DCT
1:25-cv-13624
SharkNinja Operating LLC v. Shenzhen Jinchannel Innovation Technology Co Ltd
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: SharkNinja Operating LLC and SharkNinja Sales Company (Delaware/Massachusetts)
- Defendant: Shenzhen JinChannel Innovation Technology Co., Ltd. and Zhongshan Aouball Electric Appliances Co., Ltd. (China)
- Plaintiff’s Counsel: Shook, Hardy & Bacon L.L.P.
- Case Identification: 1:25-cv-13624, D. Mass., 12/01/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendants have committed acts of infringement and transact business in the district through interactive e-commerce storefronts accessible to Massachusetts consumers. As foreign entities, Defendants may be sued in any judicial district.
- Core Dispute: Plaintiff alleges that Defendants’ portable air fryer products infringe a design patent covering an ornamental design for an air fryer adapter.
- Technical Context: The dispute concerns the ornamental design of components for portable air fryers, a popular category of countertop kitchen appliances.
- Key Procedural History: The complaint alleges that Plaintiff provided constructive notice of the patent-in-suit via a public patent-marking webpage, a fact that may become relevant to the timeline for damages and any potential claims of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2024-09-04 | ’481 Patent Application Filing Date |
| 2024-09-26 | Plaintiff's Ninja CRISPi Product Launch Date |
| 2025-11-11 | ’481 Patent Issue Date |
| 2025-11-12 | Alleged Constructive Notice of ’481 Patent via Patent Marking |
| 2025-12-01 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. D1,101,481 - "Air Fryer Adapter"
- Patent Identification: U.S. Patent No. D1,101,481, titled "Air Fryer Adapter," issued November 11, 2025 (’481 Patent).
The Invention Explained
- Problem Addressed: Design patents protect the ornamental appearance of an article of manufacture rather than a functional solution to a technical problem. The context provided by the complaint suggests an effort to create a unique and aesthetically distinct design for a component of its novel portable air fryer system (Compl. ¶14, ¶19).
- The Patented Solution: The patent claims the specific ornamental design for an air fryer adapter, as depicted in its eight figures ('481 Patent, Claim). The design consists of the visual characteristics of the adapter, which include a generally square body with rounded corners, two opposing raised handle structures, a contoured base with four distinct feet, and a raised inner rim for seating the air fryer pod ('481 Patent, Figs. 1-8). The complaint alleges this adapter is a key component of its Ninja CRISPi product, which separates a removable heating pod from a glass cooking container (Compl. ¶14).
- Technical Importance: Plaintiff alleges the adapter design "contributes to the success of the Ninja CRISPi" and "enables its portable, safe air-frying functionality for use on multiple different sized cooking containers" (Compl. ¶21).
Key Claims at a Glance
- The patent asserts a single claim for "The ornamental design for an air fryer adapter, as shown and described" ('481 Patent, Claim). This claim incorporates by reference the visual design embodied in the patent's figures.
- The core ornamental features depicted in the patent's solid-line drawings include:
- The overall configuration and three-dimensional shape of the adapter.
- A generally square frame with rounded corners.
- Two opposing, raised handle structures integrated into the frame.
- A contoured base structure with four distinct feet.
- A raised inner lip and recessed central area.
III. The Accused Instrumentality
Product Identification
- The accused products are the "Arecovas Portable Glass Air Fryer" and the "Arecovas 4-in-1" (collectively, "Accused Products") (Compl. ¶33, ¶34). The complaint identifies Defendant Aouball as the manufacturer and Defendant JinChannel as the U.S. distributor of "Arecovas-branded" products sold through online marketplaces like Amazon.com (Compl. ¶25, ¶27).
Functionality and Market Context
- Based on images in the complaint, the Accused Products appear to operate similarly to the Plaintiff's Ninja CRISPi, utilizing a top-down heating unit that sits on a glass cooking vessel (Compl. ¶34). An image from an online product listing shows the "Arecovas 4-in-1" includes a size adapter component that Plaintiff alleges is "strikingly similar in design to the Ninja CRISPi's size adapter" (Compl. ¶35). The complaint provides an image from Defendant Aouball's Alibaba.com webpage showing an "Air Fryer Oven" with the same design as the Arecovas product (Compl. ¶27).
IV. Analysis of Infringement Allegations
The standard for design patent infringement is whether an "ordinary observer," giving the degree of attention a typical purchaser gives, would be deceived into purchasing the accused product believing it to be the patented design. The complaint supports its infringement allegation with side-by-side visual comparisons.
U.S. Patent No. D1,101,481 Infringement Allegations
| Ornamental Feature (from ’481 Patent) | Alleged Infringing Feature of the Arecovas Adapter | Complaint Citation | Patent Citation |
|---|---|---|---|
| The overall ornamental design and visual impression of the adapter. | The complaint alleges the "Arecovas 4-in-1 size adapter bears a substantially similar overall ornamental appearance to the design claimed in the '481 Patent." The side-by-side comparison images are offered as evidence. | ¶41 | Fig. 1 |
| A generally square frame with rounded corners and a raised inner lip. | The Arecovas adapter is depicted as having a square frame with rounded corners and a raised inner lip, creating a similar footprint and profile. A comparative image shows the patented design drawing next to a photograph of the accused adapter. | ¶41 | Fig. 1 |
| Two opposing, raised handle structures integrated into the frame. | The accused adapter is shown with two opposing, raised handles. A side-view comparison juxtaposes the patent's Figure 2 drawing with a photograph of the accused adapter's side profile. | p. 12 | Fig. 2 |
| A contoured base with four distinct feet. | The accused adapter is depicted with a contoured base and four feet. A complaint image compares the patent's Figure 4 drawing of the side view with a photograph of the accused product, highlighting similarities in the base and foot design. | p. 12 | Fig. 4 |
Identified Points of Contention
- Scope Questions: The central legal and factual question will be whether an ordinary observer would find the overall ornamental appearance of the accused Arecovas adapter to be substantially the same as the design claimed in the ’481 Patent. The analysis will likely focus on whether any minor differences in proportion, surface texture, or specific curvature are sufficient to differentiate the designs in the mind of a typical consumer.
- Evidentiary Questions: The court will evaluate the visual evidence, such as the side-by-side comparisons provided in the complaint (Compl. ¶41, p. 12). The dispute may turn on whether the similarities in the overall shape, handle design, and base structure create the same visual impression, or if subtle differences are significant enough to avoid a finding of infringement.
V. Key Claim Terms for Construction
Claim construction, the process of defining the meaning of patent terms, is typically not a central issue in design patent litigation. The claim is understood to be the design itself, as depicted in the patent's drawings. The scope of the claim is defined by the visual appearance of the design in the figures, not by words. Therefore, disputes are more likely to focus on comparing the accused product to the patented design under the "ordinary observer" test rather than construing specific terms. A potential, though not yet raised, issue could involve arguments over which aspects of the design are ornamental versus purely functional, as functional elements are not protected by a design patent.
VI. Other Allegations
- Indirect Infringement: The complaint makes a passing allegation of indirect infringement (Compl. ¶3), but the formal claim for relief is asserted only for direct infringement under 35 U.S.C. § 271(a) (Compl. ¶39, Prayer for Relief ¶a).
- Willful Infringement: While the complaint does not explicitly use the word "willful," it lays a foundation for such a claim. It alleges Defendants had, at a minimum, actual knowledge of the ’481 Patent from the filing date of the complaint (Compl. ¶42). It further alleges constructive notice was provided via Plaintiff's public patent-marking webpage as of November 12, 2025, which may support a claim for enhanced damages for any post-notice infringement (Compl. ¶42).
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this dispute will likely depend on the answers to two primary questions:
A central issue will be one of visual similarity: Applying the "ordinary observer" test, would a typical consumer be deceived into believing the accused Arecovas adapter is the same as, or a colorable imitation of, the design patented in the ’481 Patent, based on its overall appearance?
A potential question concerns the scope of design protection: To what extent are the features of the adapter's design dictated by its function of mating with a heating pod and various cooking vessels? While not yet raised by the defense, arguments distinguishing ornamental from functional features could become critical in defining the enforceable scope of the patented design.