DCT
8:25-cv-00328
Illumidine Inc v. Hestan Smart Cooking Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Illumidine, Inc. (California)
- Defendant: Hestan Smart Cooking, Inc. (Delaware) and Meyer Corporation, U.S. (Delaware)
- Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
- Case Identification: 8:25-cv-00328, C.D. Cal., 02/19/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Central District of California because Defendants maintain a regular and established place of business in Anaheim, California, and have committed the alleged acts of patent infringement within the district.
- Core Dispute: Plaintiff alleges that Defendant’s smart induction cooktops, cookware, and associated mobile application infringe two patents related to active foodware systems that integrate heating, sensing, and communication components.
- Technical Context: The technology at issue involves the "smart kitchen" sector, where appliances like cooktops and cookware are equipped with sensors and wireless connectivity to communicate with each other and with software applications to automate and guide the cooking process.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendants with pre-suit notice of infringement for U.S. Patent No. 10,881,249 in June 2021 and for U.S. Patent No. 11,375,853 in October 2022, which may form the basis for allegations of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2004-10-22 | Patent Priority Date ('249 and '853 Patents) |
| 2021-01-05 | U.S. Patent No. 10,881,249 Issued |
| 2021-06-21 | Defendants allegedly received notice of '249 Patent |
| 2022-07-05 | U.S. Patent No. 11,375,853 Issued |
| 2022-10-12 | Defendants allegedly received notice of '853 Patent |
| 2025-02-19 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,881,249 - "Foodware System Having Visual-Stimulating, Sensing, Heating, and Wireless-Communication Components"
- Patent Identification: U.S. Patent No. 10,881,249, "Foodware System Having Visual-Stimulating, Sensing, Heating, and Wireless-Communication Components," issued January 5, 2021.
The Invention Explained
- Problem Addressed: The patent’s background section notes that conventional dishware and food presentation devices are passive and static, creating an opportunity for a more dynamic and interactive dining or cooking experience (’249 Patent, col. 1:12-2:11).
- The Patented Solution: The invention is an "active foodware system" that integrates multiple electronic components into a food-holding device (’249 Patent, col. 2:31-39). The system combines a mechanical structure supporting a food surface with a heating element, a sensor to maintain a desired temperature, a wireless communication component, and a visual display that can respond to data from the sensor or wireless component (’249 Patent, Abstract). The food surface is described as being recessed relative to a peripheral region to prevent spillage (’249 Patent, col. 5:55-58).
- Technical Importance: The invention proposes to merge data processing with food consumption or preparation, enabling interactive feedback, entertainment, or instruction during the activity (’249 Patent, col. 2:53-3:2).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶53).
- The essential elements of independent claim 1 are:
- An active foodware system comprising:
- a mechanical structure being wider than tall and including a wireless sending component for sending;
- a food surface supported by the mechanical structure, with the food surface being recessed in relation to a peripheral region to receive food and prevent spillage;
- a heating component for heating the food;
- a sensing component for controlling the heating component to maintain a desired temperature;
- a wireless communication component for communicating data; and
- a visual stimulating component for providing visual stimulation in response to data from the sensing or wireless components.
U.S. Patent No. 11,375,853 - "Foodware System Having Visual-Stimulating, Sensing, Heating, and Wireless-Communication Components"
- Patent Identification: U.S. Patent No. 11,375,853, "Foodware System Having Visual-Stimulating, Sensing, Heating, and Wireless-Communication Components," issued July 5, 2022.
The Invention Explained
- Problem Addressed: The patent addresses the same problem as the ’249 Patent: the passive and static nature of conventional foodware (’853 Patent, col. 1:12-2:11).
- The Patented Solution: This patent claims a variation of the active foodware system. The invention combines a mechanical structure that supports a recessed food surface with a heating component and a wireless communication component for sending data, wherein the wireless communication component is included within the mechanical structure (’853 Patent, Abstract; col. 47:36-48:2). Unlike the asserted claim of the ’249 Patent, this claim does not require a separate sensing component or a visual stimulating component.
- Technical Importance: This patented approach focuses on an integrated system where a food-holding and heating apparatus contains the means for wireless data transmission (’853 Patent, col. 2:31-39).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶70).
- The essential elements of independent claim 1 are:
- An active foodware system comprising:
- a mechanical structure;
- a food surface supported by the mechanical structure, with the food surface being recessed in relation to a peripheral region to receive food and prevent spillage;
- a heating component for heating the food; and
- a wireless communication component for wirelessly sending data;
- wherein the mechanical structure includes the wireless communication component.
III. The Accused Instrumentality
Product Identification
The accused products include the Hestan Smart Electric Induction Cooktop, Hestan Cue Smart Induction Burner, Hestan Cue Smart Cooking System (which includes smart pans and pots), Hestan SmartChef Cookware, and the associated Hestan Cue App (collectively, the "Accused Products") (Compl. ¶¶36-37).
Functionality and Market Context
The Accused Products constitute a smart cooking system where an induction cooktop communicates via Bluetooth and Wi-Fi with specially designed cookware and a mobile application (Compl. ¶¶36, 40, 43). The system is designed to precisely control cooking temperature, with the app providing chef-guided recipes and real-time information (Compl. ¶¶40, 43). Figure 6 of the complaint illustrates how the smart cookware, cooktop, and Hestan Cue App are designed to work together as an integrated system (Compl. ¶38, Fig. 6). The cookware contains sensors that provide temperature data to the cooktop, which in turn adjusts the power of its inductive heating coil (Compl. ¶¶38-39). Figure 7 provides a diagram explaining how the induction heating works (Compl. ¶38, Fig. 7). The system is marketed as a premium, high-technology cooking experience (Compl. ¶36, Fig. 5).
IV. Analysis of Infringement Allegations
'249 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| An active foodware system comprising: a mechanical structure being wider than tall and including a wireless sending component for sending | The Hestan induction cooktop and burner, which are wider than tall and contain Bluetooth/Wi-Fi components for sending data. | ¶¶38, 43, 54 | col. 7:4-9 |
| a food surface supported by said mechanical structure, said food surface having a peripheral region surrounding said food surface, said food surface being recessed... for receiving solid food and preventing spillage | The Hestan smart pans and pots, which are supported by the cooktop, hold food, and have a recessed surface with a peripheral rim to prevent spillage. | ¶¶36, 54 | col. 5:55-58 |
| a heating component for heating said food | The inductive coil within the cooktop that generates an electromagnetic field to heat the cookware. | ¶¶38, 54 | col. 19:1-5 |
| a sensing component for controlling said heating component for maintaining a desired temperature | The culinary sensors embedded in the Hestan cookware that monitor temperature and communicate with the cooktop to control the inductive coil. | ¶¶39, 40, 54 | col. 20:59-62 |
| a wireless communication component for communicating data... | The Bluetooth and Wi-Fi connectivity within the cooktops, cookware, and app used to communicate temperature data and control signals. | ¶¶43, 54 | col. 19:7-12 |
| and a visual stimulating component for providing visual stimulation in response to said data from said sensing component or data from said wireless communication component | The cooktop’s visual display and the Hestan Cue App interface, which provide real-time information, such as temperature, in response to data from the sensors. | ¶¶42, 43, 54 | col. 11:10-16 |
- Identified Points of Contention:
- Scope Questions: A central question may be whether the term "active foodware system" can be construed to cover a multi-component product ecosystem (cooktop, cookware, mobile app) when many patent embodiments depict a single, integrated device like a plate. A related question is whether the "mechanical structure" refers to the cooktop, the cookware, or the combination.
- Technical Questions: The analysis may focus on whether the temperature readouts on the cooktop display or app perform the claimed function of "providing visual stimulation," or if that term implies more dynamic or interactive visuals as depicted in some patent figures (e.g., '249 Patent, Figs. 4A-4D).
'853 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| An active foodware system comprising: a mechanical structure | The Hestan induction cooktop and burner. | ¶¶38, 71 | col. 7:4-9 |
| a food surface supported by said mechanical structure, said food surface having a peripheral region surrounding said food surface, said food surface being recessed... for receiving solid food and preventing spillage | The Hestan smart pans and pots, which rest on the cooktop and have a recessed surface to hold food. | ¶¶36, 71 | col. 5:55-58 |
| a heating component for heating said food | The inductive coil within the Hestan cooktop. | ¶¶38, 71 | col. 19:1-5 |
| and a wireless communication component for wirelessly sending data | The Bluetooth and Wi-Fi hardware and software within the Accused Products for transmitting data. | ¶¶43, 71 | col. 19:7-12 |
| wherein said mechanical structure includes said wireless communication component. | The complaint alleges the Hestan cooktop (the mechanical structure) contains the wireless communication components. | ¶¶43, 71 | col. 7:5-9 |
- Identified Points of Contention:
- Scope Questions: As with the ’249 Patent, the definition of "active foodware system" as applied to a multi-part product will be a key issue.
- Technical Questions: The dispute may turn on the construction of "mechanical structure." If the court determines the "mechanical structure" is the cookware rather than the cooktop, the question will be whether the cookware itself "includes" the "wireless communication component" as required by the claim.
V. Key Claim Terms for Construction
"active foodware system"
- Context and Importance: This term's construction is fundamental to the case. Practitioners may focus on whether the term is limited to a single, integrated apparatus, as shown in many patent figures, or if it can encompass a multi-part system of discrete products (cooktop, cookware, app) that work in concert.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The use of the word "system" itself suggests an aggregation of interacting components (’249 Patent, cl. 1). The specification also describes embodiments where a dining plate and a separate "underplate" communicate and function together, which may support a multi-component construction (’249 Patent, col. 12:12-19).
- Evidence for a Narrower Interpretation: The patent’s abstract describes "a mechanical structure supporting a food surface," and many figures depict a unitary object like a plate or dish containing all components, which could support a narrower definition limited to a single device (’249 Patent, Abstract; Figs. 2A, 11).
"mechanical structure"
- Context and Importance: The definition of this term is critical for claim 1 of the '853 Patent, which requires the "mechanical structure" to include the wireless communication component. The complaint appears to map this term to the cooktop.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states that the mechanical structure is "intended to be supported by furniture" and raises the "dining surface" to a convenient level, which could describe the cooktop (’249 Patent, col. 7:12-21).
- Evidence for a Narrower Interpretation: The claims state the mechanical structure "support[s]" the food surface. This could be interpreted to mean the cookware itself is the mechanical structure, as it most directly supports the surface on which food rests.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement based on Defendants' instructions, user manuals, and advertising, which allegedly direct customers to use the cooktop, cookware, and app together in an infringing manner (Compl. ¶¶55, 72). It further alleges contributory infringement, stating the Accused Products have special features for smart cooking that are not suitable for substantial non-infringing use (Compl. ¶¶56, 73).
- Willful Infringement: The willfulness allegations are based on Defendants’ alleged knowledge of the patents since at least June 2021 (for the ’249 Patent) and October 2022 (for the ’853 Patent) via pre-suit notice letters (Compl. ¶¶45, 60, 77). The complaint also alleges Defendants maintain a practice of being "willfully blind" to the patent rights of others (Compl. ¶¶58, 75).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "active foodware system," rooted in patent embodiments that often show a single integrated plate, be construed to cover a multi-component ecosystem of a physically separate cooktop, pan, and mobile application?
- A second key issue will be one of claim construction: will the court define the "mechanical structure" that "supports" the "food surface" as the cooktop on which the cookware rests, or as the cookware itself? This determination will be central to analyzing infringement of the '853 patent, which requires the "mechanical structure" to contain the wireless component.