DCT

4:25-cv-00074

North Atlantic Imports LLC v. LoCo Crazy Good Cookers Inc

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:25-cv-00074, M.D. Ga., 02/26/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant resides in the district, has committed alleged acts of infringement in the district, and maintains a regular and established place of business in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s outdoor propane griddles infringe a patent related to a locking mechanism that secures a griddle cooktop to its main body.
  • Technical Context: The technology concerns safety and stability features for portable outdoor cooking stations, a market segment characterized by competition over convenience and design features.
  • Key Procedural History: The complaint alleges that Plaintiff sent Defendant a letter on February 13, 2025, providing notice of the alleged infringement of the patent-in-suit. The patent issued approximately 13 months prior to the complaint's filing date.

Case Timeline

Date Event
2020-02-11 '693 Patent Priority Date
2022 LoCo Enters Outdoor Cooking Market
2024-01-23 '693 Patent Issue Date
2025-02-13 Blackstone Sends LoCo Notice Letter
2025-02-26 Complaint Filing Date

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

U.S. Patent No. 11,877,693 - "Griddle Cooking Station and Method Thereof," issued January 23, 2024

The Invention Explained

  • Problem Addressed: The patent describes a problem with conventional outdoor griddles, which are often not secured to their underlying cooking stations. This lack of security is described as problematic for portability and safety, particularly when a hood is attached to the griddle, as forces on the hood (e.g., from wind) could dislodge the entire hot griddle top (’693 Patent, col. 1:43-58).
  • The Patented Solution: The invention provides a system to "removably secure" the griddle to the main body of the cooking station. This is achieved through specially designed legs on the underside of the griddle that engage with a "locking structure," such as corresponding apertures, on the main body (’693 Patent, Abstract; col. 2:1-11). This engagement is designed to "minimize movement of the griddle relative to the main body" by preventing both upward and horizontal motion (’693 Patent, col. 13:19-33).
  • Technical Importance: The described solution aims to enhance the safety and stability of portable outdoor griddles by creating an integrated, yet still separable, cooking unit.

Key Claims at a Glance

  • The complaint asserts infringement of at least independent claim 1 (Compl. ¶23).
  • The essential elements of independent claim 1 are:
    • A main body with heating elements and a "locking structure."
    • A griddle with downward-extending legs, where at least one leg has a "neck and an abutment structure."
    • The abutment structure is configured to "cooperate with the locking structure" to "minimize movement" of the griddle.
    • A hood pivotably coupled to the griddle's splash guard.
  • The complaint implicitly reserves the right to assert other claims by alleging infringement of "at least claim 1" (Compl. ¶23).

III. The Accused Instrumentality

Product Identification

  • The accused products are a line of LoCo-branded propane griddles, including the "36" 3-Burner Classic SmartTemp Griddle," "36" 3-Burner Digital Series II SmartTemp Griddle," "26" 2-Burner SmartTemp Griddle," and "26" 2-Burner Digital Series II SmartTemp Griddle," as well as similar products (collectively, the "Accused Products") (Compl. ¶15).

Functionality and Market Context

  • The complaint alleges the Accused Products are "outdoor cooking stations" that are direct competitors to Blackstone’s own products and are sold through the same retail channels (Compl. ¶15, ¶22). The complaint describes the functionality of the Accused Products by directly tracking the language of asserted claim 1, alleging they possess a main body, a griddle with legs, and a hood with the specific structural and cooperative features recited in the patent (Compl. ¶24).

IV. Analysis of Infringement Allegations

The complaint alleges that the Accused Products contain each element of claim 1 of the ’693 Patent (Compl. ¶23-24). No probative visual evidence provided in complaint.

’693 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a main body extending to define a front side, a rear side, a left side and a right side...the upper portion of the main body including a locking structure positioned therealong; The Accused Products are outdoor cooking stations comprising a main body that includes multiple heating elements and a locking structure. ¶24 col. 7:35-46
a griddle configured to be supported by the upper portion of the main body...the underside including legs extending...downward from the underside of the griddle, The Accused Products include a griddle supported by the main body, with an upper side including a splash guard and an underside including legs. ¶24 col. 9:3-25
at least one of the legs defining a neck and an abutment structure along the length of the legs, At least one of the legs on the Accused Products' griddle defines a neck and an abutment structure. ¶24 col. 11:18-39
the abutment structure configured to cooperate with the locking structure so as to minimize movement of the griddle relative to the main body; The abutment structure on the Accused Products' griddle leg cooperates with the main body's locking structure to minimize movement. ¶24 col. 13:19-33
and a hood pivotably coupled to the splash guard of the griddle, the hood configured to be moveable between a closed position and an open position. The Accused Products include a hood pivotably coupled to the splash guard of the griddle. ¶24 col. 7:22-29

Identified Points of Contention

  • Structural Questions: The complaint alleges infringement by reciting the claim language but does not provide technical details or visual evidence of how the Accused Products are constructed (Compl. ¶24). A central question will be whether the legs of the LoCo griddles actually feature the specific "neck and an abutment structure" described in the patent, and whether the LoCo main body has a corresponding "locking structure" that cooperates in the claimed manner.
  • Scope Questions: The dispute may turn on the scope of the claim terms. For example, the parties may dispute whether the features on the LoCo griddles, even if different from the patent's specific embodiments, fall within the meaning of a "locking structure" and an "abutment structure" as recited in the claim.

V. Key Claim Terms for Construction

The Term: "locking structure"

  • Context and Importance: This term is the lynchpin of the claim, defining the feature on the main body that secures the griddle. Its construction will determine the breadth of the patent's protection and is central to the infringement analysis.
  • Evidence for a Broader Interpretation: The claim language itself is general, reciting "a locking structure positioned therealong" without specifying its form (e.g., aperture, bracket, or other mechanism) (’693 Patent, col. 17:8-9).
  • Evidence for a Narrower Interpretation: The specification heavily features an embodiment where the locking structure is formed by "elongated apertures" that define a "keyed structure" configured to receive the griddle legs (’693 Patent, col. 2:15-21; col. 4:39-43). A defendant may argue the term should be limited to this disclosed keyed-aperture embodiment or a structural equivalent.

The Term: "abutment structure"

  • Context and Importance: This is the corresponding feature on the griddle leg that interacts with the "locking structure". Infringement requires the presence and cooperation of both. Practitioners may focus on this term because its definition is tied to a specific geometry shown in the patent.
  • Evidence for a Broader Interpretation: The claim requires only that the structure be "along the length of the legs" and be "configured to cooperate with the locking structure" (’693 Patent, col. 17:15-18).
  • Evidence for a Narrower Interpretation: The patent's detailed description and Figure 5 illustrate a very specific multi-part leg geometry comprising a "base" (138), a "head" (140), and a narrower "neck" (142) in between, where the "abutment" (148) is the surface of the head that overhangs the neck (’693 Patent, col. 11:18-39). The term could be construed to require this specific stepped-diameter configuration.

VI. Other Allegations

  • Indirect Infringement: The complaint asserts inducement and contributory infringement in a conclusory manner (Compl. ¶25). It does not allege specific facts to support these claims, such as references to Defendant's user manuals, advertising, or other materials that might instruct or encourage infringing use.
  • Willful Infringement: The willfulness allegation is based on LoCo’s alleged continued infringement after receiving a notice letter from Blackstone on February 13, 2025 (Compl. ¶16-17, ¶25). This letter establishes a date for actual knowledge, which may support a finding of willful infringement for any infringing conduct occurring after that date.

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

  • A core issue will be one of structural correspondence: Do the accused LoCo griddles physically embody the specific two-part locking system claimed in the patent? The case will likely require a detailed factual comparison between the "neck and an abutment structure" on the griddle legs and the corresponding "locking structure" on the main body as claimed, versus the actual components of the accused products.
  • A second key issue will be one of claim scope: How will the court construe the term "locking structure"? The outcome of the case may depend on whether this term is interpreted broadly to cover any feature that secures a griddle, or narrowly limited to the "keyed aperture" embodiment that is prominently described and illustrated in the patent specification.
  • A final question will be evidentiary for willfulness: Given that the patent is relatively new, a key question for the willfulness claim will be what evidence, beyond the February 2025 notice letter, can be presented to show that LoCo's alleged conduct was "knowing" or "willful."