DCT
3:25-cv-04656
Shenzhen Tao Yi An E Commerce Co Ltd v. SharkNinja Operating LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Shenzhen Tao Yi An E-Commerce Co., Ltd. (China)
- Defendant: SharkNinja Operating LLC (Massachusetts)
- Plaintiff’s Counsel: SHM Law Firm
- Case Identification: 3:25-cv-04656, N.D. Cal., 06/03/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant’s enforcement actions, specifically an infringement complaint submitted to Amazon, caused financial harm to the Plaintiff within the Northern District of California, where Plaintiff's products are sold. Plaintiff further alleges that Defendant targets California consumers and maintains operational locations in the state.
- Core Dispute: Plaintiff seeks a declaratory judgment that its slushy machines do not infringe Defendant’s patent related to internal baffles within a mixing vessel.
- Technical Context: The technology concerns the mechanical design of mixing vessels for frozen drink makers, using internal structures to control the flow of slush for more efficient and complete mixing.
- Key Procedural History: The complaint states that this action was precipitated by Defendant's assertion of the patent-in-suit against Plaintiff through an infringement complaint to Amazon. This action allegedly resulted in the removal of Plaintiff's product listing from Amazon.com on or about May 23, 2025.
Case Timeline
| Date | Event |
|---|---|
| 2024-01-18 | U.S. Patent No. 12,279,629 Priority Date |
| 2025-04-22 | U.S. Patent No. 12,279,629 Issue Date |
| 2025-05-23 | Plaintiff's product listing allegedly removed from Amazon |
| 2025-06-03 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,279,629 - Mixing vessel baffles for a drink maker
- Patent Identification: U.S. Patent No. 12,279,629, “Mixing vessel baffles for a drink maker,” issued April 22, 2025.
The Invention Explained
- Problem Addressed: The patent identifies a problem with existing frozen drink makers, particularly household units, where slush can migrate up the sidewalls and stick to the top of the mixing chamber. This leads to inefficient mixing, poor circulation, and product waste, a problem exacerbated by the shorter chamber heights of non-commercial models (’629 Patent, col. 4:51-62).
- The Patented Solution: The invention is a mixing vessel that incorporates at least one, and up to three, internal baffles: a "side baffle" running laterally, a "front baffle" across the top front, and a "corner baffle" joining them. These structures are designed to work in tandem to actively direct the flow of slush away from the top of the vessel and back into the mixing path, ensuring more thorough processing ('629 Patent, Abstract; col. 5:13-18).
- Technical Importance: This design purports to provide precise slush control, which is described as "especially important for household frozen drink makers" that "cannot rely on a tall chamber height to control slush flow" in the way larger commercial machines can ('629 Patent, col. 4:58-62).
Key Claims at a Glance
- The complaint seeks a declaratory judgment of non-infringement with respect to independent claims 1, 13, and 20 (Compl. ¶21, ¶27).
- Independent Claim 1 requires, among other elements:
- a curved sidewall defining a vessel chamber
- a corner baffle positioned at the front and the top of the vessel chamber
- a front baffle positioned at the front of the vessel chamber extending from the left side toward the right side across the top
- Independent Claim 13 requires, among other elements:
- a curved sidewall defining a vessel chamber
- a corner baffle positioned at the front and the top of the vessel chamber
- a side baffle extending laterally along the vessel chamber
- a front baffle positioned at the front of the vessel chamber extending from the left side toward the right side across the top
- Independent Claim 20 requires, among other elements:
- a mixing vessel comprising a curved sidewall defining a vessel chamber
- a housing, a dasher, and a dispenser assembly
- at least two internal baffles, comprising a front baffle positioned at the front of the vessel chamber extending from the left side toward the right side across the top
III. The Accused Instrumentality
Product Identification
- The products at issue are identified as the "Non-Infringing Slushy Machines" sold by Plaintiff through its Amazon.com storefront, "STERAYS Mall" (Compl. ¶¶ 9, 14). The complaint specifically references a product identified by Amazon Standard Identification Number (ASIN) B0DSLJDJK4 (Compl. ¶15).
Functionality and Market Context
- The complaint describes the products as "slushy machines" but provides no specific technical details regarding their operation or internal geometry, aside from asserting what features they lack (Compl. ¶¶ 27-28). No probative visual evidence provided in complaint.
- Plaintiff alleges that the Amazon marketplace is its "primary sales channel into the United States" and that the delisting of its products has caused "immediate and irreparable harm" (Compl. ¶¶ 4, 18).
IV. Analysis of Infringement Allegations
This is a declaratory judgment action where the Plaintiff alleges non-infringement. The following chart summarizes the Plaintiff's non-infringement contentions for the representative elements of Claim 1.
'629 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality (as argued by Plaintiff) | Complaint Citation | Patent Citation |
|---|---|---|---|
| a curved sidewall defining a vessel chamber therein... | The complaint alleges that the Non-Infringing Slushy Machines "lack the limitation that 'a curved sidewall defining a vessel chamber therein.'" | ¶28 | col. 2:2-3 |
| a corner baffle positioned at the front and the top of the vessel chamber on either the right side or the left side, wherein the corner baffle is configured to direct slush flow within the vessel chamber; and | The complaint alleges that the Non-Infringing Slushy Machines "lack the limitation that 'a corner baffle positioned at the front and the top of the vessel chamber on either the right side or the left side.'" | ¶28 | col. 2:4-7 |
| a front baffle positioned at the front of the vessel chamber extending from the left side toward the right side across the top. | The complaint alleges that the Non-Infringing Slushy Machines "lack the limitation that 'a front baffle positioned at the front of the vessel chamber extending from the left side toward the right side across the top.'" | ¶27 | col. 2:32-35 |
- Identified Points of Contention:
- Scope Questions: The dispute raises the question of how broadly the key structural terms will be construed. For example, does the term "curved sidewall" encompass any non-planar surface, or is it limited by the specification’s references to "substantially cylindrical" or "oval-shaped" cross-sections ('629 Patent, col. 2:42-43)? Similarly, what range of internal protrusions fall within the scope of a "corner baffle" and a "front baffle"?
- Technical Questions: The central issue will be a factual comparison of the accused product's physical geometry against the claim limitations. The complaint's bare allegations of non-infringement provide no evidence as to what structure the accused products actually employ. The key question for the court will be whether the accused slushy machines, in fact, contain structures that perform the functions of the claimed baffles in the claimed locations, even if they are not explicitly named as such.
V. Key Claim Terms for Construction
The Term: "corner baffle"
Context and Importance: This term appears in independent claims 1 and 13, and Plaintiff explicitly alleges its products lack this feature (Compl. ¶28). Its definition is therefore critical to the infringement analysis for a majority of the asserted claims.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim requires the baffle to be "positioned at the front and the top of the vessel chamber" and "configured to direct slush flow" ('629 Patent, col. 15:30-32). A party could argue that any structure meeting these general positional and functional requirements qualifies, regardless of its specific shape or how it achieves the flow direction.
- Evidence for a Narrower Interpretation: The specification describes the corner baffle in a more specific functional context, stating it is positioned "such that the dasher is directed toward the corner baffle while moving upwardly" to force slush downward ('629 Patent, col. 13:31-41). The patent also discloses that the corner baffle may "physically join the side baffle and the front baffle" ('629 Patent, col. 13:12-13). A party may argue the term should be limited to structures that perform this specific upward-to-downward redirection or that connect other baffle elements.
The Term: "front baffle"
Context and Importance: This term is a limitation in all three asserted independent claims (1, 13, and 20), and Plaintiff alleges its products lack this feature (Compl. ¶27). Its construction is fundamental to the entire non-infringement case.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language broadly requires "a front baffle positioned at the front of the vessel chamber extending from the left side toward the right side across the top" ('629 Patent, col. 15:33-35). This could potentially read on any lip, rib, or protrusion that spans the top-front of the mixing vessel.
- Evidence for a Narrower Interpretation: The detailed description states the front baffle "is configured to urge contents away from the top surface of the vessel chamber" and may form a specific angle (e.g., 100°-150°) relative to the front face of the chamber ('629 Patent, col. 13:48-56, col. 14:1-4). A party may argue that to be a "front baffle," a structure must meet these more detailed functional and angular requirements, not just be a passive structural feature.
VI. Other Allegations
- Indirect Infringement: The Plaintiff seeks a declaratory judgment that it has not infringed the ’629 Patent "either directly, contributorily, or by inducement" (Compl. ¶26). As a complaint for declaratory relief, it does not allege facts supporting these theories but rather denies that its conduct meets the legal standards for any form of infringement.
- Willful Infringement: This allegation is not made in the complaint, as the action is brought by the accused infringer.
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of structural correspondence: Do the Plaintiff's "STERAYS Mall" slushy machines contain physical structures that meet the claim limitations of a "curved sidewall," a "corner baffle," and a "front baffle"? This will require a factual comparison between the accused product's design and the language of the claims, a comparison for which the complaint currently provides no visual or detailed technical evidence.
- The outcome will also depend on definitional scope: How will the court construe the term "baffle"? Will the term be interpreted broadly to cover any internal wall protrusion that affects slush flow, or will it be narrowed to the specific positional, angular, and cooperative functions detailed in the '629 patent's specification? The resolution of this question will likely determine whether Plaintiff's products are found to be non-infringing.