DCT

1:25-cv-01406

Whirlpool Corp v. Haier US Appliance Solutions Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-01406, D. Del., 11/18/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant is incorporated in Delaware and has committed acts of patent infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s low-profile microwave hood combination products infringe a patent related to the space-saving mechanical design of such appliances.
  • Technical Context: The technology at issue involves over-the-range combination microwave and ventilation appliances designed with a reduced vertical height to fit in compact kitchen spaces.
  • Key Procedural History: The complaint alleges that Plaintiff's own products practice the asserted patent and have been marked accordingly. It also notes that Plaintiff's design received a 2019 iF Design Award.

Case Timeline

Date Event
2016-04-12 ’819 Patent Priority Date
2019 Whirlpool receives iF Design Award for its LP-MHC product category
2025-04-29 U.S. Patent No. 12,289,819 Issues
2025-11-18 Complaint Filed

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

U.S. Patent No. 12,289,819 - "Combination Microwave and Hood System"

  • Issued: April 29, 2025 (the "’819 Patent")

The Invention Explained

  • Problem Addressed: The patent's background section describes the problem that conventional combination microwave and ventilation hood systems "typically have a significant overall vertical dimension," which can limit their installation to kitchens with ample vertical space and may "restrict[] access to rear cooking regions of the cooking appliance" below ('819 Patent, col. 1:50-58).
  • The Patented Solution: The invention is a microwave and hood system with a "significantly scaled down overall vertical dimension" ('819 Patent, col. 4:45-47). This is achieved by repositioning key internal components, such as the hood and cooling fans, into a "component space" located on the lateral sides of the cooking cavity rather than primarily above or below it ('819 Patent, col. 8:41-45; col. 24:55-65). This arrangement, illustrated in figures such as FIG. 8, allows the appliance's external height to be reduced while preserving the internal cooking volume and ventilation functions ('819 Patent, col. 4:45-59).
  • Technical Importance: This compact design enables the installation of a dual-function appliance in spaces that previously could only accommodate a single-function ventilation hood, thereby saving countertop space (Compl. ¶9).

Key Claims at a Glance

  • The complaint asserts independent claims 1 and 30, and reserves the right to assert dependent claims 2-18, 21-22, and 24-29 (Compl. ¶¶19-20).
  • Independent Claim 1 requires, among other elements:
    • An external enclosure with a top portion, a bottom portion, and a cooking cavity inside.
    • A "cooking component" located inside the enclosure but outside the cooking cavity.
    • At least one "hood fan" and a separate "cooling fan."
    • A specific geometric arrangement wherein "each of the cooling fan and the at least one hood fan is located vertically below a top surface of the cooking cavity and vertically above a bottom surface of the cooking cavity."
  • Independent Claim 30 requires a similar structure but recites the key spatial limitation differently:
    • An external enclosure with a cooking cavity.
    • A cooking component, a hood fan, and a cooling fan.
    • A specific location for these components, wherein they are "located in a component space defined between exterior vertical surfaces of the cooking cavity and vertical surfaces of the external enclosure resulting in a vertical dimension of less than about 300 mm."

III. The Accused Instrumentality

Product Identification

The accused products are Haier's "low profile" over-the-range microwave ovens sold under the "GE" brand, including at least Stock Keeping Unit ("SKU") UVM9125STSS (the "Accused Products") (Compl. ¶¶13-14).

Functionality and Market Context

The complaint alleges the Accused Products are "copycat products" that offer the same dual-function microwave cooking and ventilation features in a compact, low-profile form factor as Plaintiff's patented design (Compl. ¶13). The complaint includes a screenshot from Defendant's website marketing the UVM9125STSS as a "Low Profile Sensor Microwave Oven," a term Plaintiff claims to have coined (Compl. ¶13, p. 5). The complaint also provides images from a teardown of an Accused Product, showing its internal components, such as fans, wiring, and the magnetron (Compl. p. 7). These photos depict the internal architecture that Plaintiff alleges infringes the ’819 Patent.

IV. Analysis of Infringement Allegations

The complaint references a claim chart in Exhibit B, which was not provided with the complaint, showing how the Accused Products allegedly infringe independent claims 1 and 30 of the ’819 Patent (Compl. ¶20). The narrative infringement theory is that the Accused Products adopt the patented space-saving design by arranging their internal ventilation fans and cooking components in the specific manner claimed by the ’819 Patent (Compl. ¶13). Plaintiff alleges that Defendant’s products, such as the UVM9125STSS, achieve a "low profile" by incorporating the claimed structure, including the specific relative locations of the hood fan, cooling fan, and cooking cavity (Compl. ¶¶13, 19). The inclusion of internal photographs of the Accused Product suggests Plaintiff intends to prove infringement through a direct structural comparison of the product's architecture to the patent's claim limitations (Compl. p. 7).

Identified Points of Contention

  • Scope Questions: A central issue may be the interpretation of the claims' specific spatial requirements. For Claim 1, the dispute could center on whether the Accused Products' fans are "located vertically below a top surface of the cooking cavity and vertically above a bottom surface of the cooking cavity." For Claim 30, the question may be whether the components are located in the claimed "component space defined between exterior vertical surfaces of the cooking cavity and vertical surfaces of the external enclosure."
  • Technical Questions: A key factual question will be whether the internal layout of the Accused Products, as depicted in the complaint's photographs (Compl. p. 7), matches the geometric constraints recited in the asserted claims. The precise measurement and definition of the various "surfaces" and "spaces" will be critical. Further, the functional requirement in Claim 1 that the cooling fan "direct the air through the cooking cavity" raises an evidentiary question about the actual airflow path within the Accused Products.

V. Key Claim Terms for Construction

Term: "located vertically below a top surface of the cooking cavity and vertically above a bottom surface of the cooking cavity" (Claim 1)

  • Context and Importance: This phrase defines the core structural innovation enabling the low-profile design—placing fans in the lateral space alongside the cooking cavity, rather than stacked above or below it. The infringement determination will depend heavily on whether the accused fan placement meets this geometric limitation. Practitioners may focus on this term because its interpretation dictates whether a side-mounted fan configuration falls within the claim scope.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes embodiments where fans "may be located on lateral sides of cooking cavity 34" ('819 Patent, col. 8:41-43). Plaintiff may argue the claim language is intended to encompass any such lateral arrangement that falls within the vertical height profile of the cooking cavity itself.
    • Evidence for a Narrower Interpretation: Defendant may point to specific embodiments like FIG. 8 to argue for a more restrictive meaning of "top surface" and "bottom surface." They may also argue that the claim requires the fans to be located within the direct vertical projection of the cavity, not merely offset to the side.

Term: "a component space defined between exterior vertical surfaces of the cooking cavity and vertical surfaces of the external enclosure" (Claim 30)

  • Context and Importance: This term in Claim 30 appears to be an alternative way of defining the lateral regions where the key components are placed. The definition of the "surfaces" that bound this "space" will be dispositive for infringement of this claim.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: Plaintiff may argue this term broadly covers the entire volume inside the external enclosure that is not occupied by the cooking cavity, where components like fans and electronics are housed.
    • Evidence for a Narrower Interpretation: Defendant could argue that "component space" is limited by the specification's examples to only the distinct left and right side volumes where the fans are explicitly placed in figures like FIG. 8 ('819 Patent, col. 8:56-64), potentially excluding other areas within the enclosure.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges Haier induces infringement by "actively encouraging others" to use the Accused Products through "marketing materials, product manuals, and web pages on its website" (Compl. ¶¶21-22).
  • Willful Infringement: Willfulness is alleged based on Haier's purported pre-suit knowledge or willful blindness to the ’819 Patent's existence (Compl. ¶25). The complaint also establishes post-suit knowledge via the filing of the lawsuit itself, alleging that any continued infringement will be willful (Compl. ¶23).

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

  • A core issue will be one of definitional scope: can the specific geometric limitations in the claims, such as the requirement that fans be located "vertically below a top surface of the cooking cavity and vertically above a bottom surface" (Claim 1), be construed to read on the physical architecture of the accused products? The case will likely depend on how the court construes the spatial relationships between the core components.
  • A key evidentiary question will be one of structural mapping: does a factual analysis of the Accused Products' internal layout, as suggested by the complaint's teardown photographs, demonstrate the presence of the "component space" claimed in Claim 30 and the specific relative component positioning required by Claim 1, or is there a material difference in their mechanical design?