DCT

2:25-cv-02523

Brokenbrough v. Davison Design & Devel Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-02523, E.D. Cal., 09/04/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendants have committed acts of patent infringement in the district and maintain regular and established places of business through the distribution and sale of infringing products within the district.
  • Core Dispute: Plaintiff alleges that Defendants misappropriated his invention for a portable cooking station, which Defendants then commercialized in the Blackstone griddle product line and patented in their own name, and seeks correction of inventorship on Defendants' patents and damages for patent infringement, among other claims.
  • Technical Context: The technology relates to portable outdoor cooking stations, specifically griddles, featuring innovations in portability, grease management, and hood design within the consumer outdoor cooking market.
  • Key Procedural History: The complaint alleges a decade-long (2009-2019) business relationship between Plaintiff and Defendant Davison for product development, governed by confidentiality and development agreements. Plaintiff alleges this relationship was used to misappropriate his invention concepts. No prior litigation or post-grant proceedings are mentioned in the complaint.

Case Timeline

Date Event
2009 Plaintiff alleges conception of the "Portable Cooking Station" invention
2009-11 Plaintiff contacts Defendant Davison Design & Development
2009-12-15 Plaintiff and Davison execute a Confidentiality Agreement
2010-08-19 Plaintiff and Davison enter a "New Product Sample Agreement"
2016-05-04 Earliest priority date for U.S. Patent No. 12,185,873
2019-07-12 Earliest priority date for U.S. Patent No. 12,274,394
2020-04-09 Earliest priority date for U.S. Patent No. 12,150,590
Late 2023 Plaintiff alleges discovery of Defendants' accused products
2024-11-26 U.S. Patent No. 12,150,590 issues
2025-01-07 U.S. Patent No. 12,185,873 issues
2025-04-15 U.S. Patent No. 12,274,394 issues
2025-09-04 Complaint filed

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

U.S. Patent No. 12,150,590 - "Griddle Cooking Station with Hood and Method Thereof"

  • Patent Identification: U.S. Patent No. 12,150,590, titled "Griddle Cooking Station with Hood and Method Thereof," issued on November 26, 2024 (the "’590 Patent").

The Invention Explained

  • Problem Addressed: The patent's background section identifies a problem specific to portable grills with hoods: large forces placed on an open hood during windy conditions can cause the entire grill to become unstable and potentially topple over, creating a dangerous situation ('590 Patent, col. 1:47-51).
  • The Patented Solution: The invention is a cooking station with a hood that is not only pivotable but also fully removable from the griddle. The hood couples to the griddle via pins on the splash guard that engage with corresponding notches on the hood, allowing it to pivot between open and closed positions ('590 Patent, col. 8:55-61). When tilted to a specific forward angle, the hood can be lifted off the pins and removed entirely ('590 Patent, col. 10:50-65). A key feature is a "hook structure" on the hood that allows the removed hood to be hung securely on the rear splash guard in a low-profile position, mitigating the wind hazard ('590 Patent, Abstract).
  • Technical Importance: This design aims to enhance the safety and usability of portable griddles by providing a practical way to manage the hood in adverse weather conditions common to outdoor cooking.

Key Claims at a Glance

  • The complaint does not identify specific asserted claims. Independent claim 1 is representative of the core invention.
  • Essential elements of Independent Claim 1 include:
    • A main body supporting heating elements.
    • A griddle with a splash guard having first and second hinge pins that define a pivot axis.
    • A hood with first and second side hood walls, each defining a slot configured to receive the respective hinge pins, allowing the hood to pivot about the axis.
    • The slots are configured to facilitate the hood being manually moved upward when in an open position, allowing the pins to slide out of the slots so the hood is removable.
    • The hood is positionable to hang on the rear splash guard with a hook structure after being removed.

U.S. Patent No. 12,185,873 - "Outdoor Cooking Station with Griddle, System and Method Thereof"

  • Patent Identification: U.S. Patent No. 12,185,873, titled "Outdoor Cooking Station with Griddle, System and Method Thereof," issued on January 7, 2025 (the "’873 Patent").

The Invention Explained

  • Problem Addressed: The patent background describes a common issue with griddle cooking: the buildup of grease and food byproducts. It notes that conventional drain systems located on the side or front of the griddle are unsightly and can lead to grease spilling or spattering onto the front of the cooking station and the user ('873 Patent, col. 1:62 - col. 2:2).
  • The Patented Solution: The invention proposes a rear-mounted grease management system. It features a trough defined in the cooking surface at its rear central portion, which includes a sloped surface extending downward toward a "rear opening" in the splash guard ('873 Patent, Abstract). This configuration allows a user to push unwanted grease and debris to the back of the griddle, where it is funneled through the opening and collected in a container below, keeping it out of sight and away from the user ('873 Patent, col. 2:35-40). The specification describes the trough as having a "v-shape" to facilitate this funneling ('873 Patent, col. 4:10-14).
  • Technical Importance: By relocating the grease collection system to the rear, the invention aims to improve the cleanliness, aesthetics, and safety of the griddle cooking experience.

Key Claims at a Glance

  • The complaint does not identify specific asserted claims. Independent claim 1 is representative of the core invention.
  • Essential elements of Independent Claim 1 include:
    • An outdoor cooking station with a frame and a griddle.
    • A flat cooking surface.
    • A splash guard extending upward from the front, rear, left, and right ends of the cooking surface.
    • The rear splash guard defines a "grease opening" and has a height greater than the front splash guard.
    • A "sloped surface" extending from the flat cooking surface adjacent to the rear end, extending downward toward the grease opening.

U.S. Patent No. 12,274,394 - "Heat Channeling System for Outdoor Cooking Station and Method Thereof"

  • Patent Identification: U.S. Patent No. 12,274,394, titled "Heat Channeling System for Outdoor Cooking Station and Method Thereof," issued on April 15, 2025 (the "’394 Patent").

Technology Synopsis

  • The patent describes a solution to the problem of heat escaping laterally from underneath a griddle, which can create a hazard and potentially damage adjacent side shelves. The invention consists of one or more baffles positioned along the sides of the griddle, which are configured to capture and redirect, or "funnel," this lateral heat upward into the area above the cooking surface and beneath the hood ('394 Patent, Abstract; col. 2:8-14).

Asserted Claims

  • The complaint does not specify asserted claims. Independent claim 1 is representative.

Accused Features

  • The complaint broadly accuses Blackstone griddle products of incorporating the Plaintiff's original invention, which allegedly includes features covered by this patent (Compl. ¶¶ 36-37). Specific features accused in the complaint include flat cooking surfaces, grease management systems, portability, temperature controls, and side shelves (Compl. ¶36).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies "Blackstone's griddle products, marketed under various model names" as the accused instrumentalities (Compl. ¶36).

Functionality and Market Context

  • The complaint alleges the accused products incorporate features that are "identical or substantially similar" to the Plaintiff's original invention (Compl. ¶36). These alleged features include:
    • Flat cooking surfaces for versatile food preparation (Compl. ¶36a).
    • Grease management systems with drainage and collection (Compl. ¶36b).
    • Portable designs with folding or removable legs (Compl. ¶36c).
    • Temperature control systems (Compl. ¶36d).
    • Side shelves and storage features (Compl. ¶36e).
  • The complaint alleges that these products have achieved significant commercial success, generating substantial revenue and market share in the outdoor cooking industry (Compl. ¶¶ 39, 42). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not provide an element-by-element infringement analysis or a claim chart mapping the asserted patents to the accused products. The central theory of the case is not a straightforward patent infringement claim by a patent owner against an accused infringer. Instead, the complaint alleges that Plaintiff is the true inventor of the subject matter claimed in the patents-in-suit, which are owned by Defendants (Compl. ¶¶ 37-38, 77).

The narrative infringement theory appears to be based on a claim of derivation and correction of inventorship. The complaint alleges that: (1) Plaintiff conceived of an invention for a portable cooking station with specific features (Compl. ¶17); (2) Plaintiff disclosed this invention to Defendant Davison under confidentiality (Compl. ¶25); (3) Defendants misappropriated this invention and incorporated its features into the accused Blackstone griddle products (Compl. ¶35-36); and (4) Defendants wrongfully obtained the patents-in-suit covering these same features (Compl. ¶37). The prayer for relief seeks damages for "patent infringement," suggesting that if Plaintiff is declared a rightful inventor or owner, the Defendants' commercialization of the products constitutes infringement for which he is owed compensation (Compl., p. 16, ¶2).

  • Identified Points of Contention:
    • Inventorship and Derivation: The primary legal and factual dispute will concern inventorship. The key question is whether the subject matter claimed in the ’590, ’873, and ’394 Patents was conceived independently by the named inventors or was derived from the confidential information Plaintiff allegedly provided to Defendant Davison.
    • Chain of Custody: A central factual question will be whether Plaintiff can establish a chain of communication and information transfer from Defendant Davison to the other Defendants (Blackstone/North Atlantic Imports) that would support the claim of misappropriation and derivation (Compl. ¶¶ 40-41).
    • Claim Scope vs. Plaintiff's Concepts: Should the case proceed to an infringement analysis, a key technical question will be the extent to which the specific features of Plaintiff's alleged 2009 invention (Compl. ¶17) align with the scope of the patent claims as issued years later.

V. Key Claim Terms for Construction

  • ’590 Patent Infringement Allegations: The complaint does not provide sufficient detail for analysis of infringement allegations on a claim-by-claim basis.

  • ’873 Patent Infringement Allegations: The complaint does not provide sufficient detail for analysis of infringement allegations on a claim-by-claim basis.

  • The Term: "hook structure" (’590 Patent, Claim 1)

  • Context and Importance: This term is critical to the novel "removable and hangable" hood feature. Its scope will determine what types of mechanisms on the hood for engaging the splash guard are covered by the claim, which is a central part of the patented solution to the wind-toppling problem.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The claim term itself is generic. The specification describes the function as being "for suspending the hood" ('590 Patent, col. 10:59-60). This functional language may support a construction that covers any protrusion or feature on the hood capable of performing the suspending function.
    • Evidence for a Narrower Interpretation: The only embodiment disclosed shows a specific tab-like structure with two extensions and a bend ('590 Patent, Fig. 6, elements 162, 164, 166, 168, 172). A defendant may argue that the term should be limited to this disclosed structure or equivalents thereof, as it is the only structure described as performing the claimed function.

  • The Term: "sloped surface" (’873 Patent, Claim 1)

  • Context and Importance: This term is the central element of the rear grease management system. The definition will determine the required geometry of the grease-funneling mechanism, which is key to the patent's purported improvement over prior art systems.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The plain meaning of "sloped surface" is broad and could encompass any surface angled downward toward the grease opening, including a simple flat plane or a curved, bowl-like shape ('873 Patent, Abstract).
    • Evidence for a Narrower Interpretation: The specification repeatedly describes the trough containing the sloped surface as having a "v-shape" ('873 Patent, col. 4:12; col. 4:61). This repeated characterization may support an argument that the claimed "sloped surface" must be part of a v-shaped structure to fall within the scope of the invention, potentially excluding other geometries.

VI. Other Allegations

  • Indirect Infringement: The complaint does not plead specific facts to support claims of induced or contributory infringement.
  • Willful Infringement: The complaint does not contain allegations of willful patent infringement. It does allege willful and malicious conduct in the context of trade secret misappropriation (Compl. ¶54).

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

This case appears to be primarily a dispute over inventorship and trade secret misappropriation rather than a conventional patent infringement action. The central questions for the court will likely be:

  • A core issue will be one of derivation: Can the Plaintiff produce sufficient evidence to demonstrate that the inventions claimed in the Defendants' ’590, ’873, and ’394 patents were derived from his confidential disclosures to Defendant Davison, rather than being independently conceived by the named inventors?
  • A key evidentiary question will be the link between defendants: Can the Plaintiff prove a connection between Davison Design & Development and the other manufacturing and sales entities (Blackstone, North Atlantic Imports) sufficient to establish that his allegedly misappropriated concepts were transferred and used to create the accused products and file the patents-in-suit?
  • Should the Plaintiff succeed in being named an inventor or owner, a dispositive issue will be one of claim scope: How broadly will key terms like "hook structure" and "sloped surface" be construed, and do the accused Blackstone products, as sold, fall within that scope?