DCT
2:25-cv-17663
Whirpool Corp v. Midea Group Co Ltd
Key Events
Complaint
Hearing
Markman
Summary Judgment
Daubert
Markman
Jury Verdict
Daubert (denied)
Jury Trial Transcript
Judgment
Markman
Summary Judgment
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Whirlpool Corp. (Delaware)
- Defendant: Midea Group Co., Ltd. (China); Midea America Corp. (Florida)
- Plaintiff’s Counsel: MIDLIGE RICHTER, LLC
- Case Identification: 2:25-cv-17663, D.N.J., 11/18/2025
- Venue Allegations: Venue is alleged as proper in the District of New Jersey because Defendant Midea America Corp. maintains its principal place of business in the district and has allegedly committed acts of patent infringement there. Venue is alleged as proper for Midea Group Co., Ltd. as a foreign entity.
- Core Dispute: Plaintiff alleges that Defendant’s low-profile over-the-range microwave hood combination products infringe a patent related to the space-saving arrangement of internal ventilation and cooking components.
- Technical Context: The technology concerns combination over-the-range microwave ovens and ventilation hoods, which are designed with a reduced vertical height to fit into compact kitchen spaces without impeding access to the cooktop below.
- Key Procedural History: The complaint states that, contemporaneously with this filing, Plaintiff filed a complaint with the U.S. International Trade Commission (ITC) asserting the same patent against the same Midea products, as well as products from other major appliance manufacturers. Plaintiff also notes it has filed similar district court complaints against those other manufacturers, indicating the commencement of a broad, multi-front patent enforcement campaign.
Case Timeline
| Date | Event |
|---|---|
| 2016-04-12 | U.S. Patent No. 12,289,819 Priority Date |
| 2025-04-29 | U.S. Patent No. 12,289,819 Issues |
| 2025-11-18 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,289,819 - “Combination Microwave and Hood System”, Issued April 29, 2025
The Invention Explained
- Problem Addressed: Conventional combination microwave and ventilation hood systems possess a "significant overall vertical dimension" that can limit their installation to kitchens with ample overhead space and may "overly restrict access to rear cooking regions of the cooking appliance" below (’819 Patent, col. 1:50-59).
- The Patented Solution: The patent describes a microwave hood system with a "significantly scaled down overall vertical dimension" (’819 Patent, col. 4:45-47). This is achieved by strategically relocating internal components. Instead of stacking components vertically, key elements like the hood fans and cooking componentry are placed in a "component space" on the lateral sides of the cooking cavity (’819 Patent, col. 24:55-62; Fig. 9A). This reconfiguration allows for a thinner appliance profile while preserving both microwave and ventilation functions.
- Technical Importance: This design allows a dual-function appliance to be installed in spaces previously only large enough for a standalone ventilation hood, expanding the market for such combination products (Compl. ¶12).
Key Claims at a Glance
The complaint asserts infringement of independent claims 1 and 30, and reserves the right to assert dependent claims (Compl. ¶¶23-24).
Independent Claim 1:
- A microwave oven with a low profile configuration comprising an external enclosure with top, bottom, and side portions.
- A cooking cavity within the enclosure.
- A cooking component located outside the cooking cavity.
- At least one recirculation vent outlet on the top portion.
- At least one vent inlet on the bottom portion.
- At least one hood fan to draw air through the inlet and expel it through the outlet.
- A cooling air inlet and a cooling air outlet.
- A cooling fan configured to draw air through the cooling inlet, "direct the air through the cooking cavity," and expel it via the cooling outlet.
- A specific location requirement: the cooling fan and hood fan(s) must be located vertically below the top surface and vertically above the bottom surface of the cooking cavity.
Independent Claim 30:
- A microwave oven with an external enclosure, cooking cavity, cooking component, vent inlet/outlet, and cooling inlet/outlet, similar to Claim 1.
- A specific location and dimensional requirement: the cooling fan, hood fan, and cooking component are located in a "component space defined between exterior vertical surfaces of the cooking cavity and vertical surfaces of the external enclosure," resulting in an overall vertical dimension of "less than about 300 mm."
III. The Accused Instrumentality
Product Identification
The complaint identifies the "Accused Products" as low-profile microwave hood combination products (LP-MHCs) manufactured by Midea (Compl. ¶¶17-18). The lead product identified is the Midea-branded SKU MMO12S3AST (Compl. ¶17). The complaint also names Midea-manufactured products sold under other brands, including GE, Cosmo, Farberware, Koolmore, Frigidaire, and THOR (Compl. ¶18).
Functionality and Market Context
The complaint alleges the Accused Products are "copycat products" that practice the technology of the ’819 Patent to achieve a space-saving, low-profile design (Compl. ¶16). A screenshot from Midea’s website shows the accused MMO12S3AST product marketed as a "Low Profile Over-the-Range Microwave" (Compl. p. 6). The complaint provides photographs of the interior of an exemplary Accused Product, showing the arrangement of its internal components relative to the cooking cavity (Compl. pp. 7-8). These images depict components, such as the magnetron and ventilation fans, positioned on the sides of the central cooking chamber (Compl. p. 8).
IV. Analysis of Infringement Allegations
The complaint alleges that the Accused Products directly infringe claims 1 and 30 of the ’819 Patent, but does not include the referenced claim chart exhibits (Compl. ¶24). The following tables summarize the infringement theory based on the complaint's narrative allegations.
’819 Patent Infringement Allegations (Claim 1)
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A microwave oven having a low profile configuration, comprising: an external enclosure including: a first side portion; a second side portion; a top portion...; a bottom portion...; and a door | The Accused Products are marketed and sold as "low profile" microwave ovens with a standard external enclosure, as shown in product photographs. | ¶¶16-17, 19 | col. 6:40-52 |
| a cooking cavity located within the external enclosure... | The Accused Products contain a central cooking cavity for heating food. A photograph shows the interior cavity of an accused Midea product. | ¶19 | col. 6:41-42 |
| a cooking component located inside the external enclosure and outside the cooking cavity | The Accused Products contain microwave-generating components, such as a magnetron, located within the enclosure but outside the food cavity. | ¶¶17, 19 | col. 22:38-40 |
| at least one recirculation vent outlet located proximate an edge of the top portion | The Accused Products feature vents on their top surface for recirculating air. | ¶19 | col. 9:54-61 |
| at least one vent inlet located on the bottom portion of the external enclosure | The Accused Products have air intake vents on their bottom surface to draw in air from the cooktop below. | ¶19 | col. 9:29-35 |
| at least one hood fan located inside the external enclosure... configured to: draw air through the at least one vent inlet; and expel the air vertically through the at least one recirculation vent outlet | The Accused Products contain internal fans for their ventilation hood function. | ¶19 | col. 8:46-56 |
| a cooling fan configured to... direct the air through the cooking cavity | The Accused Products contain a cooling fan for internal components. The complaint does not specify the cooling airflow path. | ¶¶17, 19 | col. 8:60-64 |
| each of the cooling fan and the at least one hood fan is located vertically below a top surface of the cooking cavity and vertically above a bottom surface of the cooking cavity | The Accused Products allegedly achieve their low profile by placing fans on the lateral sides of the cooking cavity, within its vertical bounds. | ¶¶16, 19 | col. 8:35-50 |
’819 Patent Infringement Allegations (Claim 30)
| Claim Element (from Independent Claim 30) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A microwave oven, comprising: an external enclosure including... a door; a cooking cavity... a cooking component... | The Accused Products contain the basic structural elements of a microwave oven. A photograph shows the internal components of an accused product. | ¶¶17, 19, p. 8 | col. 6:40-42 |
| each of the cooling fan, the at least one hood fan, and the cooking component are located in a component space defined between exterior vertical surfaces of the cooking cavity and vertical surfaces of the external enclosure... | The Accused Products allegedly place their fans and microwave-generating components in the space to the sides of the cooking cavity, rather than above or behind it. | ¶¶16, 19 | col. 8:35-50 |
| ...resulting in a vertical dimension of less than about 300 mm. | The Accused Products are marketed as "low profile" and possess a reduced vertical height consistent with this dimension. | ¶16 | col. 10:66-11:11 |
- Identified Points of Contention:
- Scope Questions: Claim 1 requires the cooling fan to "direct the air through the cooking cavity." This raises the question of whether cooling air in the accused devices passes through the food-containing portion of the cavity, or merely through passages along the cavity's exterior shell. A mismatch on this point could present a significant non-infringement argument.
- Technical Questions: The infringement reading of Claim 30 depends on the precise location of the fans and cooking componentry within the accused products. The case may turn on evidence establishing whether these components are located in the specific lateral "component space" defined by the claim, which is the structural feature allegedly enabling the patented "low profile" design.
V. Key Claim Terms for Construction
The Term: "direct the air through the cooking cavity" (Claim 1)
- Context and Importance: This term is critical because it defines a specific and unusual airflow path for cooling. Typically, cooling air for electronics is kept separate from the food cavity. The defendant will likely argue its product does not route air this way, making the interpretation of "through the cooking cavity" a central issue.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue for the plain and ordinary meaning, suggesting the air must pass through the interior space where food is placed.
- Evidence for a Narrower Interpretation: The patent specification describes cooling air passing "through a first cooking cavity air passage 96 on a surface of cooking cavity 34" and "out a second cooking cavity air passage 98 on a top surface of cooking cavity 34" (’819 Patent, col. 10:22-28). This language may support an interpretation that "through" means passing over the cavity's exterior surfaces via defined passages, not through the food-containing interior itself.
The Term: "component space defined between exterior vertical surfaces of the cooking cavity and vertical surfaces of the external enclosure" (Claim 30)
- Context and Importance: This term defines the specific location of the operative components that is the basis for the invention's low-profile structure. Practitioners may focus on this term because infringement hinges on a direct structural correspondence between the accused product's layout and this claimed "component space."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue this language covers any arrangement where components are generally "to the side" of the cavity.
- Evidence for a Narrower Interpretation: Figures 8 and 9A clearly depict the hood fans (66, 74) and cooking component area (64) occupying a distinct volume on the lateral sides of the cooking cavity (34), between the cavity wall and the outer wrapper. The specification states that in some embodiments, "hood fans may be located on lateral sides of cooking cavity 34" to "minimize the vertical dimension" (’819 Patent, col. 8:39-45). This evidence strongly supports a specific, limiting construction tied to a lateral-only placement.
VI. Other Allegations
- Indirect Infringement: The complaint alleges Midea induces infringement by "actively encouraging" the use of the Accused Products through marketing materials, product manuals, and web pages (Compl. ¶¶25-26). It specifically cites Midea's website, which allegedly provides links to product manuals and markets the product's "slim design" (Compl. ¶26, n.6).
- Willful Infringement: Willfulness is alleged on the basis that Midea "knew of the ’819 patent or was willfully blind to its existence" (Compl. ¶29). The complaint asserts that Midea received notice of the patent and its alleged infringement no later than the filing of the complaint itself, and that any continued infringement would be knowing and intentional (Compl. ¶27).
VII. Analyst’s Conclusion: Key Questions for the Case
This dispute appears to center on the specific structural and functional details that enable a low-profile microwave hood. The resolution will likely depend on the answers to two key questions:
A core issue will be one of functional operation: Does the accused product's cooling system "direct the air through the cooking cavity" as required by Claim 1? The case will require a factual determination of the cooling airflow path and a legal construction of whether passing air over the cavity's exterior surfaces meets this limitation.
A second key question will be one of structural correspondence: Are the fans and cooking components in the accused products located within the specific lateral "component space" defined in Claim 30? This will involve a detailed comparison of the accused product's architecture against the patent's claims and figures, which explicitly link this placement to the invention's central purpose of achieving a reduced vertical dimension.