DCT
2:25-cv-01042
Whirlpool Corp v. Samsung Electronics Co Ltd
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Whirlpool Corporation (Delaware)
- Defendant: Samsung Electronics Co., Ltd. (Republic of Korea); Samsung Electronics America, Inc. (New York)
- Plaintiff’s Counsel: Susman Godfrey L.L.P.; Miller Fair Henry, PLLC
- Case Identification: 2:25-cv-01042, E.D. Tex., 10/10/2025
- Venue Allegations: Plaintiff alleges venue is proper for Samsung Electronics Co., Ltd. as a foreign corporation and for Samsung Electronics America, Inc. based on its alleged commission of infringing acts and maintenance of a regular and established place of business in the district.
- Core Dispute: Plaintiff alleges that Defendant’s premium dishwashers featuring an enhanced third rack infringe two patents related to dishwasher rack designs capable of holding both utensils and drinkware.
- Technical Context: The technology concerns the internal architecture of household dishwashers, where features like versatile third racks are a key point of competition and product differentiation in the consumer appliance market.
- Key Procedural History: The complaint notes that in other recent patent cases in the Eastern District of Texas, Defendants have not disputed the court's personal jurisdiction or contested venue.
Case Timeline
| Date | Event |
|---|---|
| 2014-02-28 | U.S. Patent No. 10,512,385 Priority Date |
| 2019-12-24 | U.S. Patent No. 10,512,385 Issued |
| c. 2020 | Plaintiff Whirlpool releases dishwashers with enhanced top racks |
| 2020-03-30 | U.S. Patent No. 12,232,681 Priority Date |
| 2025-02-25 | U.S. Patent No. 12,232,681 Issued |
| c. April 2025 | Defendant Samsung releases Accused Products |
| 2025-10-10 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,232,681 - “Dishwasher with a Dish Rack,” Issued Feb. 25, 2025
The Invention Explained
- Problem Addressed: The patent’s background describes conventional dishwasher layouts, including upper racks for glassware, lower racks for plates, and sometimes a shallow third rack limited to low-profile utensils, suggesting an inefficient use of space for mixed loads (’681 Patent, col. 1:22-44).
- The Patented Solution: The invention discloses a single dish rack with a bottom wall constructed in two distinct zones: a "substantially planar portion" designed to act as a "utensil seat," and an adjacent "depression portion" that is angled relative to the first portion to create a deeper "cup seat." This dual-geometry design allows a single rack to accommodate both flatware and taller items like cups (’681 Patent, Abstract; col. 2:51-58; Fig. 3).
- Technical Importance: This design enhances the utility and loading capacity of a dishwasher's third rack, a feature that the complaint presents as a major market differentiator for premium dishwashers (Compl. ¶24).
Key Claims at a Glance
- The complaint asserts independent claim 14 (Compl. ¶35).
- The essential elements of claim 14 include:
- An automatic dishwasher comprising a tub and a dish rack with a bottom wall and a peripheral wall.
- The bottom wall having a first portion at a first end, defined by a "first substantially horizontal planar portion."
- The bottom wall having a second portion at a second end that is "angled with respect to the first portion and defining a depression."
- The depression extends "lower than the first portion relative to the peripheral wall."
- The complaint reserves the right to assert additional claims (Compl. ¶35).
U.S. Patent No. 10,512,385 - “Glasses Rack for Dishwasher,” Issued Dec. 24, 2019
The Invention Explained
- Problem Addressed: The patent background discusses the conventional arrangement of dish racks, implying a need for improved methods of securing and effectively cleaning glassware, which can be prone to rolling or trapping water if not properly oriented (’385 Patent, col. 1:16-26).
- The Patented Solution: The invention describes a dish rack with a bottom wall featuring an "upwardly angled portion" composed of multiple "spaced apart inclined portions." Two adjacent inclined portions are configured to "cradle a glass at an inclined angle," preventing it from rolling and promoting drainage. The solution also integrates a dedicated "spray tube" with nozzles that is "carried with the dish rack" to direct cleaning liquid along the angled glassware (’385 Patent, Abstract; col. 12:40-58).
- Technical Importance: This integrated system of structural support and targeted spraying aims to improve cleaning performance and stability for delicate glassware, a common pain point for consumers (Compl. ¶22).
Key Claims at a Glance
- The complaint asserts independent claim 17 (Compl. ¶45).
- The essential elements of claim 17 include:
- A dishwasher with a tub, a spray system, and a selectively moveable dish rack.
- The dish rack has an "upwardly angled portion" in its bottom wall comprising "a plurality of spaced apart inclined portions."
- Two adjacent inclined portions are configured to "cradle a glass at an inclined angle and prevent the glass from rolling."
- A "contoured portion" in the bottom wall is configured to "prevent glasses from sliding."
- A "spray tube having nozzles emitting spray along the angled portion," where the spray tube is mounted to and "carried with the dish rack."
- The complaint reserves the right to assert additional claims (Compl. ¶45).
III. The Accused Instrumentality
Product Identification
- The "Samsung 38 dBA Bespoke Smart Dishwasher with 3rd Rack Washing System" and other Samsung dishwashers that include an "infringing enhanced top rack" (Compl. ¶¶ 26, 35, 45).
Functionality and Market Context
- The complaint alleges the Accused Products incorporate an "enhanced top rack" that, like Whirlpool's commercial embodiment, can hold both drinkware and silverware/utensils (Compl. ¶26). Plaintiff alleges this feature was "modeled after the KitchenAid technology" (Compl. ¶26). An included screenshot from Samsung's advertising describes the feature as a "3rd Rack Washing System" with a "Dedicated area for drinkware, cutlery and utensils" (Compl. ¶28, p. 9). The complaint further alleges the Accused Products feature "sprayers placed strategically along the depression portion of the top racks meant to serve as the starting point for inclined cup seats" (Compl. ¶29). A supporting screenshot shows "Dedicated wash jets with six spinning nozzles" integrated into the rack structure (Compl. ¶29, p. 10). The complaint alleges that Samsung’s entry into this market segment threatens Whirlpool's sales and market position for its premium dishwashers (Compl. ¶27).
IV. Analysis of Infringement Allegations
'681 Patent Infringement Allegations
| Claim Element (from Independent Claim 14) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a dish rack located within the dish treating chamber... comprising a bottom wall from which extends a peripheral wall... | The Accused Products' "enhanced top rack," advertised as the "3rd Rack Washing System." | ¶37 | col. 2:51-53 |
| at the first end of the dish rack, the bottom wall has a first portion defined by a first substantially horizontal planar portion... | The area of the accused third rack advertised as a "dedicated area for... cutlery and utensils." | ¶¶ 28, 37 | col. 2:53-56 |
| at the second end of the dishrack, a second portion is angled with respect to the first portion and defining a depression... | The area of the accused third rack advertised as a "dedicated area for drinkware," which creates a deeper section for cups. | ¶¶ 28, 37 | col. 2:56-58 |
| the depression extending lower than the first portion relative to the peripheral wall. | The geometric arrangement of the accused third rack, where the drinkware section is lower than the cutlery section. | ¶¶ 28, 37 | col. 2:58-60 |
- Identified Points of Contention:
- Scope Questions: A central issue may be whether the accused rack's geometry satisfies the specific limitations of a "substantially horizontal planar portion" and an "angled" second portion. The interpretation of "substantially horizontal" could be a focus of claim construction.
- Technical Questions: What evidence does the complaint provide that the accused rack's "depression" meets the precise structural requirement of "extending lower than the first portion relative to the peripheral wall"? Proving this specific spatial relationship will require evidence beyond the provided marketing images.
'385 Patent Infringement Allegations
| Claim Element (from Independent Claim 17) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a dish rack located in the tub and selectively moveable... with an upwardly angled portion formed in the bottom wall comprising a plurality of spaced apart inclined portions... | The accused third rack, which is alleged to have "inclined cup seats that function to secure drinkware" in a "depression portion." | ¶¶ 29, 47 | col. 8:36-44 |
| wherein two adjacent inclined portions... are configured to cradle a glass at an inclined angle and prevent the glass from rolling... | The wire structure of the accused rack's cup seats, which allegedly holds drinkware at an angle. | ¶¶ 29, 47 | col. 8:58-63 |
| and a contoured portion formed in the bottom wall configured to prevent glasses from sliding down the inclined angle... | The structure of the accused rack that allegedly secures drinkware and prevents it from "rolling around the rack." | ¶¶ 29, 47 | col. 8:67-col. 9:1 |
| a spray tube having nozzles emitting spray along the angled portion... the spray tube is mounted such that the spray tube is carried with the dish rack. | The accused product's "dedicated wash jets with six spinning nozzles," which are allegedly part of the moveable third rack and positioned to clean items in the inclined cup seats. | ¶¶ 29, 47 | col. 12:54-58 |
- Identified Points of Contention:
- Scope Questions: Does the wire structure of the accused rack constitute "a plurality of spaced apart inclined portions" that "cradle" a glass, as those terms are used in the patent? The definition of "cradle" will be critical.
- Technical Questions: Does the accused product’s spray system function as a "spray tube... carried with the dish rack"? The complaint's visual evidence suggests sprayers are integrated into the rack, but establishing that this structure meets the claim limitation will be a key technical question.
V. Key Claim Terms for Construction
Term from '681 Patent, Claim 14: "defining a depression"
- Context and Importance: The infringement theory for the ’681 patent depends on the accused rack having this specific feature. The definition of "depression" will determine whether Samsung's multi-level rack, which accommodates both utensils and cups, falls within the claim's scope.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The summary of the invention describes the feature more generally as "at least one of a second and third planar portion angled with respect to the first planar portion," suggesting that any non-coplanar, lowered section could meet the definition (’681 Patent, col. 2:5-9).
- Evidence for a Narrower Interpretation: The specification repeatedly refers to the depression as defining a "cup seat" (’681 Patent, col. 5:61-62). Figures 3 and 5A show a distinct, recessed area. This may support an argument that the term requires a clearly demarcated, purpose-built seat, not just a generally lower area.
Term from '385 Patent, Claim 17: "configured to cradle a glass"
- Context and Importance: This term is central to how the patented rack secures glassware. The dispute will likely focus on whether the structure of the accused rack performs this specific "cradling" function or is merely a generic support.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the function of the supports as being "to retain the glasses... in a particular location and prevent the glasses... from rolling" (’385 Patent, col. 5:7-9). This functional description could support construing "cradle" to cover any structure that achieves this anti-rolling result.
- Evidence for a Narrower Interpretation: The patent describes how "opposing inclined portions 67 may form a cradle for each of the glasses 74" (’385 Patent, col. 8:58-59). The accompanying Figure 8 illustrates a distinct V-shaped structure formed by these portions. This may support a narrower construction limited to a structure that envelops or closely conforms to the glass, rather than simply propping it at an angle.
VI. Other Allegations
- Indirect Infringement: The complaint includes boilerplate allegations of induced and contributory infringement in the prayer for relief (Compl. ¶14a), but the complaint does not provide sufficient detail for analysis of the specific facts supporting knowledge or intent.
- Willful Infringement: The complaint alleges that Samsung's infringement is willful and deliberate for both patents, asserting that Samsung proceeded "despite the risk of infringement being either known or so obvious that it should have been known to Samsung" (Compl. ¶¶ 39, 49). The allegations are made on "information and belief" without specific factual assertions of pre-suit notice.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: How will the court construe the key geometric terms of the claims? The case may turn on whether the accused rack's structure can be characterized as having a "depression" (’681 patent) and supports that "cradle a glass" (’385 patent), or if these terms are limited to the more specific embodiments shown in the patent figures.
- A key evidentiary question will be one of technical and functional proof: Beyond marketing materials, can Plaintiff demonstrate that the accused Samsung rack and its integrated sprayers operate in the specific manner required by the claims? For instance, proving the precise spatial relationships of the rack geometry (’681 patent) and that the spray system is "carried with the dish rack" to spray "along the angled portion" (’385 patent) will be critical.