DCT

1:24-cv-08984

SharkNinja Operating LLC v. RJ Brands LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:24-cv-08984, D.N.J., 06/02/2025
  • Venue Allegations: Venue is alleged to be proper in the District of New Jersey because Defendant is a New Jersey corporation with its principal place of business in the district, and therefore resides there.
  • Core Dispute: Plaintiff alleges that Defendant’s indoor grills and dual-basket air fryers infringe six utility and design patents related to specialized grill plates for airflow management and dual-zone cooking systems.
  • Technical Context: The lawsuit concerns the highly competitive market for countertop kitchen appliances, where innovations in cooking performance and convenience are significant drivers of market share.
  • Key Procedural History: The complaint alleges that Defendant had pre-suit knowledge of its infringement of the ’146 and ’152 patents via a notice letter sent on August 29, 2024, which may form the basis for a willfulness claim.

Case Timeline

Date Event
2019-02-25 Priority Date for ’146 and ’152 Patents
2019-06-06 Priority Date for D918,654 Patent
2019-07-15 Priority Date for ’026 and ’377 Patents
2019-07-XX Plaintiff releases Ninja® Indoor Grill & Air Fryers
2020-06-20 Priority Date for D986,669 Patent
2020-SU-XX Plaintiff releases Ninja® 2-Basket Air Fryer with DualZone™
2021-05-11 U.S. Patent No. D918,654 Issued
2021-06-15 U.S. Patent No. 11,033,146 Issued
2022-07-19 U.S. Patent No. 11,389,026 Issued
2023-05-23 U.S. Patent No. D986,669 Issued
2023-06-13 U.S. Patent No. 11,672,377 Issued
2023-09-26 U.S. Patent No. 11,766,152 Issued
2024-08-29 Plaintiff sends notice letter to Defendant regarding ’146 and ’152 patents
2025-06-02 Complaint Filed

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

U.S. Patent No. 11,033,146 - “Cooking Device and Components Thereof”

The Invention Explained

  • Problem Addressed: The patent background describes conventional indoor grills that heat food unevenly, either from the bottom only or from both the top and bottom simultaneously (Compl. ¶24).
  • The Patented Solution: The invention is a countertop grilling system that uses a heating element located above the food in conjunction with a specially designed grill plate. This plate features a configuration of ribs and channels that captures downward-flowing hot air, redirects it horizontally toward the center, and then allows it to flow upward from beneath the food, thereby heating the entire food item more evenly (’146 Patent, col. 13:5-26; Compl. ¶27). The design aims to create more uniform heating and allow for indoor searing that creates grill marks, a result typically not possible with prior indoor systems (’146 Patent, col. 14:14-15:5).
  • Technical Importance: The technology purports to solve the long-standing challenge of replicating outdoor grill performance—specifically, even heating and high-temperature searing—in a convenient indoor countertop appliance (Compl. ¶28).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶60).
  • Essential elements of claim 1 include:
    • A housing with a hollow interior for receiving food.
    • A heating element associated with the housing.
    • A support body (e.g., a grill plate) with a support surface that includes a plurality of ribs.
    • A plurality of channels located between the ribs.
    • The plurality of ribs includes “diffuser ribs,” which in turn include short, intermediate, and long ribs.
    • A food container receivable in the hollow interior, where the support body is removably mounted within the food container.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 11,766,152 - “Cooking Device and Components Thereof”

The Invention Explained

  • Problem Addressed: As with the related ’146 Patent, this patent addresses the problem of uneven cooking in conventional indoor countertop grills (Compl. ¶24).
  • The Patented Solution: The ’152 Patent also describes a top-down heating system paired with a specialized grill plate. The claims of this patent, however, provide a more detailed geometric definition of the grill plate's "diffuser ribs," describing them as curved and extending radially inward from an outer edge to three distinct radial positions on the support surface (’152 Patent, col. 17:49-67). This specific structure is designed to control airflow to achieve even heating and searing performance (’152 Patent, col. 13:5-26).
  • Technical Importance: This patent refines the technological approach of the ’146 Patent by claiming a specific geometric arrangement of ribs, suggesting that the precise configuration of the airflow-directing structures is critical to the invention's improved performance (Compl. ¶28).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶71).
  • Essential elements of claim 1 include:
    • A housing with a hollow interior configured to receive food.
    • A heating element associated with the housing.
    • A support body configured to support food within the hollow interior, including a support surface and an outer edge.
    • The support surface includes a plurality of diffuser ribs that are curved.
    • The diffuser ribs include first, second, and third ribs extending radially inward from the outer edge to distinct first, second, and third radial positions on the support surface.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. D918,654 - "Grill Plate"

  • Technology Synopsis: This is a design patent that claims the ornamental appearance of the grill plate described in the ’146 and ’152 patents. The design features a distinctive pattern of curved, radiating ribs of varying lengths (Compl. ¶22).
  • Asserted Claims: The single claim covering the ornamental design as shown in the patent figures (Compl. ¶82).
  • Accused Features: The complaint alleges that the ornamental design of the grill plate in the Chefman Electric Indoor Air Fryer + Grill is substantially the same as the patented design (Compl. ¶50).

U.S. Patent No. 11,389,026 - “Cooking Device and Components Thereof”

  • Technology Synopsis: This patent addresses the inefficiency of cooking different foods that require different temperatures one at a time. The invention is a cooking system with a single housing that contains two separate internal compartments, each with its own cooking container, heating element, and fan, allowing for independent operation and simultaneous cooking at different temperatures (Compl. ¶¶36-37, 39).
  • Asserted Claims: At least independent claim 1 (Compl. ¶92).
  • Accused Features: The Chefman Dual Air Fryer is accused of infringing by having a housing with two internal compartments, two removable cooking containers (baskets), and independent heating elements and fans for each compartment (Compl. ¶¶52-54, 93).

U.S. Patent No. 11,672,377 - “Cooking Device and Components Thereof”

  • Technology Synopsis: This patent is also directed to a dual-zone cooking system. It claims a housing with two internal compartments separated by a dividing wall that extends upward from the base of the housing, with each compartment containing a removable cooking container and having its own heating element and fan (Compl. ¶¶36-37; ’377 Patent, Abstract).
  • Asserted Claims: At least independent claim 1 (Compl. ¶103).
  • Accused Features: The Chefman Dual Air Fryer is accused of infringing by having two compartments separated by a dividing wall, along with independently operable heating elements and fans for each side (Compl. ¶¶52-54, 104).

U.S. Patent No. D986,669 - "Food Preparation Device"

  • Technology Synopsis: This design patent claims the overall ornamental appearance of the dual-zone cooking appliance described in the ’026 and ’377 patents. The design features a generally rectangular housing with two prominent, front-facing drawers or baskets and a top-mounted control panel (Compl. ¶38).
  • Asserted Claims: The single claim covering the ornamental design as shown in the patent figures (Compl. ¶114).
  • Accused Features: The complaint alleges that the overall appearance of the Chefman Dual Air Fryer product embodies the patented design (Compl. ¶55).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies two product lines: the "Chefman Electric Indoor Air Fryer + Grill" and the "Chefman Dual Air Fryer" (Compl. ¶18).

Functionality and Market Context

  • The Chefman Electric Indoor Air Fryer + Grill is a countertop appliance that includes a housing with a hinged lid, a hollow interior, a removable cooking pan, and a removable grill plate (Compl. ¶¶48, 50). It features a heating element in the lid, positioned above the cooking container, and its grill plate contains a series of ribs and channels that the complaint alleges diffuses airflow to provide even heating (Compl. ¶¶49-51). An annotated diagram from the product's user guide identifies the housing, hollow interior, and cooking pan. (Compl. ¶61, Ex. G at 13).
  • The Chefman Dual Air Fryer is a countertop appliance with a housing that contains two separate internal compartments, each with its own removable cooking basket (Compl. ¶¶52, 87). Each compartment also includes its own heating element and fan, allowing a user to cook two different foods at different temperatures and for different times simultaneously (Compl. ¶¶53-54). The complaint alleges these products are "copycat products" released after SharkNinja's similar products achieved market success (Compl. ¶¶8, 43-46).

IV. Analysis of Infringement Allegations

U.S. Patent No. 11,033,146 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a housing having a hollow interior, food being receivable within said hollow interior The accused product has a main body (housing) with an internal space (hollow interior) into which a cooking pan and grill plate are placed to hold food. ¶61 (p. 27) col. 3:33-37
a heating element associated with said housing The accused product has an electric heating element mounted within the lid of the housing. ¶61 (p. 35) col. 6:54-55
a support body for supporting food...said support body including a support surface, wherein said support surface includes a plurality of ribs The accused product’s removable grill plate acts as a support body for food, and its top surface includes multiple ribs. ¶61 (p. 37) col. 4:50-65
wherein said support surface includes a plurality of channels between said plurality of ribs The ribs on the accused grill plate are separated by spaces, which form channels between them. ¶61 (p. 45) col. 13:13-17
wherein said plurality of ribs includes diffuser ribs, said plurality of diffuser ribs including short ribs, intermediate ribs, and long ribs The complaint alleges the accused grill plate’s ribs function as "diffuser ribs" to create grill marks and include ribs of varying lengths, measured as approximately 20mm, 30mm, and 79mm. ¶61 (p. 46-49) col. 5:50-63
further comprising a food container receivable in said hollow interior, said support body being removably mounted within an interior of said food container The accused product includes a cooking pan (food container) that is placed in the hollow interior, and the grill plate (support body) is removably placed inside the cooking pan. ¶61 (p. 50) col. 5:14-20

U.S. Patent No. 11,766,152 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a housing having a hollow interior configured to receive food therein The accused product's main body (housing) has an internal space (hollow interior) configured to receive a cooking pan and food. ¶72 (p. 60) col. 3:33-35
a heating element associated with the housing An electric heating element is mounted within the lid of the housing. ¶72 (p. 66) col. 6:54-55
a support body configured to support food...the support body including a support surface and an outer edge, wherein the support surface includes a plurality of diffuser ribs, the plurality of diffuser ribs being curved The accused grill plate is a support body with a top support surface and an outer edge, and features a plurality of curved ribs alleged to be diffuser ribs. ¶72 (p. 68) col. 12:17-19
and including first ribs, second ribs, and third ribs, the first ribs extending radially inward...to a first radial position...the second ribs extending radially inward...to a second radial position...and the third ribs extending radially inward...to a third radial position, the first, second, and third radial positions being different The complaint presents photographs with caliper measurements alleging that different sets of ribs on the accused grill plate extend inward to three distinct radial positions (73mm, 115mm, and 109mm from the inner radius). ¶72 (p. 76-78) col. 12:23-41
  • Identified Points of Contention:
    • Scope Questions: The infringement analysis for the ’146 and ’152 patents may focus on the term "diffuser ribs." The complaint alleges that ribs creating grill marks inherently function as "diffuser ribs" (Compl. ¶61, p. 46; ¶72, p. 75). A central question may be whether the term, as defined and used in the patent specification, requires a specific aerodynamic function beyond simply transferring heat via conduction to create sear marks.
    • Technical Questions: For the ’152 patent, a key factual dispute may arise over whether the accused grill plate meets the precise geometric limitations of claim 1. The complaint provides photographic evidence with measurements purporting to show ribs terminating at distinct "first, second, and third radial positions" (Compl. ¶72, pp. 77-79). The case may turn on whether these measurements accurately map onto the claimed limitations and whether the term "radial position" has a specific meaning in the patent that is either met or not met by the accused product's structure.

V. Key Claim Terms for Construction

  • The Term: "diffuser ribs" (’146 Patent, Claim 1; ’152 Patent, Claim 1)

  • Context and Importance: This term is central to the infringement allegations for both the ’146 and ’152 patents, as it describes the key functional component of the grill plate. Practitioners may focus on this term because its definition—whether it implies a specific air-diffusion function or can be read more broadly to cover ribs that create grill marks through conduction—will likely determine the scope of the claims.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification states that the diffuser ribs are part of a “diffusing structure operable to diffuse an air flow” and that this structure functions to “slow the speed of an air flow” and “reduce the rotation of the airflow” (’146 Patent, col. 12:17-23). Parties arguing for a broader scope may contend that any structure of ribs that alters airflow fits this description.
    • Evidence for a Narrower Interpretation: The detailed description links the diffuser ribs to a specific aerodynamic effect: deflecting "downward flowing fluid relatively horizontally across said support body" (’146 Patent, col. 2:25-30). A party could argue this requires more than merely obstructing air; it requires a specific redirection of flow that must be proven to occur in the accused product.

  • The Term: "first radial position," "second radial position," "third radial position" (’152 Patent, Claim 1)

  • Context and Importance: These terms define the specific geometric layout of the ribs, which distinguishes the ’152 patent from the broader ’146 patent. Infringement of claim 1 of the ’152 patent hinges entirely on whether the accused grill plate has three sets of ribs terminating at three different radial positions.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The patent does not appear to provide an explicit numerical or formulaic definition for "radial position." A party might argue it simply means three different distances from the center, a standard that the complaint's measurements appear to meet (Compl. ¶72, pp. 77-79).
    • Evidence for a Narrower Interpretation: Figure 12 of the patent shows distinct, concentric rings (121, 123) from which the intermediate and short ribs appear to originate (’152 Patent, Fig. 12). A defendant might argue that "radial position" should be construed to mean the location of these specific structural rings, and that infringement would require proving the accused product has corresponding structures, not just ribs of varying lengths.

VI. Other Allegations

  • Indirect Infringement: The complaint does not contain specific counts for indirect infringement (inducement or contributory infringement).
  • Willful Infringement: Willfulness is alleged for all six patents-in-suit. For the ’146 and ’152 patents, the claim is based on alleged pre-suit notice via a letter dated August 29, 2024, as well as the filing of the complaint (Compl. ¶¶64-66, 75-77). For the remaining four patents, the basis for willfulness is alleged to be at least as early as the filing of the complaint (Compl. ¶¶86-87, 97-98, 108-109, 119-120).

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

  • A core issue will be one of functional scope: does the term "diffuser ribs" require proof of a specific aerodynamic effect on airflow, as detailed in the patent specification, or can it be construed more broadly to cover any rib structure that produces grill marks, as the complaint's infringement theory suggests?
  • A key evidentiary question will be one of structural correspondence: can Plaintiff demonstrate that the physical measurements of the accused Chefman grill plate map precisely onto the specific geometric limitations of the ’152 patent's claims, particularly the requirement for ribs extending to three distinct "radial positions"?
  • For the dual-cooker patents, a central question of claim construction will be whether the Chefman Dual Air Fryer, with two physically separate and removable baskets, meets the limitation of a single "housing" containing a "first internal compartment and a second internal compartment," or if the patented language implies a more integrated structure.