Harvest Right LLC v. Stay Fresh Technology LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Harvest Right, LLC (Delaware)
  • Defendant: Stay Fresh Technology, LLC (California)
  • Plaintiff’s Counsel: Fisherbroyles, LLP
• Case Identification: 2:25-cv-10396, C.D. Cal., 10/29/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Central District of California because Defendant maintains its principal place of business in Gardena, California, which is located within the district.
• Core Dispute: Plaintiff alleges that Defendant’s line of freeze dryer products infringes two patents related to specialized processes for drying materials with low water content, such as candy.
• Technical Context: The technology resides in the consumer and "prosumer" freeze-drying market, an appliance category that has gained popularity for long-term food preservation and for creating novelty confections like freeze-dried candy.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or administrative patent challenges. The allegations of willful infringement are based on knowledge of the patents as of the complaint's filing date, suggesting no pre-suit notice was provided.

Case Timeline

Date	Event
2023-05-08	Priority Date for ’914 and ’610 Patents
2023-07-01	Accused Product candy features advertised via blog post
2025-02-18	’914 Patent Issued
2025-03-11	’610 Patent Issued
2025-10-29	Complaint Filed

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

U.S. Patent No. 12,225,914 - Freeze Dryers And Drying Processes For Materials With Low Water Content (Issued Feb. 18, 2025)

The Invention Explained

• Problem Addressed: Standard freeze-drying processes are optimized for materials with high water content and typically require a lengthy defrost cycle after each batch to remove accumulated ice from the vacuum chamber (Compl. ¶20; ’914 Patent, col. 1:11-23). This defrosting step creates a significant bottleneck when processing large quantities of materials, especially those with low water content that do not generate substantial ice buildup (’914 Patent, col. 1:50-53).
• The Patented Solution: The patent describes a method and system that allows a freeze dryer to process a second batch of low-water-content material immediately after a first batch without running an intervening defrost cycle (’914 Patent, col. 3:51-64). By collecting the small amount of water vapor as ice and then proceeding directly to a subsequent batch, the invention claims to make drying large quantities of such materials much faster (’914 Patent, col. 1:50-53). Figure 28 of the patent illustrates a user interface with distinct options for "START NEW CANDY BATCH" and "DEFROST," embodying the claimed choice to skip the defrost step (’914 Patent, Fig. 28).
• Technical Importance: This approach increases the throughput and efficiency of freeze dryers for the specific application of processing low-moisture items like candy, a key function in the prosumer market (Compl. ¶12).

Key Claims at a Glance

• The complaint asserts at least independent method claim 20 (Compl. ¶22).
• The essential elements of Claim 20 include:
  • A method for drying a first material and a second material in a freeze dryer.
  • Drying the first material by reducing pressure and collecting water vapor as ice on the chamber walls.
  • Removing the first material and positioning the second material in the freeze dryer.
  • Drying the second material by reducing pressure "without defrosting the ice on the one or more interior walls of the vacuum chamber."

U.S. Patent No. 12,245,610 - Freeze Dryers And Drying Processes For Materials With Low Water Content (Issued Mar. 11, 2025)

The Invention Explained

• Problem Addressed: Conventional freeze-drying, or lyophilization, is fundamentally a two-step process: first, a material is frozen solid, and second, a vacuum is applied to cause the ice to sublimate directly into vapor (’610 Patent, col. 1:11-20). This process is unnecessary and inefficient for materials that already have very low water content and high sugar content, such as many types of candy, which do not require a freezing step to maintain their structure during vacuum drying (’610 Patent, col. 19:42-51).
• The Patented Solution: The patent discloses a freeze dryer apparatus containing instructions for a specialized "candy drying process" that dries the material by reducing pressure in the vacuum chamber without first freezing the material (’610 Patent, Abstract; col. 1:33-41). This effectively allows the machine to operate as a vacuum oven or dryer, bypassing the energy- and time-intensive freezing phase typical of lyophilization. The flowchart in Figure 18 illustrates a process for low-water-content material that proceeds from loading the material directly to a drying phase, omitting a freeze phase (’610 Patent, Fig. 18).
• Technical Importance: This invention provides a dual-function appliance capable of both traditional freeze-drying and a more efficient, specialized vacuum-drying process for low-moisture materials, enhancing the machine's versatility (Compl. ¶28).

Key Claims at a Glance

• The complaint asserts at least independent apparatus claim 1 (Compl. ¶30).
• The essential elements of Claim 1 include:
  • A freeze dryer comprising a chamber, vacuum pump, cooling system, heating system, and an electronic controller.
  • The controller’s memory stores instructions to operate the freeze dryer.
  • The instructions comprise a "candy drying process" that includes "reducing pressure in the chamber below ambient pressure to dry the material without the material being frozen."

III. The Accused Instrumentality

Product Identification

The complaint identifies the "Freeze Dryer with Commercial Pump," "Freeze Dryer with Premier Pump," "Freeze Dryer (7 Shelf)" with both pump types, and the "Mega Freeze Dryer," sold under model numbers 4H11560US and 12H11560US (Compl. ¶1).

Functionality and Market Context

The complaint alleges that the Accused Products are marketed and sold on Defendant's website and directly compete with Plaintiff's products (Compl. ¶1, ¶16). The allegations center on a "candy-specific functionality" that is specially programmed into the Accused Products (Compl. ¶6). Plaintiff claims this feature is a "critical commercial selling point" that Defendant promotes through user manuals and numerous blog posts to unfairly compete in the market for at-home candy freeze-drying (Compl. ¶4, ¶17).

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits that were not provided. The narrative infringement theories are summarized below.

’914 Patent Infringement Allegations

The complaint alleges that the Accused Products infringe at least method claim 20 by enabling and instructing users to perform sequential drying batches of low-water-content materials without an intervening defrost cycle (Compl. ¶20-22, ¶24). The theory of infringement is that the Accused Products are designed to be capable of performing this patented method, and that Defendant induces infringement by providing customers with user manuals that contain instructions on how to do so (Compl. ¶24). A key factual question will be whether the Accused Products' operating software permits a user to start a new drying cycle after one has completed without first initiating a mandatory defrost cycle.

’610 Patent Infringement Allegations

The complaint alleges that the Accused Products, as physical apparatuses, infringe at least claim 1 because they are equipped with an electronic controller storing instructions for a "dedicated candy drying process" (Compl. ¶28-30). This process is alleged to operate by reducing chamber pressure to dry materials like candy "without the material being frozen," which directly tracks the language of the asserted claim (Compl. ¶29). The infringement theory relies on the allegation that the Accused Products are sold with this built-in, infringing functionality (Compl. ¶6, ¶34). A central point of inquiry will be the precise operational steps of the Accused Products' "candy mode."

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

Term from ’914 Patent, Claim 20: "without defrosting the ice"

• Context and Importance: This phrase is the central limitation of the method claim, distinguishing it from prior art processes that required a full defrost between batches. The definition of "defrosting" will be critical to determining infringement.
• Intrinsic Evidence for a Broader Interpretation: The specification contrasts the invention with the conventional, time-consuming step of a full defrost cycle (’914 Patent, col. 1:50-53). Further, Figure 28 presents the user with a specific "DEFROST" button as an alternative to starting a new batch, suggesting "defrosting" is a discrete, machine-initiated process rather than any incidental melting (’914 Patent, Fig. 28). This evidence may support an interpretation that "defrosting" refers to an active, complete, and deliberate cycle run by the machine.
• Intrinsic Evidence for a Narrower Interpretation: The patent does not explicitly define the term "defrosting." A party could argue that any substantial melting of the accumulated ice, even passive melting that occurs when the chamber door is opened to exchange batches, constitutes "defrosting," thereby avoiding infringement.

Term from ’610 Patent, Claim 1: "without the material being frozen"

• Context and Importance: This term defines the core feature of the "candy drying process." The case may turn on whether the accused process meets this negative limitation. Practitioners may focus on this term because the process necessarily involves cooling the chamber, which will in turn cool the material.
• Intrinsic Evidence for a Broader Interpretation: The specification describes the candy process as one where the material "may cool somewhat when it is first placed in the vacuum chamber 102, but it is not exposed to low enough temperatures for a long enough time to freeze" (’610 Patent, col. 20:36-39). This language suggests that "frozen" refers to the state achieved through a deliberate, sustained freezing cycle, not incidental cooling.
• Intrinsic Evidence for a Narrower Interpretation: The patent does not provide a specific temperature threshold for what constitutes "frozen." This raises the question of whether the material reaching a temperature at or below 0°C (32°F) during the initial chamber cool-down phase would mean it has been "frozen," even without a dedicated freezing step as understood in conventional lyophilization.

VI. Other Allegations

Indirect Infringement

The complaint alleges both induced and contributory infringement. Inducement is primarily based on allegations that Defendant's user manuals and other materials provide "explicit instructions" that guide customers to use the Accused Products in an infringing manner (Compl. ¶24, ¶33). Contributory infringement is alleged for the ’610 Patent on the basis that the "patented functionality" has no substantial non-infringing use and was specifically adapted for infringement (Compl. ¶34).

Willful Infringement

Willfulness is alleged for both patents based on knowledge acquired "since at least the filing date of this Complaint," at which time Plaintiff allegedly sent Defendant a letter noticing the infringement (Compl. ¶23, ¶31). This frames the willfulness claim around post-filing conduct.

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

This dispute appears to center on two primary areas of inquiry that will be critical for the court's determination:

1. A core issue will be one of technical operation: Does the "candy mode" of the Accused Products, in practice, function as Plaintiff alleges? Answering this will require a factual investigation into whether the products' software and hardware allow for sequential batches without a mandatory defrost cycle (implicating the ’914 Patent) and whether they dry materials under vacuum without first subjecting them to a freezing cycle (implicating the ’610 Patent).

2. A second key issue will be one of definitional scope: How will the court construe the key claim limitations? The viability of the infringement claims may depend on whether the term "without defrosting the ice" (’914 Patent) can accommodate any incidental melting between batches, and whether "without the material being frozen" (’610 Patent) can be met if the material's temperature briefly drops below 0°C during the chamber cool-down.