1:25-cv-00477
UMBRA LLC v. Electrolux Consumer Products Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Umbra LLC (New York)
- Defendant: Electrolux Consumer Products, Inc. (Delaware)
- Plaintiff’s Counsel: Potter Anderson & Corroon LLP
- Case Identification: 1:25-cv-00477, D. Del., 04/18/2025
- Venue Allegations: Venue is asserted in the District of Delaware based on Defendant's incorporation in that state.
- Core Dispute: Plaintiff alleges that Defendant’s "Deans Dish Drying Mat with Rack," sold under the Frigidaire brand, infringes a patent related to a combination dish drying mat and rack assembly.
- Technical Context: The technology concerns kitchen housewares, specifically products designed to combine the water-absorbing properties of a drying mat with the structural support of a dish rack for holding kitchenware.
- Key Procedural History: The complaint notes a corporate succession, alleging Defendant Electrolux Consumer Products, Inc. is the successor-in-interest to Electrolux Home Products, Inc. It also alleges that Plaintiff provided Defendant with notice of the alleged infringement via letters on February 3, 2025, and February 28, 2025, prior to filing the complaint.
Case Timeline
| Date | Event |
|---|---|
| 2015-12-22 | ’453 Patent Priority Date (Application Filing Date) |
| 2018-03-06 | ’453 Patent Issued |
| 2024-06-25 | Trademark assignment recorded to Defendant (Alleged) |
| 2025-02-03 | Plaintiff sent first pre-suit notice letter to Defendant |
| 2025-02-28 | Plaintiff sent second pre-suit notice letter to Defendant |
| 2025-04-18 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,907,453 - “COMBINATION DISH DRYING MAT AND RACK”
The Invention Explained
The patent's background section identifies issues with conventional dish drying solutions, noting that standalone racks often require a separate towel to catch water runoff and can be bulky, while standard drying mats lack structures to hold plates or utensils upright for efficient drying (’453 Patent, col. 1:31-48).
The invention is a single, integrated product comprising a flexible, absorbent mat and a removable, rigid rack (’453 Patent, Abstract). The rack features specific structures, such as upward-extending ribs and protrusions, designed to hold plates and other kitchenware upright, while the mat absorbs water runoff (’453 Patent, col. 2:1-17). A key feature is the mat's ability to be folded around the rack for compact storage, secured by a strap (’453 Patent, col. 6:4-29; Fig. 11).
The claimed invention provides a hybrid solution that combines the space-saving and absorbent qualities of a mat with the organizational and air-drying benefits of a rack into a single, cohesive, and easily storable unit (’453 Patent, col. 1:50-59).
Key Claims at a Glance
- The complaint asserts infringement of at least independent claim 1 (Compl. ¶33).
- The essential elements of independent claim 1 include:
- A mat with a top surface, a bottom surface, a plurality of segments, and at least two folds, arranged to be foldable into a closed position.
- A rack with a base that rests on the mat.
- The rack has a plurality of upwardly extending ribs forming channels to hold kitchenware upright.
- The rack also has a plurality of upwardly extending protrusions arranged in pairs.
- The rack has a plurality of slots recessed within the base, which are co-planar and parallel.
- The rack is arranged to be disposed within a portion of the mat when the mat is folded into a closed position.
- The complaint does not explicitly reserve the right to assert dependent claims, but the general allegation of infringing "one or more claims" leaves this possibility open (Compl. ¶27).
III. The Accused Instrumentality
Product Identification
The accused product is the "Deans Dish Drying Mat with Rack," sold by Defendant under the "Frigidaire" brand (Compl. ¶22).
Functionality and Market Context
The complaint describes and depicts the Accused Product as a single unit combining a textile mat with an integrated, molded plastic rack (Compl. ¶22, p.6). The product's packaging, shown in a photograph, indicates it has a "POLYESTER EXTERIOR," "POLYURETHANE FOAM INTERIOR," and a "POLYPROPYLENE" rack (Compl. p.7). The visual evidence provided shows the plastic rack portion features a series of parallel ridges and what appear to be smaller, perpendicular nubs (Compl. p.6). The product is sold through retail channels such as Amazon.com (Compl. ¶¶22, 25). The complaint includes a screenshot from the "Frigidaire Store" on Amazon showing the Accused Product for sale (Compl. p.8).
IV. Analysis of Infringement Allegations
The complaint references an exemplary claim chart attached as Exhibit B, which was not included with the filing (Compl. ¶27). The following chart is constructed based on the complaint's narrative allegations, the provided images of the Accused Product, and the language of asserted claim 1 of the ’453 Patent.
’453 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a mat having a top surface, bottom surface, a plurality of segments and at least two folds, wherein each fold is disposed as a divisor between each of two segments and the mat is operatively arranged to be foldable about the folds into a closed position... | The Accused Product includes a flexible, absorbent mat component upon which the rack sits. The mat's ability to be folded for storage is alleged to meet this limitation. | ¶¶22, 33; p.6 | col. 6:4-25 |
| a rack having a base, wherein the base of the rack rests upon at least a portion of the top surface of the mat in an open position... | The Accused Product includes a molded plastic rack component that is integrated with and rests upon the fabric mat. A photograph in the complaint shows the product in its open, ready-to-use state (Compl. p.6). | ¶¶22, 33; p.6 | col. 4:28-32 |
| the rack having a plurality of ribs extending upwardly from the base and a plurality of channels, wherein the plurality of ribs form the corresponding plurality of channels, the plurality of ribs and channels are operatively arranged to hold kitchenware in a substantially upright position... | The plastic rack component of the Accused Product has a series of raised parallel ridges that form channels between them, designed to hold dishes upright, as depicted in a product photograph (Compl. p.6). | ¶¶22, 33; p.6 | col. 4:51-64 |
| the rack further comprising a plurality of protrusions extending upwardly from the base and a plurality of slots recessed within the base, wherein the plurality of protrusions are arranged in pairs... and the plurality of slots are co-planar and parallel to one another. | The plastic rack component also features smaller raised elements between the larger ribs, which are alleged to be the claimed "protrusions" and "slots" for holding utensils or other items (Compl. p.6). | ¶¶22, 33; p.6 | col. 5:22-43 |
| and the rack is arranged to be disposed within at least a portion of the mat when the mat is folded into a closed position. | The complaint alleges infringement of the claim as a whole, which implies the Accused Product's mat can be folded in a manner that at least partially encloses the rack portion. | ¶¶27, 33 | col. 6:12-25 |
- Identified Points of Contention:
- Scope Questions: The case may turn on the construction of "foldable about the folds into a closed position." The patent specification and figures describe a specific folding method where separate mat segments wrap entirely around the rack (Fig. 11). The complaint does not show the accused product being folded. A central question will be whether the accused product, which appears to have a permanently attached rack on a flexible mat, is capable of being folded in the manner required by the claim.
- Technical Questions: Evidence will be needed to determine if the structures on the accused rack meet the specific definitions and arrangements of "ribs," "protrusions," and "slots" as claimed. For example, the court may need to decide if the small raised elements on the accused product are "arranged in pairs" and form "slots" in the manner described in the patent specification.
V. Key Claim Terms for Construction
- The Term: "a mat... operatively arranged to be foldable about the folds into a closed position" (Claim 1)
- Context and Importance: This term is critical because it defines a primary functional feature of the claimed invention—compact storage via a specific folding mechanism. The infringement analysis will likely depend on whether the accused product's mat and rack combination, which appears to be a single integrated unit, can be considered "foldable" into a "closed position" in the way envisioned by the patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that any mat that is flexible and can be folded for storage meets the plain meaning of the term. The specification describes the mat as being made of a "substantially flexible material, such as microfiber, cloth, etc." (’453 Patent, col. 2:49-51), which may support the view that general flexibility is the key.
- Evidence for a Narrower Interpretation: A party could argue the term requires the specific structure shown in the patent's figures and description. The specification details a mat with "three segments and two folds" where the segments fold over one another to fully enclose the rack, secured by a strap (Fig. 11; ’453 Patent, col. 6:4-25). This specific embodiment may be used to argue for a narrower construction that the accused product does not meet.
VI. Other Allegations
- Indirect Infringement: The complaint alleges active inducement, asserting Defendant induced infringement by third parties (Compl. ¶34). The basis for this allegation is not detailed beyond general statements.
- Willful Infringement: Willfulness is alleged based on Defendant's purported knowledge of the ’453 Patent. The complaint specifically cites pre-suit notice letters sent to Defendant on February 3, 2025, and February 28, 2025, as establishing knowledge (Compl. ¶28, ¶40). It also alleges that, alternatively, Defendant knew of a high probability of infringement and took deliberate actions to avoid learning of the facts (Compl. ¶37).
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this dispute will likely depend on the court's determination of two central issues:
- A core issue will be one of definitional scope: can the phrase "foldable about the folds into a closed position," which the patent illustrates as a specific wrap-around enclosure, be construed to cover the accused product, which appears to be a flexible mat with a permanently affixed rack that may fold in a more general manner?
- A key evidentiary question will be one of structural correspondence: do the raised elements on the accused product's rack possess the specific quantity, arrangement, and function of the "ribs," "protrusions arranged in pairs," and "slots" as strictly required by the limitations of Claim 1, or is there a material difference in their structure and operation?