on whether this geometric term is interpreted strictly or functionally.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification describes a "base configured to abut the vessel and rest on a support surface" which could suggest a functional definition rather than a purely geometric one ('739 Patent, col. 3:27-32).
  • Evidence for a Narrower Interpretation: The term "U-shaped" itself carries a strong geometric connotation. The complaint alleges that prosecution history estoppel bars a broader interpretation (Compl. ¶31). Figures in the patent, such as the base (2006) shown in FIG. 31, depict a clear U-shaped structure that supports a vessel without fully enclosing it, which may support a narrower construction.

• The Term: "a gap ... configured to be a thermal break" (Claim 7)

• Context and Importance: Plaintiff argues its product, which allegedly uses "direct mechanical contact via reinforcing ribs," does not have the claimed "gap" (Compl. ¶32). The dispute will likely focus on whether any space between components constitutes a "gap" and whether the interface is "configured to be a thermal break."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent states the gap is "configured to be a thermal break between the vessel and the handlebar" ('739 Patent, col. 41:21-23). This functional language could allow for various structures that achieve thermal separation, not just empty space.
  • Evidence for a Narrower Interpretation: The common meaning of "gap" implies a physical separation or space. Embodiments such as FIG. 31 show a clear physical space (2138) between the vessel (2004) and the handlebar structure (2036), which may be used to argue for a narrower definition requiring such separation.

VI. Other Allegations

• Indirect Infringement: The complaint seeks a declaratory judgment of non-infringement for direct, contributory, or vicarious liability (Compl. ¶1). It does not, however, allege specific facts regarding indirect infringement theories, focusing instead on arguing a lack of direct infringement.
• Invalidity: The complaint includes a detailed count for a declaratory judgment of invalidity, alleging the ’739 Patent is invalid under 35 U.S.C. §§ 102 and/or 103 in view of several prior art references (Compl. ¶¶19-26). It identifies five patents and two published applications, describing how each allegedly discloses or renders obvious key limitations of the asserted claims, such as the attachment of a base to a vessel, mechanical interlocking features, and the general air fryer system architecture (Compl. ¶¶20-25).

VII. Analyst’s Conclusion: Key Questions for the Case

1. Claim Construction and Estoppel: A core issue will be one of definitional scope: can the term "U-shaped base," which has a common geometric meaning, be construed to cover the accused product's fully enclosed, bowl-like housing? The plaintiff's reference to prosecution history estoppel suggests this term's scope may have been narrowed during examination, making its interpretation a critical threshold question.
2. Structural and Functional Equivalence: A central evidentiary question will be one of technical comparison: do the specific mechanical structures of the accused product meet the claim limitations, either literally or under the doctrine of equivalents? This will involve detailed factual analysis of whether a laterally-mounted handle is "under the vessel," whether a single-bolt lock constitutes a reciprocal "indent and detent" mechanism, and whether a "rigid" assembly can be considered "flexible" in the context of the patent.
3. Obviousness in a Crowded Art: Given the number of prior art references cited for invalidity, a key question for the patent's survival will be patentability over prior art: do the specific combinations of a vessel, a removable heating unit, and a supporting base claimed in the ’739 Patent represent a non-obvious advance over existing cooking appliance designs, or are they merely an aggregation of known elements as alleged by the plaintiff?