North Atlantic Imports LLC v. YSN Imports Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: North Atlantic Imports, LLC, d/b/a Blackstone (Utah)
  • Defendant: YSN Imports, Inc., d/b/a Flame King (Nevada)
  • Plaintiff’s Counsel: Foley & Lardner LLP
• Case Identification: 2:23-cv-08204, C.D. Cal., 09/29/2023
• Venue Allegations: Plaintiff alleges venue is proper in the Central District of California because Defendant’s principal place of business is located there, and Defendant distributes and sells the accused products within the district.
• Core Dispute: Plaintiff alleges that Defendant’s tabletop griddle station infringes five patents related to griddle designs featuring rear-located grease management systems.
• Technical Context: The technology concerns outdoor cooking griddles, a product category where innovations in convenience and cleanup, such as grease management, are significant market differentiators.
• Key Procedural History: The complaint alleges that Plaintiff has provided constructive notice to the public of the patents-in-suit via a publicly accessible website, a fact which may be relevant to the calculation of pre-suit damages under 35 U.S.C. § 287.

Case Timeline

Date	Event
2008-01-01	Plaintiff launches its first classic griddle
2016-05-04	Priority Date for ’588, ’589, ’564, ’572, and ’743 Patents
2019-06-25	U.S. Patent No. 10,327,588 Issues
2019-06-25	U.S. Patent No. 10,327,589 Issues
2021-03-23	U.S. Patent No. 10,952,564 Issues
2021-03-30	U.S. Patent No. 10,959,572 Issues
2022-03-29	U.S. Patent No. 11,284,743 Issues
2023-09-29	Complaint Filed

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

U.S. Patent No. 10,327,588 - Griddle device, system, and method

• Issued: June 25, 2019 (Compl. ¶32)

The Invention Explained

• Problem Addressed: The patent’s background section describes a concern with conventional griddles where grease drain systems are located on the side or front, which is described as "unsightly" and creates the potential for grease to spill on the user's clothing (’588 Patent, col. 1:46-52).
• The Patented Solution: The invention proposes a griddle design that relocates the grease management system to the rear. It features a trough extending along the rear of the cooking surface that directs grease and food byproducts into a "through hole," moving the collection process away from the user and out of sight (’588 Patent, Abstract; col. 5:39-47; Fig. 1).
• Technical Importance: This design approach seeks to improve user experience by making grease disposal cleaner and less conspicuous during the cooking process (Compl. ¶19).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶37).
• Essential elements of Claim 1 include:
  • A griddle with a flat cooking surface and a splash guard extending along an "entire periphery" of the griddle's upper side.
  • The splash guard defines rear, front, left, and right splash guards, with the front, left, and right guards extending upward from the cooking surface along their "entire lengths."
  • The flat cooking surface extends directly to a "sloped surface to define a trough" adjacent to the rear end of the cooking surface.
  • The sloped surface extends at an "acute angle" relative to the cooking surface.
  • The trough's sloped surface extends downward to a "rear opening" that is at least partially defined in the trough and the rear splash guard.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 10,327,589 - Outdoor cooking station with griddle, system and method thereof

• Issued: June 25, 2019 (Compl. ¶45)

The Invention Explained

• Problem Addressed: The patent identifies the same problem as the ’588 Patent: unsightly and messy front- or side-mounted grease drain systems on outdoor griddles (’589 Patent, col. 1:50-58).
• The Patented Solution: This patent claims an entire outdoor cooking station that integrates the griddle design. The invention comprises a frame with heating elements that supports a griddle featuring a rear-positioned grease management system. This system includes a splash guard with a rear opening and a trough with a sloped surface to channel waste toward that opening, combining the griddle top innovation with the supporting structure into a single claimed system (’589 Patent, Abstract; col. 2:3-28).
• Technical Importance: By claiming the entire station, the patent provides protection for a complete commercial product, rather than just the griddle component, which aligns with how such products are typically marketed and sold (Compl. ¶13).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶50).
• Essential elements of Claim 1 include:
  • A frame that includes multiple heating elements.
  • A griddle supported by the frame, which includes a flat cooking surface.
  • A splash guard extending upward from the cooking surface that defines a "rear opening" located at a "lower mid-portion" of the splash guard.
  • A "trough defined in the cooking surface" at a "rear central portion" of the cooking surface.
  • The trough includes a sloped surface that extends downward toward the rear opening in the splash guard.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 10,952,564 - Griddle device, system, and method

• Issued: March 23, 2021 (Compl. ¶58)
• Technology Synopsis: This patent addresses the management of grease on griddles by claiming a griddle device with a rear-located trough and a splash guard (’564 Patent, col. 1:44-52). A key feature of the claimed solution is that the "top edge along the rear splash guard extends over the rear opening," creating a structural overhang intended to improve the containment and direction of food byproducts into the collection system (’564 Patent, claim 1c).
• Asserted Claims: At least independent claim 1 (Compl. ¶63).
• Accused Features: The complaint accuses the Defendant's griddle system, specifically its flat cooking surface, peripheral splash guard, sloped trough, and rear opening defined in the rear splash guard (Compl. ¶64).

U.S. Patent No. 10,959,572 - Outdoor cooking station with griddle, system and method thereof

• Issued: March 30, 2021 (Compl. ¶71)
• Technology Synopsis: This patent claims an entire outdoor cooking station that integrates a griddle with a rear grease management system (’572 Patent, col. 1:50-58). The invention specifies a splash guard with a "top edge" that extends above the cooking surface and also extends "above the rear opening," creating an overhang feature designed to guide grease and waste more effectively (’572 Patent, claim 1d).
• Asserted Claims: At least independent claim 1 (Compl. ¶76).
• Accused Features: The complaint accuses the Defendant's integrated outdoor cooking station, including its frame, griddle, flat cooking surface, upward-extending splash guard, rear opening, and sloped surface extending toward that opening (Compl. ¶77).

U.S. Patent No. 11,284,743 - Outdoor cooking station with griddle, system and method thereof

• Issued: March 29, 2022 (Compl. ¶84)
• Technology Synopsis: This patent also covers a complete outdoor cooking station featuring a griddle with a rear-located grease management system (’743 Patent, col. 1:55-63). The claimed invention focuses on the structural relationship where the splash guard's "top edge extends over the rear opening," a configuration designed for improved waste funneling and containment within an integrated unit (’743 Patent, claim 1d).
• Asserted Claims: At least independent claim 1 (Compl. ¶89).
• Accused Features: The complaint accuses the Defendant's complete cooking station, highlighting the frame, griddle, splash guard with a top edge, rear opening, and a sloped surface for directing waste (Compl. ¶90).

III. The Accused Instrumentality

Product Identification

The accused product is the "2-Burner Propane Tabletop, Heavy Duty Flat Top Cast Iron Griddle Grill Station," identified by Model No. YSNFM-HT-120DB (Compl. ¶22).

Functionality and Market Context

The complaint alleges the Accused Product is a tabletop griddle station that incorporates a feature for removing unwanted food byproducts, such as grease, through a rear opening (Compl. ¶23, 25). An image from Defendant’s advertising, included in the complaint, depicts an "Oil Collection Design" with a "Residual Oil Hole" and an "Easy Clean Receptacle" located at the rear of the griddle. This diagram illustrates the product's advertised functionality for rear grease management (Compl. p. 6). The complaint further alleges that the Accused Product competes directly with Plaintiff's products, is sold through the same retail channels, and "closely imitate[s]" the patented technology (Compl. ¶36, 49).

IV. Analysis of Infringement Allegations

’588 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a griddle including an upper side... the upper side including a flat cooking surface... [and] a splash guard extending along an entire periphery of the upper side of the griddle	The Accused Product is a griddle with a flat cooking surface and a peripheral splash guard.	¶38a	col. 4:39-46
the front splash guard and the left and right splash guards directly extending upward from the flat cooking surface along entire lengths of the respective front, left and right ends	The Accused Product has front, left, and right splash guards extending upward from the cooking surface.	¶38a	col. 4:50-59
wherein the flat cooking surface, adjacent a length of the rear end of the cooking surface, directly extends to a sloped surface to define a trough	The Accused Product's flat cooking surface extends to a sloped surface that forms a trough at the rear.	¶38b	col. 5:26-31
such that the sloped surface extends with an acute angle relative to the flat cooking surface, the sloped surface of the trough extending downward to a rear opening	The Accused Product's trough has a sloped surface angled downward toward a rear opening for grease removal. The complaint's included diagram shows a "Residual Oil Hole" at the base of this feature (Compl. p. 6).	¶38b	col. 2:45-46

’589 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a frame extending to define a front side, a rear side, a left side and a right side... the frame including multiple heating elements	The Accused Product is a cooking station with a frame that supports heating elements.	¶51a	col. 6:10-12
a griddle configured to be supported by the upper portion of the frame and positioned above the heating elements	The Accused Product's griddle top is supported by its frame, above the burners.	¶51b	col. 2:4-6
a splash guard extending upward from the flat cooking surface... defining a rear opening therein... positioned at a lower mid-portion of the splash guard	The Accused Product has a splash guard with a rear opening for grease. The included diagram shows this opening at the base of the rear splash guard (Compl. p. 11).	¶51d	col. 2:20-24
a trough defined in the cooking surface at a rear central portion... the trough including a sloped surface extending downward toward the rear opening	The Accused Product's cooking surface includes a trough with a sloped surface at the rear to direct grease to the rear opening.	¶51e	col. 2:24-28

Identified Points of Contention

• Scope Questions: A potential point of contention for the ’588 Patent is the claim requirement for a splash guard extending along the "entire periphery." The court may need to determine if a design that incorporates a trough and opening at the rear still meets this limitation, or if the opening constitutes a break in the periphery. For the ’589 Patent, the requirement that the opening be at a "lower mid-portion" and the trough at a "rear central portion" may raise questions of indefiniteness or create factual disputes over the precise location of these features on the Accused Product.
• Technical Questions: The infringement analysis may turn on whether the Defendant's "Residual Oil Hole" and the surrounding structure meet the patents' definition of a "trough," which is described as a specific structure extending from the cooking surface. The evidence presented in the complaint, particularly the "Oil Collection Design" diagram, suggests a sloped entry into the hole, which may support the allegation that it functions as the claimed trough (Compl. p. 6).

V. Key Claim Terms for Construction

"trough" (’588 Patent, Claim 1; ’589 Patent, Claim 1)

Context and Importance

The structure and existence of a "trough" is a central element of the asserted claims. The case may depend on whether the feature leading to the "Residual Oil Hole" in the Accused Product is construed as meeting the structural definition of a "trough" as claimed in the patents. Practitioners may focus on this term because Defendant could argue its product merely has a hole, not the more complex structure implied by a "trough."

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The specification functionally describes the trough as being "sized and configured to receive grease or other food byproduct" (’588 Patent, col. 5:23-24). This language could support an interpretation where any structure that channels grease at the rear of the griddle qualifies as a trough.
• Evidence for a Narrower Interpretation: The detailed description and figures illustrate a specific structure that "extend[s] laterally from the cooking surface... to a bottom trough surface... and then extend[s] upward" (’588 Patent, col. 5:29-32, Fig. 1A). This could support a narrower construction requiring a distinct, U-shaped channel rather than just a sloped depression.

"splash guard extending along an entire periphery" (’588 Patent, Claim 1)

Context and Importance

This term is critical for determining the scope of Claim 1 of the ’588 Patent. Infringement will depend on whether a griddle with a rear opening for grease can be considered to have a splash guard along its "entire periphery."

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The claim separately recites the trough and rear opening, suggesting these features are contemplated as part of the overall design that includes the full-periphery splash guard. A party could argue "entire periphery" refers to the general boundary, within which specific functional features like an opening can exist.
• Evidence for a Narrower Interpretation: A plain reading of "entire" implies an unbroken, continuous structure. The specification depicts the splash guard as four distinct sections: rear, front, left, and right, which together form the periphery (’588 Patent, col. 4:50-55). An opening in the rear guard could be argued to break this continuity.

VI. Other Allegations

Indirect Infringement

The complaint alleges both induced and contributory infringement for each asserted patent (Compl. ¶40, 53, 66, 79, 92). The factual basis for these allegations appears to rest on Defendant making and selling the Accused Product, as well as on marketing materials, such as the "QUICK AND EASY CLEAN-UP" diagram, which may be construed as instructing users on how to use the product in an infringing manner (Compl. p. 6).

Willful Infringement

The complaint does not use the word "willful" but lays a foundation for such a claim. It alleges that Defendant "closely imitate[s]" the patented technology and seeks treble damages and attorneys' fees, which are remedies for willful or exceptional cases (Compl. ¶36; Prayer for Relief ¶D, F). The complaint also asserts pre-suit constructive notice via a patent marking website, which is relevant to establishing knowledge (Compl. ¶41).

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

The resolution of this case will likely depend on the court's answers to several central questions regarding claim interpretation and factual comparison.

• A core issue will be one of definitional scope: How will the term "trough" be construed? Will it be defined broadly to cover any sloped feature that directs grease to a rear hole, as suggested by the Accused Product's marketing, or will it be limited to the specific multi-surfaced channel structure detailed in the patent specifications?
• A second key issue will be one of structural integrity: Can a splash guard with a rear opening for grease management be considered to extend along an "entire periphery" as required by Claim 1 of the ’588 Patent? The interpretation of this phrase will be dispositive for that patent.
• A final question will be one of locational precision: Does the Accused Product's grease management system meet the specific positional limitations of claims requiring features to be at a "lower mid-portion" or "rear central portion"? This will likely become a factual battleground, potentially involving expert testimony on product design and measurement.