Whirlpool Corp v. Haier Group Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Whirlpool Corp. (Delaware)
  • Defendant: Haier Group Corp. (China); Haier US Appliance Solutions, Inc., d/b/a GE Appliances (Delaware)
  • Plaintiff’s Counsel: MIDLIGE RICHTER, LLC
• Case Identification: 2:25-cv-17666, D.N.J., 11/18/2025
• Venue Allegations: Venue for Haier Group Corp. is based on its status as a foreign entity. Venue for Haier US Appliance Solutions, Inc. is based on allegations of a regular and established place of business in New Jersey, supported by references to local authorized dealers, business registrations, and prior consent to venue in the district.
• Core Dispute: Plaintiff alleges that Defendant’s GE-branded low-profile over-the-range microwave ovens infringe a patent related to the space-saving arrangement of components in a combination microwave and ventilation hood system.
• Technical Context: The technology addresses the challenge of fitting combination microwave-hood appliances into the limited vertical space above a cooktop, a market segment driven by consumer demand for integrated kitchen solutions and efficient use of space.
• Key Procedural History: The complaint notes that contemporaneous with this filing, Plaintiff also filed a complaint against GE Appliances in the District of Delaware and a complaint with the U.S. International Trade Commission (ITC) against Haier and several other major appliance manufacturers, asserting the same patent. This indicates the commencement of a broad, multi-forum 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

• Patent Identification: U.S. Patent No. 12,289,819, "Combination Microwave and Hood System," issued April 29, 2025.

The Invention Explained

• Problem Addressed: The patent's background section describes that conventional combination microwave and ventilation hood systems possess a "significant overall vertical dimension," which can prevent their installation in kitchens with limited space between the cooktop and upper cabinetry ('819 Patent, col. 1:50-58).
• The Patented Solution: The invention claims to solve this problem by reconfiguring the internal components to create a unit with a "significantly scaled down overall vertical dimension" ('819 Patent, col. 4:45-49). A key aspect of this solution is the placement of components like hood fans on the "lateral sides of cooking cavity 34," rather than primarily above or below it, which allows for a reduction in the appliance's total height ('819 Patent, col. 8:42-44, Fig. 8). This spatial rearrangement is intended to preserve both cooking and ventilation functionality within a more compact vertical profile.
• Technical Importance: This design allows a dual-function appliance to be installed in environments that previously could only accommodate a standalone ventilation hood, thereby enhancing kitchen functionality without sacrificing counter space (Compl. ¶13; '819 Patent, col. 4:56-60).

Key Claims at a Glance

• The complaint asserts independent claims 1 and 30, along with numerous dependent claims (Compl. ¶¶23-24).
• Independent Claim 1 recites the essential elements of the low-profile microwave oven, including:
  • An external enclosure with top, bottom, side portions, and a door.
  • A cooking cavity within the enclosure.
  • A "cooking component" (e.g., magnetron) located outside the cooking cavity.
  • A ventilation system including at least one "hood fan," a vent inlet on the bottom, and a recirculation vent outlet near an edge of the top portion.
  • A component cooling system including a "cooling fan," a cooling air inlet, and a cooling air outlet.
  • A specific spatial limitation requiring that "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." ('819 Patent, col. 22:48-62).
• The complaint asserts claims 1-18, 21-22, and 24-30 of the '819 Patent (Compl. ¶23).

III. The Accused Instrumentality

Product Identification

• The complaint identifies "a line of copycat products under the GE brand name," specifically including the "1.2 Cu. Ft. Over-the-Range Low Profile Sensor Microwave Oven," Model No. UVM9125STSS (Compl. ¶¶17-18). These are collectively termed the "Accused Products" (Compl. ¶18).

Functionality and Market Context

• The Accused Products are marketed as "low profile" microwave ovens that combine microwave cooking and ventilation functions in a compact form (Compl. ¶17). The complaint alleges these products are designed to fit "over the range in the same space as a regular undercabinet hood, leaving plenty of countertop space," directly targeting the same problem addressed by the '819 patent (Compl. ¶26, fn. 12). The complaint provides a screenshot from the GE Appliances website showing the "Low Profile" branding of the accused UVM9125STSS model (Compl. ¶17, p. 7).

IV. Analysis of Infringement Allegations

Although the complaint references a claim chart exhibit that was not provided, the complaint itself contains sufficient narrative allegations and photographic evidence to construct a summary of the infringement theory for the asserted claims.

'819 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A microwave oven having a low profile configuration...	The accused product is marketed as a "Low Profile Sensor Microwave Oven."	¶17	col. 21:26
an external enclosure including... a door	The accused product possesses a standard microwave enclosure with a front-facing door. An image of the accused product's exterior is provided in the complaint (Compl. ¶19, p. 8).	¶19	col. 22:1-10
a cooking component located inside the external enclosure and outside the cooking cavity	The complaint includes an image of the accused product's internal components, showing a magnetron and high-voltage transformer located outside the main cooking chamber (Compl. ¶19, p. 9).	¶19	col. 22:16-18
at least one vent inlet located on the bottom portion of the external enclosure	The exterior image of the accused product shows ventilation grilles integrated into its bottom surface (Compl. ¶19, p. 8).	¶19	col. 22:22-24
at least one hood fan located inside the external enclosure	An internal photograph of the accused product depicts fan structures consistent with ventilation components (Compl. ¶19, p. 9).	¶19	col. 22:25-26
a cooling fan configured to... direct the air through the cooking cavity	The complaint does not provide sufficient detail for analysis of the specific airflow path of the cooling fan.	-	col. 22:36-37
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 complaint's internal photographs depict components, including fans, positioned laterally adjacent to the cooking cavity, which may place them within the vertical bounds defined by the cavity's top and bottom surfaces (Compl. ¶19, p. 9).	¶19	col. 22:40-44

Identified Points of Contention

• Scope Questions: A central issue may be whether the term "low profile configuration" in the claim preamble is construed as a limiting structural feature or merely a statement of intended use. The interpretation of this term could influence the entire infringement analysis.
• Technical Questions: A key factual dispute may revolve around the specific functions and locations of the fans within the accused product. The analysis will likely require evidence to determine if the accused product contains two distinct fan systems—a "hood fan" for cooktop ventilation and a "cooling fan" for component cooling—as recited in Claim 1, and whether the airflow path of the cooling fan meets the "direct the air through the cooking cavity" limitation.

V. Key Claim Terms for Construction

The Term: "wherein 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"

• Context and Importance: This limitation appears to be the central structural element that enables the patented "low profile" design. The entire infringement case may depend on whether the accused product's internal fan arrangement falls within the specific geometric boundaries defined by this clause. Practitioners may focus on this term because it quantifies the spatial relationship between the fans and the cooking cavity, which is the core of the asserted invention.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party could argue that the term only requires any part of the fans to be within the specified vertical range. The claim language "is located" does not explicitly require the entirety of the fan assemblies to be within these vertical bounds.
  • Evidence for a Narrower Interpretation: The patent specification repeatedly illustrates embodiments where the fans are placed on the "lateral sides of cooking cavity 34" (e.g., '819 Patent, col. 8:42-44, Fig. 8). A party may argue that this consistent disclosure limits the claim to configurations where the fans are substantially or entirely located beside the cavity, not partially above or below it.

The Term: "direct the air through the cooking cavity"

• Context and Importance: This term defines the function of the "cooling fan." The precise path of the cooling air is a critical limitation that distinguishes it from the "hood fan," which handles contaminated air from the cooktop.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: Plaintiff may point to figures in the patent, such as Figure 16, which shows cooling air (94) passing through passages (96, 98) on the outer surfaces of the cooking cavity (34) ('819 Patent, Fig. 16). This could support a construction where "through the cooking cavity" includes airflow in channels adjacent to or surrounding the cavity liner, not necessarily through the food-preparation space itself.
  • Evidence for a Narrower Interpretation: Defendant may argue that the plain meaning of the phrase requires air to pass into the main chamber where food is cooked. They could argue that such a design is uncommon for component cooling and that their product utilizes a separate, isolated cooling path, thus not meeting this limitation.

VI. Other Allegations

• Indirect Infringement: The complaint alleges active inducement, asserting that Haier encourages infringement through its "marketing materials, product manuals, and web pages on its website" that promote the sale and use of the Accused Products (Compl. ¶26).
• Willful Infringement: Willfulness is alleged based on both pre- and post-suit knowledge. The complaint alleges post-suit knowledge based on the filing of the lawsuit itself (Compl. ¶27). It also makes a pre-suit allegation on "information and belief" that Haier "knew of the '819 patent or was willfully blind to its existence," which is supported by the broader allegation that Haier launched "copycat products" (Compl. ¶¶17, 29).

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

• A core issue will be one of claim construction and structural mapping: Can the phrase "low profile configuration" be defined with sufficient specificity to be an enforceable limitation, and can Whirlpool factually demonstrate that the accused product’s internal fans are positioned entirely within the vertical planes defined by the top and bottom surfaces of the cooking cavity, as required by Claim 1?
• A second key evidentiary question will be one of functional distinction and airflow: Does the accused product contain two functionally and structurally separate fan systems corresponding to the claimed "cooling fan" and "hood fan," and what is the precise path of the air driven by the cooling fan? The viability of the infringement claim may turn on whether that path can be proven to be directed "through the cooking cavity" as the patent construes that term.