DCT
1:25-cv-12447
Shenzhen Salilan Technology Co Ltd v. SharkNinja Operating LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Shenzhen SaLilan Technology Co., Ltd., Shenzhen FanXingWang Trading Co., Ltd., and Shenzhen XiWei Technology Co., Ltd. (People's Republic of China)
- Defendant: SharkNinja Operating LLC (Delaware / Massachusetts)
- Plaintiff’s Counsel: Pierce & Mandell, P.C.
- Case Identification: 1:25-cv-12447, D. Mass., 09/03/2025
- Venue Allegations: Venue is based on Defendant SharkNinja having its headquarters and a regular and established place of business in Needham, Massachusetts, which is within the district.
- Core Dispute: Plaintiffs seek a declaratory judgment that their "Slushie Machines" do not infringe Defendant’s patent related to internal baffle structures in mixing vessels for frozen drink makers.
- Technical Context: The technology concerns mechanical improvements to consumer-grade frozen beverage machines, specifically the use of internal baffles to manage slush flow and prevent blockages in compact designs.
- Key Procedural History: The complaint states that this action follows a "marketplace enforcement campaign" by Defendant, including takedown complaints to Amazon targeting products similar to Plaintiffs'. It also notes that other sellers have filed similar declaratory judgment actions against Defendant concerning the same patent.
Case Timeline
| Date | Event |
|---|---|
| 2024-01-18 | ’629 Patent Priority Date |
| 2024-07-15 | ’629 Patent assignment executed |
| 2024-08-07 | ’629 Patent assignment recorded |
| 2025-04-22 | ’629 Patent Issue Date |
| 2025-05-19 | Related declaratory judgment action (Foshan DJ Action) filed |
| 2025-06-03 | Related declaratory judgment action (TaoYiAn DJ Action) filed |
| 2025-08-25 | Plaintiffs sent email to Defendant to resolve dispute |
| 2025-08-27 | Plaintiffs sent follow-up email to Defendant |
| 2025-09-03 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,279,629 - “Mixing vessel baffles for a drink maker”
- Patent Identification: U.S. Patent No. 12,279,629, titled “Mixing vessel baffles for a drink maker,” issued on April 22, 2025 (the "’629 Patent").
The Invention Explained
- Problem Addressed: The patent describes a problem in existing frozen drink makers, particularly household models, where the rotating dasher causes slush to migrate up the vessel’s sidewalls and stick to the top of the chamber. This is exacerbated in compact household units that "cannot rely on a tall chamber height to control slush flow," leading to poor circulation, inefficient cooling, and product waste (ʼ629 Patent, col. 4:51-62).
- The Patented Solution: The invention is a mixing vessel that incorporates one or more internal baffles—specifically a side baffle, a front baffle, and a corner baffle—that work together to direct the flow of slush. These structures are designed to redirect contents away from the top of the vessel, thereby optimizing mixing, preventing blockages, and improving dispensing performance within a compact form factor (ʼ629 Patent, Abstract; col. 5:1-17).
- Technical Importance: The claimed configuration of baffles provides a method for managing slush in smaller, household-sized appliances that lack the large vertical headspace common in commercial machines (ʼ629 Patent, col. 4:57-62).
Key Claims at a Glance
- The complaint seeks a declaratory judgment of non-infringement of independent claims 1, 13, and 20 (Compl. ¶26).
- Independent Claim 1: A mixing vessel comprising:
- a curved sidewall defining a vessel chamber
- a corner baffle positioned at the front and the top of the vessel chamber, configured to direct slush flow
- a front baffle positioned at the front of the vessel chamber extending across the top
- Independent Claim 13: A mixing vessel comprising:
- a curved sidewall defining a vessel chamber
- a corner baffle positioned at the front and the top of the vessel chamber
- a side baffle extending laterally along the vessel chamber from the front toward the rear
- a front baffle positioned at the front of the vessel chamber extending across the top
- Independent Claim 20: A frozen drink maker comprising:
- a mixing vessel with a curved sidewall
- a housing abutting the rear of the mixing vessel
- a dasher arranged to rotate within the mixing vessel
- a dispenser assembly at the front
- wherein the mixing vessel comprises at least two internal baffles, including a front baffle extending across the top
- The complaint also states that Plaintiffs do not infringe claims that depend on these independent claims (Compl. ¶¶28, 30, 32).
III. The Accused Instrumentality
Product Identification
- The accused products are identified as "Slushie Machines" sold by the three Plaintiffs on Amazon under various storefronts and ASIN numbers (Compl. ¶¶1, 21-23).
Functionality and Market Context
- The complaint describes the Slushie Machines as frozen drink makers and provides external product images. An external product image of an exemplary SaLiLan Slushie Machine is provided in the complaint (Compl. p. 6, Illustration 1). The complaint does not describe the internal mechanics of the accused products; instead, its allegations are premised on the absence of certain features (Compl. ¶¶28, 30, 32). The products are alleged to be the subject of Defendant's marketplace enforcement and takedown efforts on Amazon (Compl. ¶4).
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement. Its allegations focus on claim elements that it asserts are absent from the accused Slushie Machines.
’629 Patent Infringement Allegations (Claim 1)
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality / Missing Element | Complaint Citation | Patent Citation |
|---|---|---|---|
| a curved sidewall defining a vessel chamber therein, wherein the vessel chamber includes a front, a rear, a right side, a left side, and a top | The complaint does not specifically contest this element. | col. 2:1-4 | |
| a corner baffle positioned at the front and the top of the vessel chamber on either the right side or the left side, wherein the corner baffle is configured to direct slush flow within the vessel chamber | The complaint alleges the Slushie Machines lack this corner baffle limitation. | ¶28 | col. 2:4-7 |
| a front baffle positioned at the front of the vessel chamber extending from the left side toward the right side across the top | The complaint alleges the Slushie Machines lack this front baffle limitation. | ¶28 | col. 2:31-33 |
’629 Patent Infringement Allegations (Claim 13)
| Claim Element (from Independent Claim 13) | Alleged Non-Infringing Functionality / Missing Element | Complaint Citation | Patent Citation |
|---|---|---|---|
| a curved sidewall defining a vessel chamber therein, wherein the vessel chamber includes a front, a rear, a right side, a left side, and a top | The complaint does not specifically contest this element. | col. 2:45-48 | |
| a corner baffle positioned at the front and the top of the vessel chamber on either the right side or the left side | The complaint alleges the Slushie Machines lack this corner baffle limitation. | ¶30 | col. 2:49-51 |
| a side baffle extending laterally along the vessel chamber from the front toward the rear | The complaint alleges the Slushie Machines lack this side baffle limitation. | ¶30 | col. 2:49-51 |
| a front baffle positioned at the front of the vessel chamber extending from the left side toward the right side across the top | The complaint alleges the Slushie Machines lack this front baffle limitation. | ¶30 | col. 2:53-55 |
Identified Points of Contention
- Factual Questions: The central dispute appears to be factual: do the accused Slushie Machines physically contain the structures recited in the claims? The complaint makes conclusory allegations of absence without providing technical evidence, such as diagrams or internal photographs of the accused products. The resolution will depend on evidence produced during discovery regarding the internal design of the Slushie Machines.
- Scope Questions: Should discovery reveal any internal protrusions or ribs inside the accused products, the dispute may shift to claim construction. A key question will be whether the definitions of "corner baffle," "side baffle," and "front baffle" are broad enough to read on those structures, or if the terms are limited to the specific shapes and arrangements disclosed in the ’629 Patent's specification and figures.
V. Key Claim Terms for Construction
The Term: "corner baffle"
- Context and Importance: This term appears in independent claims 1 and 13 and is a primary basis for Plaintiffs' non-infringement allegations (Compl. ¶¶28, 30). The construction of this term will be critical in determining whether any structure in the accused products meets this limitation, even if not explicitly labeled a "baffle."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent suggests a baffle may be a simple structure, such as a "rib" (ʼ629 Patent, col. 4:65). Claim 1 includes the functional limitation "configured to direct slush flow," which could be used to argue that any structure performing this function in the claimed location constitutes a "corner baffle."
- Evidence for a Narrower Interpretation: The specification and figures depict the corner baffle (109) as a distinct element with a "curved surface" (155) that physically "joins or connects the side baffle 105 and the front baffle 107" (ʼ629 Patent, col. 14:9-14; Fig. 6A). This may support an argument that the term requires a structure that connects two other specific baffles, rather than being a standalone feature.
The Term: "front baffle"
- Context and Importance: This term is recited in all three asserted independent claims (1, 13, and 20) and is another core element that Plaintiffs allege is missing from their products (Compl. ¶¶28, 30, 32). Its definition is therefore fundamental to the non-infringement analysis for all asserted claims.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language primarily defines the "front baffle" by its location: "positioned at the front of the vessel chamber extending from the left side toward the right side across the top" (ʼ629 Patent, cl. 1). An argument could be made that any structure meeting this positional description infringes.
- Evidence for a Narrower Interpretation: The detailed description teaches that the front baffle (107) "may form an angle relative the front face of the vessel chamber (e.g., 100°-150°)" that "redirects vessel contents" toward the rear (ʼ629 Patent, col. 13:54-59). The figures show a distinct, angled, shelf-like structure. This could support a narrower construction requiring these specific angular and functional characteristics.
VI. Other Allegations
- Indirect Infringement: The complaint seeks a declaratory judgment that Plaintiffs do not infringe, either "directly or indirectly" (Compl. ¶26). However, the complaint does not present any specific facts related to the elements of indirect infringement (e.g., knowledge or intent) beyond a general denial of liability.
VII. Analyst’s Conclusion: Key Questions for the Case
This declaratory judgment action appears to be poised to turn on two central questions, one factual and one legal, which will define the course of the litigation.
- A primary issue will be one of evidentiary proof: What is the actual internal construction of the Plaintiffs' Slushie Machines? As the complaint provides only external images, the case will depend heavily on discovery to determine whether the accused products contain any physical structures that could correspond to the claimed "corner baffle," "side baffle," and "front baffle" limitations.
- A subsequent, and potentially dispositive, issue will be one of definitional scope: How will the court construe the key baffle terms? The case may turn on whether these terms are interpreted broadly to cover any internal rib or protrusion serving a general slush-directing function, or narrowly to require the specific, interconnected three-part baffle system illustrated in the patent’s preferred embodiments.