DCT
1:25-cv-00484
Seakeeper Inc v. Dometic Corp
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Seakeeper, Incorporated (Delaware)
- Defendant: Dometic Corporation (Delaware)
- Plaintiff’s Counsel: Richards, Layton & Finger, P.A.; Marshall, Gerstein & Borun LLP
- Case Identification: 1:25-cv-00484, D. Del., 04/21/2025
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because the Defendant is a corporation organized and existing under the laws of Delaware.
- Core Dispute: Plaintiff alleges that Defendant’s DG3 marine gyrostabilizer infringes patents related to systems for cooling the heat-generating components of such devices.
- Technical Context: The technology involves gyroscopic stabilizers that counteract a boat’s side-to-side roll, a technology that has become a significant feature for enhancing comfort and safety in the recreational and small commercial marine markets.
- Key Procedural History: The complaint alleges that in January 2024, Defendant entered into discussions to potentially acquire Plaintiff, signing a confidentiality agreement and receiving confidential technical and business information. The complaint alleges that Defendant subsequently launched its accused product in February 2025, incorporating patented technology that was absent from Defendant's own earlier patent application designs, suggesting that the accused product was developed using Plaintiff's confidential information.
Case Timeline
| Date | Event |
|---|---|
| 2006-01-12 | U.S. Patent Nos. 7,546,782 & 8,117,930 Priority Date |
| 2009-06-16 | U.S. Patent No. 7,546,782 Issue Date |
| 2012-02-21 | U.S. Patent No. 8,117,930 Issue Date |
| 2024-01-XX | Dometic allegedly approaches Seakeeper for acquisition talks |
| 2024-02-04 | Parties allegedly enter into a confidentiality agreement |
| 2025-02-11 | Dometic reveals the accused DG3 product to the public |
| 2025-02-12 | Dometic issues a press release announcing the DG3 product |
| 2025-04-21 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,546,782 - “Cooling bearings, motors and other rotating heat generating components,” issued June 16, 2009
The Invention Explained
- Problem Addressed: The patent addresses the challenge of dissipating significant friction-generated heat from the bearings of high-speed flywheels, a problem that is particularly acute when the flywheel operates in a partial vacuum where conventional air convection is ineffective (Compl. ¶25-26; ’782 Patent, col. 1:20-38). This heat buildup can lead to lubricant failure and catastrophic destruction of the bearings ( Compl. ¶27; ’782 Patent, col. 2:35-40).
- The Patented Solution: The invention provides a cooling apparatus comprising a first heat transfer element (e.g., a set of vanes) attached to the spinning member and a second, stationary heat transfer element in close proximity. This configuration allows for substantial heat transfer from the rotating components to the stationary components via gaseous conduction and convection, which then dissipates the heat to the exterior of the device (Compl. ¶30-33; ’782 Patent, Abstract; col. 3:1-10).
- Technical Importance: This cooling innovation is described as enabling the creation of compact, lightweight, and power-efficient gyroscopic stabilizers that are feasible for smaller recreational boats, which lack the space and power resources of larger vessels (Compl. ¶35-37).
Key Claims at a Glance
- The complaint asserts independent claim 11 (Compl. ¶67).
- The essential elements of independent claim 11 include:
- An enclosure for a spinning member containing a gas at below-ambient pressure or density.
- A first plurality of vanes attached to the spinning member, described as "cylindrical elements."
- A second plurality of fixed vanes, also "cylindrical elements," that define channels into which the first vanes extend so they are "interleaved."
- The first and second vanes are positioned in "close proximity" to allow for "substantial heat" transfer, with the second vanes configured to transfer that heat to the exterior of the enclosure.
U.S. Patent No. 8,117,930 - “Cooling bearings, motors and other rotating heat generating components,” issued February 21, 2012
Technology Synopsis
This patent, which is a continuation of the application that resulted in the ’782 Patent, is directed to a "gyroscopic roll stabilizer for a boat" (Compl. ¶44, 87). The invention claims a stabilizer that includes a flywheel, a heat-generating component, and interleaved first and second pluralities of vanes for cooling. A key feature is the requirement that the enclosure contains a "below-ambient density gas" with a "thermal conductivity at least 5 times greater than air," with the entire apparatus configured to damp the roll motion of a boat (’930 Patent, Abstract; col. 10:29-67).
Asserted Claims
The complaint asserts independent claim 1 (Compl. ¶87).
Accused Features
The Dometic DG3 product is accused of infringement, specifically its alleged system of a flywheel, interleaved cooling vanes, and a sealed enclosure that, on information and belief, contains helium gas to meet the high-thermal-conductivity requirement (Compl. ¶89-93).
III. The Accused Instrumentality
Product Identification
- The Dometic DG3 marine gyrostabilizer (Compl. ¶47).
Functionality and Market Context
- The DG3 is a gyrostabilizer designed to enhance boat stability by minimizing roll motion (Compl. ¶47). The complaint alleges its internal structure includes a spinning flywheel within a sealed enclosure, a "first plurality of vanes" attached to the flywheel, and a "second set [of vanes] is stationary and attached to the enclosure" to dissipate heat (Compl. ¶48). An annotated cutaway diagram provided in the complaint illustrates a spinning member with green-highlighted vanes interleaved with stationary vanes. (Compl. ¶48, p. 11). The complaint also alleges, on information and belief, that the DG3 enclosure contains helium gas (Compl. ¶93).
- The complaint alleges the DG3 marks Dometic's entry into the "rapidly growing vessel stabilizer market," a market where Seakeeper asserts it holds a 95% share (Compl. ¶46, 59).
IV. Analysis of Infringement Allegations
’782 Patent Infringement Allegations
| Claim Element (from Independent Claim 11) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an enclosure enclosing the spinning member, the enclosure containing a gas at below-ambient pressure or below-ambient density... | The DG3 product includes an enclosure that encloses a spinning member at below-ambient pressure or density. | ¶69, 73 | col. 5:25-29 |
| a first plurality of vanes attached to the spinning member... wherein the first vanes are cylindrical elements... | The DG3 product includes a first plurality of vanes attached to its spinning member, which are alleged to be cylindrical elements. | ¶70, 73 | col. 6:55-61 |
| a second plurality of vanes fixed relative to the enclosure... wherein the second vanes are cylindrical elements... the second vanes defining cylindrical shaped channels into which the first vanes extend so that the first and second vanes are interleaved... | The DG3 product includes a second, fixed plurality of vanes defining channels into which the first vanes extend, causing them to be interleaved. | ¶71, 73 | col. 6:55-65 |
| wherein the first and second vanes are positioned in close proximity to one another so that substantial heat is transferred from the first vanes to the second vanes and the second vanes are configured such that that heat can be readily transferred from the second vanes to the exterior of the enclosure. | The first and second vanes in the DG3 are allegedly positioned in close proximity for substantial heat transfer to the exterior. An annotated diagram shows the alleged configuration. (Compl. ¶73). | ¶72, 73 | col. 6:65-12 |
’930 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a flywheel, the flywheel being configured to be spun about a spin axis | The DG3 product includes a flywheel configured to be spun about a spin axis. | ¶89, 95 | col. 10:32-34 |
| a first plurality of vanes coupled to the flywheel such that the first plurality of vanes spin with the flywheel relative to an enclosure | The DG3 allegedly has a first plurality of vanes coupled to the flywheel that spin relative to the enclosure. | ¶90, 95 | col. 10:35-38 |
| a second plurality of vanes fixed relative to the enclosure... the second plurality of vanes defining gaps into which the first plurality of vanes extend so that the first and second plurality of vanes are interleaved | The DG3 allegedly has a second, fixed plurality of vanes with gaps into which the first vanes extend, resulting in an interleaved structure. | ¶91, 95 | col. 10:39-45 |
| at least one rotating heat generating component coupled to the flywheel and positioned such that heat is transferred from the heat generating component to the first plurality of vanes | The DG3 is alleged to have at least one rotating heat generating component positioned to transfer heat to the first plurality of vanes. | ¶92, 95 | col. 10:46-50 |
| the enclosure... containing a below-ambient density gas... wherein the below ambient density gas has a thermal conductivity at least 5 times greater than air | The complaint alleges on information and belief that the DG3's enclosure contains helium, a gas with thermal conductivity more than 5 times greater than air. | ¶93, 95 | col. 10:55-59 |
| wherein the flywheel, the first plurality of vanes... and the gimbal structure are configured so that, when installed in the boat, the stabilizer damps roll motion of the boat | The DG3 product, including its alleged flywheel and vane system, is configured to damp the roll motion of a boat when installed. | ¶94 | col. 10:63-67 |
Identified Points of Contention
- Scope Questions: A central question for the ’782 patent will be whether the term "cylindrical elements" can be construed to read on the specific geometry of the vane structures within the accused DG3 product.
- Technical Questions: For the ’930 patent, a key factual dispute will be proving the composition of the gas inside the sealed DG3 enclosure. The complaint's allegation that it contains helium is made "on information and belief" (Compl. ¶93), raising the question of what evidence Seakeeper will produce to meet this specific quantitative claim limitation.
V. Key Claim Terms for Construction
The Term: "cylindrical elements" (’782 Patent, Claim 11)
Context and Importance
This term defines the shape of the vanes central to the claimed cooling apparatus. The infringement analysis for the ’782 patent will depend on whether the physical structures within the DG3 are found to be "cylindrical." Practitioners may focus on this term because the visual evidence in the complaint depicts complex shapes that Dometic may argue are not "cylindrical" in the sense intended by the patent.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The specification discusses alternative embodiments, such as vanes that are "planar elements extending in radial directions," which could support an argument that "cylindrical" should not be limited to a perfect geometric cylinder and can encompass other shapes that perform the same interleaving function (’782 Patent, col. 3:45-50).
- Evidence for a Narrower Interpretation: The primary embodiments detailed in the patent's figures (e.g., Figs. 4, 5, 8, 9) consistently depict sets of concentric, nested cylinders. This could support an argument that the term is limited to the specific structures shown and described in detail.
The Term: "below-ambient density gas has a thermal conductivity at least 5 times greater than air" (’930 Patent, Claim 1)
Context and Importance
This quantitative limitation is a critical hurdle for proving infringement of the ’930 patent. The entire infringement theory for this patent rests on establishing that the DG3 contains a gas meeting this specific physical property.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: A party might argue that the "5 times greater" property should be interpreted under a range of standard operating conditions, rather than a single, specific temperature or pressure, unless the specification dictates otherwise.
- Evidence for a Narrower Interpretation: The patent specification, incorporated by reference from the parent ’782 patent, explicitly names "helium or hydrogen" as gases that would satisfy the goal of increased heat transfer (’782 Patent, col. 7:29-34). A party could argue that this context limits the scope or, at minimum, sets a clear standard for what kind of gas satisfies the claim.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Dometic induces infringement by providing the DG3 product and instructing customers on its use, and contributes to infringement by selling a product that is a material part of the patented invention, is not a staple article of commerce, and is especially made for use in an infringing manner (Compl. ¶75-76, 97-98).
- Willful Infringement: The willfulness allegation is based on alleged pre-suit knowledge of the patents, which Dometic is said to have gained "by at least as early as February 2024" during due diligence for a potential acquisition of Seakeeper (Compl. ¶78, 100). The claim is bolstered by allegations that Dometic fundamentally altered its product design to include the patented vane technology only after being exposed to Seakeeper's confidential information, pointing to an earlier Dometic patent application with a different design as evidence (Compl. ¶53-55).
VII. Analyst’s Conclusion: Key Questions for the Case
- A key evidentiary question will be one of technical proof: what evidence will Seakeeper present to prove the precise internal construction and gaseous composition of the sealed Dometic DG3 unit, particularly to satisfy the "cylindrical elements" and "5 times greater than air" thermal conductivity limitations of the asserted claims?
- The case may turn on a question of definitional scope: can the term "cylindrical elements," as used in the ’782 patent, be construed broadly enough to read on the vane geometry in the accused DG3 device, or will Dometic succeed in arguing for a narrower construction that its product avoids?
- A central issue for willfulness will be one of causation and intent: does the evidence, including the timeline of acquisition talks and alleged design changes, support the narrative that Dometic's accused product was derived from Seakeeper's confidential technology, or will Dometic be able to demonstrate independent innovation?