DCT

1:23-cv-11277

SharkNinja Operating LLC v. Dyson Inc

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:23-cv-11277, D. Mass., 09/19/2023
  • Venue Allegations: Plaintiffs allege venue is proper in the District of Massachusetts because Defendant Dyson maintains a regular and established place of business in the district (a Dyson Service Center), has committed acts of infringement through substantial sales in the district, and directed communications accusing SharkNinja of infringement to its headquarters in the district.
  • Core Dispute: Plaintiffs allege that various models of Defendant's cordless stick vacuum cleaners infringe eight patents related to vacuum cleaner configuration and technology, and separately seek a declaratory judgment that their hair styling product does not infringe one of Defendant's patents.
  • Technical Context: The dispute centers on the highly competitive market for premium cordless vacuum cleaners and hair styling appliances, where innovations in power, efficiency, and user convenience are key market differentiators.
  • Key Procedural History: The complaint notes that Defendant Dyson has counterclaimed for infringement of its U.S. Patent No. 11,044,979. It also details ongoing litigation initiated by Dyson in Germany and France concerning foreign counterparts to the '979 patent, suggesting an escalating global dispute over the hair styling technology.

Case Timeline

Date Event
2007-12-10 Priority Date for ’666 Patent
2009-03-11 Priority Date for ’407 Patent
2011-03-03 Priority Date for ’472 Patent
2013-12-17 ’407 Patent Issued
2015-08-10 Priority Date for ’550 Patent
2015-10-05 Priority Date for ’607 Patent
2016-01-01 Dyson Accused Products available "since at least 2016"
2016-04-05 ’666 Patent Issued
2016-04-11 Priority Date for ’477 Patent
2016-10-05 Priority Date for ’030 Patent
2018-03-30 Dyson promotes V10 "hygienic bin emptying"
2018-09-25 ’472 Patent Issued
2018-10-10 Priority Date for ’038 Patent
2018-11-06 ’550 Patent Issued
2019-06-25 ’607 Patent Issued
2019-11-19 ’030 Patent Issued
2020-02-25 ’477 Patent Issued
2022-07-19 ’038 Patent Issued
2022-09-06 SharkNinja FlexStyle™ formal launch date
2023-09-19 Second Amended Complaint Filed

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

U.S. Patent No. 8,607,407 - "Configuration of a hand vacuum cleaner"

  • Patent Identification: U.S. Patent No. 8,607,407, "Configuration of a hand vacuum cleaner," issued December 17, 2013.

The Invention Explained

  • Problem Addressed: The patent does not explicitly state a problem in its background, but the invention is directed at the overall physical arrangement of a hand vacuum cleaner's components. (Compl. ¶62). The complaint suggests the problem is messy dirt disposal from conventional vacuums. (Compl. ¶45).
  • The Patented Solution: The patent describes a hand vacuum cleaner where the dirt collection chamber has an openable door located at the front of the unit. (Compl. ¶62). This configuration is presented as advantageous because "when the vacuum cleaner is inclined or inverted to empty... no portion of the vacuum cleaner need be in front of the door," which prevents "the dirt leaving the vacuum cleaner" from contaminating the appliance itself when emptied into a garbage can. (’407 Patent, 1:50-62; Compl. ¶45).
  • Technical Importance: This design addresses a common consumer annoyance with bagless vacuums—the dust and debris created during emptying—by enabling a more direct and cleaner path from the dirt bin to a trash receptacle. (Compl. ¶45).

Key Claims at a Glance

  • The complaint asserts at least independent claim 24. (Compl. ¶65).
  • The essential elements of claim 24 include:
    • A hand vacuum cleaner with a front end, a rear end, and an air flow passage.
    • A first cyclone unit in the air flow path, comprising at least one cyclone and at least one dirt collection chamber.
    • The dirt collection chamber having an openable door positioned at the front end of the vacuum cleaner.
    • A suction motor positioned in the air flow passage.
    • The door being openable when mounted to the hand vacuum cleaner.

U.S. Patent No. 9,301,666 - "Surface cleaning apparatus"

  • Patent Identification: U.S. Patent No. 9,301,666, "Surface cleaning apparatus," issued April 5, 2016.

The Invention Explained

  • Problem Addressed: The patent addresses various configurations for surface cleaning apparatuses, including the popular "stick vacuum" format which combines the portability of a handheld unit with the extended reach of an upright cleaner. (’666 Patent, Abstract).
  • The Patented Solution: The invention describes a surface cleaning apparatus comprising a hand vacuum cleaner with a cyclonic cleaning stage, a wand mounted to the dirty fluid inlet of the hand unit, and a surface cleaning head mounted to the distal end of the wand. (Compl. ¶74; ’666 Patent, Abstract). This architecture defines a common convertible stick vacuum design.
  • Technical Importance: This modular configuration allows a single device to function as both a handheld vacuum for spot cleaning and a stick vacuum for floor cleaning, offering improved convenience and versatility over single-purpose appliances. (Compl. ¶39).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1. (Compl. ¶77).
  • The essential elements of claim 1 include:
    • A surface cleaning apparatus comprising a hand vacuum cleaner, a wand, and a surface cleaning head.
    • The hand vacuum cleaner has a dirty fluid inlet and a cyclonic cleaning stage.
    • The wand is mounted to the dirty fluid inlet of the hand vacuum cleaner.
    • The wand has a distal inlet mounted on the surface cleaning head.

Multi-Patent Capsules

  • Patent Identification: U.S. Patent No. 10,080,472, "Hand carriable surface cleaning apparatus," issued September 25, 2018.

  • Technology Synopsis: The patent is directed to a hand vacuum cleaner with an airflow passage extending from a dirty air inlet to a clean air outlet. A suction motor and at least one air treatment member (e.g., a cyclone) are positioned in the airflow path. (Compl. ¶85).

  • Asserted Claims: At least claim 1. (Compl. ¶88).

  • Accused Features: The Dyson V8™ line of cordless vacuums. (Compl. ¶86).

  • Patent Identification: U.S. Patent No. 10,117,550, "Surface cleaning apparatus," issued November 6, 2018.

  • Technology Synopsis: The patent describes a hand vacuum cleaner with a cyclone unit having an electrical connector at its front end, adjacent to the air inlet. Electrical cables extend rearwardly from this connector through a central portion of the cyclone unit toward the motor. (Compl. ¶97). The complaint links this to Dyson's "inline" design, which allegedly enhances airflow efficiency. (Compl. ¶44).

  • Asserted Claims: At least claim 28. (Compl. ¶100).

  • Accused Features: The Dyson Cyclone V10™, V11™, Outsize™, V12™, V15 Detect™, V15s Detect Submarine™, and Gen5™ lines. (Compl. ¶98).

  • Patent Identification: U.S. Patent No. 10,327,607, "Surface cleaning apparatus," issued June 25, 2019.

  • Technology Synopsis: The patent is directed to a hand-carriable surface cleaning apparatus that includes a cyclonic cleaning stage defined by an upper end, a bottom end spaced longitudinally below, and a side wall extending between them. (Compl. ¶109).

  • Asserted Claims: At least claim 1. (Compl. ¶112).

  • Accused Features: The Dyson V8™ line of cordless vacuums. (Compl. ¶110).

  • Patent Identification: U.S. Patent No. 10,478,030, "Surface cleaning apparatus," issued November 19, 2019.

  • Technology Synopsis: The patent describes an apparatus with a hand vacuum, a cleaning head, and a rigid wand. The hand vacuum's air inlet is centrally positioned on the front end of an air treatment member and is releasably connectable to the wand's air outlet. (Compl. ¶121).

  • Asserted Claims: At least claim 9. (Compl. ¶124).

  • Accused Features: The Dyson Cyclone V10™, V11™, Omni-glide™, Outsize™, V12™, V15 Detect™, V15s Detect Submarine™, Gen5™, and Humdinger™ lines. (Compl. ¶122).

  • Patent Identification: U.S. Patent No. 10,568,477, "Surface cleaning apparatus," issued February 25, 2020.

  • Technology Synopsis: The patent claims a surface cleaning apparatus with a dirt collection region that has an openable door. A key feature is that when an accessory is connected to the dirty air inlet, the openable door is inhibited from opening. (Compl. ¶133).

  • Asserted Claims: At least claim 14. (Compl. ¶136).

  • Accused Features: The Dyson Cyclone V10™, V11™, Omni-glide™, Outsize™, V12™, V15 Detect™, V15s Detect Submarine™, Gen5™, and Humdinger™ lines. (Compl. ¶134).

  • Patent Identification: U.S. Patent No. 11,389,038, "Surface cleaning apparatus," issued July 19, 2022.

  • Technology Synopsis: The patent is directed to an apparatus with a hand vacuum cleaner, cleaning head, and rigid air conduit. The hand vacuum component houses dual cyclonic cleaning stages along with a suction motor and fan assembly. (Compl. ¶145).

  • Asserted Claims: At least claim 1. (Compl. ¶148).

  • Accused Features: The Dyson Cyclone V10™, V11™, Outsize™, V12™, V15 Detect™, V15s Detect Submarine™, and Gen5™ lines. (Compl. ¶146).

III. The Accused Instrumentality

Product Identification

The accused products are numerous lines of Dyson cordless vacuum cleaners, including the Dyson V8™, Cyclone V10™, V11™, Omni-glide™, Outsize™, V12™, V15 Detect™, V15s Detect Submarine™, Gen5™, and Humdinger™ lines. (Compl. ¶41).

Functionality and Market Context

The complaint focuses on two key functionalities promoted by Dyson that allegedly practice the asserted patents. First is the "inline, horizontal configuration" of the cyclone and motor, introduced with the Cyclone V10™ line, which Dyson's founder touted as "quite important" because it "saves on air flow" by allowing air to pass "straight clean through the machine" without turning corners that create inefficiency. (Compl. ¶42). A screenshot from a Dyson launch event shows James Dyson highlighting this feature. (Compl. p. 18). Second is the "hygienic bin emptying" mechanism, also promoted for the V10™ line, which allows the user to empty the dirt bin with a forward-facing door. (Compl. ¶43). A promotional video screenshot shows this bin-emptying process. (Compl. p. 18). Plaintiffs allege these features were developed and patented by Omachron and SharkNinja years prior to Dyson's implementation. (Compl. ¶42, 44-45).

IV. Analysis of Infringement Allegations

The complaint references claim-chart exhibits that are not provided; the following is a prose summary of the narrative infringement theories.

’407 Patent Infringement Allegations

The complaint alleges that the '407 Accused Products (Dyson V10 line and subsequent models) infringe at least claim 24 of the ’407 Patent. (Compl. ¶63, 65). The infringement theory centers on the vacuum's configuration, specifically the inclusion of a dirt collection chamber with an "openable door positioned at the front end." (Compl. ¶62). Plaintiffs allege that Dyson's marketing of its V10 line, which heavily promoted a new "hygienic bin emptying" mechanism, demonstrates the adoption of this patented front-emptying design, which Plaintiffs claim to have contemplated and described years earlier to enable cleaner disposal of debris. (Compl. ¶43, 45).

  • Identified Points of Contention: The dispute may turn on the construction of "front end of the vacuum cleaner." The parties may contest whether the specific location and operation of the emptying mechanism on the accused Dyson products correspond to the claimed "front end." A technical question will be whether the internal structure of the accused products, including the relationship between the cyclone and the dirt collection chamber, meets the specific elements of claim 24.

’666 Patent Infringement Allegations

The complaint alleges that the '666 Accused Products (Dyson V8 line) infringe at least claim 1 of the ’666 Patent. (Compl. ¶75, 77). The infringement theory is based on the overall "stick vacuum" architecture. The patent claims a combination of a hand vacuum cleaner with a cyclonic stage, a wand "mounted to the dirty fluid inlet" of the hand unit, and a surface cleaning head at the opposite end of the wand. (Compl. ¶74). The complaint alleges that the Dyson V8 line embodies this specific, claimed arrangement of components. (Compl. ¶75, 77).

  • Identified Points of Contention: A likely scope question is the meaning of "wand mounted to the dirty fluid inlet of the hand vacuum cleaner." The analysis will likely focus on the precise nature of the physical and fluidic connection between the wand and the handheld unit in the accused V8 products. A technical question may be whether the specific port on the accused products where the wand connects qualifies as the "dirty fluid inlet of the hand vacuum cleaner" as that term is used in the patent.

V. Key Claim Terms for Construction

"an openable door positioned at the front end of the vacuum cleaner" (’407 Patent, Claim 24)

  • Context and Importance: The location and functionality of this door are central to the ’407 Patent's asserted novelty and the infringement claim against Dyson's "hygienic bin emptying" feature. Practitioners may focus on this term because its construction will determine whether Dyson's forward-emptying mechanism falls within the claim scope.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification's emphasis on the functional benefit—emptying debris "into a garbage can" without having it "contact any portion of the vacuum cleaner"—may support an interpretation where any forward-facing door that achieves this functional goal could be considered at the "front end." (’407 Patent, 1:50-62).
    • Evidence for a Narrower Interpretation: The figures in the ’407 Patent (e.g., Fig. 1) depict a specific physical arrangement where the door forms the absolute forward-most surface of the device. This could support a narrower construction requiring the door to be the leading physical surface of the vacuum cleaner during operation, not just during emptying.

"a wand mounted to the dirty fluid inlet of the hand vacuum cleaner" (’666 Patent, Claim 1)

  • Context and Importance: This phrase defines the fundamental connection in the claimed "stick vac" configuration. The infringement analysis for the ’666 Patent depends entirely on whether the connection between the wand and the handheld unit in the accused Dyson V8 products satisfies this limitation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term "mounted to" is general and could be construed broadly to mean any form of physical and fluidic attachment, whether permanent or releasable. The specification describes various configurations, suggesting the term is not limited to one specific type of connection.
    • Evidence for a Narrower Interpretation: The patent's figures (e.g., Fig. 1a) illustrate a specific geometry where the wand connects directly to an inlet port that is integral to the main cyclonic body of the handheld unit. This could support a narrower interpretation requiring a direct connection to the primary cyclonic intake, potentially excluding designs where the wand connects to an intermediate component.

VI. Other Allegations

Indirect Infringement

The complaint alleges inducement of infringement, stating that Dyson's website, advertisements, and user manuals instruct customers to use the accused vacuums in a manner that infringes the asserted claims. (Compl. ¶68, 79). It further alleges contributory infringement through Dyson's sale of spare and replacement parts, such as cleaner heads, bins, and wands, which are alleged to be material components especially made for the infringing systems with no substantial non-infringing uses. (Compl. ¶69, 80).

Willful Infringement

Willfulness is alleged based on pre-suit knowledge of the asserted patents. The complaint claims Dyson had actual knowledge because it cited several of the asserted patents (e.g., the '407, '472, '550, '607, and '030 patents) during the prosecution of its own patent applications before the USPTO and foreign patent offices. (Compl. ¶67, 90, 102, 114, 126).

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

  • A central issue will be one of technical origin and scope: Plaintiffs allege that Dyson's "inline" vacuum architecture and "hygienic bin emptying" mechanism, heavily marketed as Dyson innovations, were in fact patented by Plaintiffs years earlier. The case will likely examine whether the specific technical implementations in Dyson's products fall within the scope of the asserted patent claims, or if they represent a parallel, non-infringing design path.
  • A key evidentiary question will concern knowledge and intent: The complaint's allegations of willfulness are supported by claims that Dyson cited several of the asserted patents during the prosecution of its own patent portfolio. This raises a critical question for the court regarding the extent of Dyson’s pre-suit knowledge and whether its continued sale of the accused products constitutes willful infringement.
  • The dispute will also involve a question of structural correspondence: Many of the asserted claims recite specific physical arrangements and connections between components, such as a wand "mounted to the dirty fluid inlet" or an accessory that "inhibits" a door from opening. The outcome may depend on a detailed comparison of the accused products' mechanical structures and functionalities against the precise language of the claims.