DCT

4:24-cv-00137

Spider Grills LLC v. LoCo Crazy Good Cookers Inc

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I. Executive Summary and Procedural Information

  • Case Name: Spider Grills, LLC v. LOCO – Crazy Good Cookers, Inc. d/b/a LoCo Cookers
  • Parties & Counsel:
  • Case Identification: 4:24-cv-00137, M.D. Ga., 10/02/2024
  • Venue Allegations: Venue is alleged to be proper because the Defendant has its principal place of business within the district and has allegedly committed acts of infringement there.
  • Core Dispute: Plaintiff alleges that Defendant’s line of SmartTemp Kettle Grills infringes a patent related to systems for providing bimodal (manual and automated) airflow control for kettle-style charcoal grills.
  • Technical Context: The technology concerns electronic, fan-driven add-on controllers that automate temperature regulation in conventional charcoal kettle grills, a market segment popular with barbecue enthusiasts.
  • Key Procedural History: The complaint states that Plaintiff sent a cease and desist letter to Defendant on May 8, 2024, which included a copy of the patent-in-suit and a claim chart. This pre-suit notice is the basis for the allegation of willful infringement.

Case Timeline

Date Event
2020-11-20 U.S. Patent No. 11,852,346 Priority Date
2021-01-01 Plaintiff Spider Grills launches its "Venom" product
2022-01-01 Defendant LoCo Cookers is founded
2023-12-26 U.S. Patent No. 11,852,346 issues
2024-05-08 Plaintiff sends cease and desist letter to Defendant
2024-10-02 Complaint filed

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

U.S. Patent No. 11,852,346 - System and Method for Bimodal Air Control in a Kettle-Style Grill

The Invention Explained

  • Problem Addressed: The patent's background section describes the difficulty of manually controlling temperature in kettle-style charcoal grills, which requires significant user skill. It also notes that prior art automated "add on" solutions often require permanent modification of the grill or prevent the user from reverting to manual damper control (’346 Patent, col. 1:19-38).
  • The Patented Solution: The invention is a detachable system that mounts to the exterior of a standard kettle grill without requiring modification. It features a "plenum" component that fits over the grill's lower damper holes, an electronic controller, and a fan. This "bimodal" design allows a user to select between manual control (via a manually adjustable intake damper that is mechanically linked to the grill's internal dampers) and automated control (where a fan provides a forced air flow to maintain a set temperature) (’346 Patent, Abstract; col. 4:6-9; Fig. 6).
  • Technical Importance: The described approach provides sophisticated, automated temperature management capabilities to common, unmodified kettle grills while uniquely preserving the user's option to operate the grill in its original, manual configuration (’346 Patent, col. 1:33-38).

Key Claims at a Glance

  • The complaint asserts infringement of claim 1 and reserves the right to assert others (Compl. ¶¶ 16-17).
  • Independent Claim 1 requires:
    • A plenum mated at a top surface to a lower kettle of a kettle-styled charcoal grill, where the plenum surrounds an aperture in the base of the lower kettle.
    • An ash receptacle releasably mated to a bottom surface of the plenum.
    • An air control unit mounted to a side surface of the plenum, configured to supply a forced air flow into the plenum, and comprising a fan and an electronic controller.
    • Wherein the forced air flow is directed through the aperture and into the lower kettle.
    • Wherein ash from the kettle falls gravitationally through the aperture and plenum and is collected by the ash receptacle.

III. The Accused Instrumentality

Product Identification

The accused products are the "22.5" SmartTemp Kettle Grill" and the "22.5" SmartTemp Kettle Grill with Cart," collectively referred to as the "SmartTemp Kettle Grills" (Compl. ¶3).

Functionality and Market Context

The complaint alleges the SmartTemp Kettle Grills incorporate a "thermostatically-controlled fan that supplies air into the grill's plenum to control internal temperature" (Compl. ¶4). Defendant markets this as its "'Fan the Fire' Technology," which is described as a "built-in, thermostatically-controlled fan that blows continuously on the stack of charcoal" and "automatically turns on to fan the fire until the temperature rebounds" (Compl. ¶4). The complaint includes an image of the accused "22.5" SmartTemp Kettle Grill with Cart" (Compl. p. 4, Fig. 6). The products are sold at Home Depot, and the Defendant company was founded in 2022, after the Plaintiff launched its competing product (Compl. ¶3).

IV. Analysis of Infringement Allegations

The complaint states that a "detailed infringement analysis demonstrating how the SmartTemp Kettle Grills practices each and every limitation of claim 1" is provided in Exhibit A (Compl. ¶17). However, this exhibit was not filed with the complaint on the public docket. The narrative infringement theory presented is that the Defendant’s "SmartTemp Kettle Grills" perform the same function as the patented invention by using a "thermostatically-controlled fan" to supply air into a "plenum" to regulate the internal temperature (Compl. ¶4). The complaint relies on Defendant's own marketing descriptions of its "'Fan the Fire' Technology" as evidence that the accused products operate in an infringing manner (Compl. ¶4).

Identified Points of Contention

  • Scope Questions: A primary question may be whether the claims, which describe a detachable, multi-component system "for use with a kettle-styled charcoal grill" (’346 Patent, Claim 1), can be read to cover the accused products, which appear to be integrated grills rather than add-on units. The interpretation of whether an integrated system can have a "plenum mated... to a lower kettle" and an "air control unit mounted to a side surface of the plenum" will be central to the infringement analysis.
  • Technical Questions: The complaint does not provide specific evidence detailing the internal construction of the accused grills. A key technical question will be whether the accused products contain distinct components that correspond to the claimed "plenum," "ash receptacle," and "air control unit," or if their integrated design presents a structural and functional mismatch with the specific claim elements. For example, it is unclear if the accused product’s ash collection system is "releasably mated to a bottom surface of the plenum" as required by the claim (’346 Patent, col. 8:1-3).

V. Key Claim Terms for Construction

The Term: "plenum mated at a top surface to a lower kettle"

  • Context and Importance: Practitioners may focus on this term because the patent repeatedly frames the invention as a detachable unit for an existing grill, whereas the accused product is an integrated grill. The construction of "mated" will be critical to determining if an integrated design infringes a claim written for a modular add-on.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party could argue that the plain meaning of "mated" simply requires that the two components be joined or fitted together, without implying they must be separable.
    • Evidence for a Narrower Interpretation: The specification consistently describes the invention as being "detachably mounted to the exterior of a kettle-styled grill" and enabling a user to "integrate" the system onto an "existing kettle-styled grill without modifying" it (’346 Patent, col. 2:42-43; col. 3:5-8). This context may support a narrower construction that requires two distinct components being brought together, rather than being manufactured as one.

The Term: "air control unit mounted to a side surface of the plenum"

  • Context and Importance: Claim 1 recites an "air control unit" that is "mounted to" the plenum, suggesting two separate components. The infringement analysis will hinge on whether the accused product's control housing is a distinct, "mounted" unit or an inseparable part of the overall grill body.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: "Mounted to" could be construed broadly to mean "attached" or "affixed," potentially covering components that are integrated during manufacturing.
    • Evidence for a Narrower Interpretation: The patent's figures, particularly the exploded view in Figure 2, clearly depict the "air control unit" (housed in 117) and the "damper plenum" (107) as distinct, separable components (’346 Patent, Fig. 2). This could be used to argue that the claim requires two separate structures that are assembled together.

VI. Other Allegations

Willful Infringement

The complaint alleges that Defendant’s infringement has been willful since at least May 8, 2024, the date it received Plaintiff’s cease and desist letter. The letter allegedly provided notice of the ’346 Patent and included a claim chart analyzing the infringement (Compl. ¶¶ 5, 18).

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

  • A core issue will be one of structural scope: can the claims, which describe a modular, detachable system "for use with" a kettle grill, be construed to cover an integrated grill where the control system is a built-in feature? The case may turn on whether the accused product's single-body construction can satisfy the claim limitations of a "plenum mated to" a kettle and an "air control unit mounted to" a plenum.
  • A key evidentiary question will be one of component correspondence: what evidence will emerge in discovery regarding the internal structure of the SmartTemp Kettle Grills? The resolution of the infringement question will depend on whether the accused product contains physically distinct components that map onto the specific elements of Claim 1, or if its architecture is fundamentally different from the multi-part system claimed in the patent.