DCT
2:25-cv-01136
Whirlpool Corp v. LG Electronics Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Whirlpool Corp. (Delaware)
- Defendant: LG Electronics, Inc. (Korea); LG Electronics USA, Inc. (Delaware)
- Plaintiff’s Counsel: Winston & Strawn LLP
- Case Identification: 2:25-cv-01136, E.D. Tex., 11/18/2025
- Venue Allegations: Plaintiff alleges venue is proper for LG Electronics, Inc. as a foreign entity and for LG Electronics USA, Inc. based on its regular and established place of business within the Eastern District of Texas.
- Core Dispute: Plaintiff alleges that Defendant’s low-profile over-the-range microwave oven products infringe two patents related to compact combination microwave and ventilation hood systems.
- Technical Context: The technology concerns the design of over-the-range appliances that combine microwave cooking and ventilation functions into a unit with a reduced vertical height, intended to improve kitchen ergonomics and expand installation options.
- Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history between the parties concerning the patents-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2016-04-12 | ’317 and ’819 Patents Priority Date |
| 2024-10-29 | U.S. Patent No. 12,133,317 Issues |
| 2025-04-29 | U.S. Patent No. 12,289,819 Issues |
| 2025-11-18 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,133,317 - "Combination Microwave and Hood System"
The Invention Explained
- Problem Addressed: The patent’s background section notes that conventional combination microwave and ventilation hood systems "typically have a significant overall vertical dimension," which can restrict user access to the rear cooking regions of the range below (’317 Patent, col. 1:44-53).
- The Patented Solution: The invention claims to solve this problem through a specific internal architecture that enables a reduced height. The design features a "cooking component area" for electronics located between the internal cooking cavity and the external enclosure, and a specifically defined "cooling air path" where air is drawn from an inlet on the top surface, directed through the component area, then through the cooking cavity itself, and finally expelled through an outlet on the top surface (’317 Patent, Abstract; col. 2:10-22). This relocates components and re-routes airflow to achieve a slimmer vertical profile.
- Technical Importance: This design allows for the installation of a dual-function appliance in spaces that previously may have only been able to accommodate a single-function, standalone ventilation hood (’317 Patent, col. 4:56-59).
Key Claims at a Glance
- The complaint asserts independent claim 1 and dependent claims 2-6 and 8 (Compl. ¶25).
- Independent Claim 1 requires:
- An external enclosure with a top surface defining a cooling air inlet, a cooling air outlet, and at least one vent outlet.
- An internal enclosure defining a cooking cavity.
- A cooking component area defined between the internal and external enclosures.
- A cooling fan in the cooking component area configured to direct air along a specific "cooling air path."
- The cooling air path is defined as flowing in sequence: through the cooling air inlet, into the component area, through the first air passage (sidewall), through the cooking cavity, through the second air passage (top wall), and out the cooling air outlet.
- At least one hood fan, separate from the cooling fan, to draw air from a bottom vent inlet and expel it through a vent outlet.
U.S. Patent No. 12,289,819 - "Combination Microwave and Hood System"
The Invention Explained
- Problem Addressed: This patent, from the same family as the ’317 patent, addresses the desire to add more cooking functionality (e.g., broiling or warming) into the compact, low-profile form factor of an over-the-range appliance without significantly increasing its size (’819 Patent, col. 4:60-63).
- The Patented Solution: The invention describes a modular system comprising a microwave oven enclosure, a separate "heating system" (which defines a heating cavity for a broiler or salamander unit), and a "dual hood system" for ventilation. The claims focus on the structural combination of these distinct subsystems into a single, integrated appliance (’819 Patent, Abstract; col. 18:1-11).
- Technical Importance: The claimed solution provides a multi-function cooking appliance (microwave, broiler, vent hood) in a single compact unit, enhancing the utility of the over-the-range space (’819 Patent, col. 4:60-63).
Key Claims at a Glance
- The complaint asserts independent claims 1 and 30, and numerous dependent claims (Compl. ¶35).
- Independent Claim 1 requires:
- A microwave oven enclosure defining a cooking cavity.
- A heating system coupled to the microwave enclosure, defining a separate heating cavity.
- A heating element and a broiler element within the heating cavity.
- A dual hood system coupled to the microwave hood system.
- Independent Claim 30 requires:
- An external enclosure including a cooking component and a cooking cavity.
- At least one hood fan.
- A cooling fan.
- The cooling fan, hood fan, and cooking component are located in a "component space" defined between the exterior vertical surfaces of the cooking cavity and the external enclosure, resulting in a vertical dimension of less than about 300 mm.
III. The Accused Instrumentality
Product Identification
- The accused products are LG’s "Smart Low Profile Over-the-Range Microwave Oven" appliances, specifically Stock Keeping Units (SKUs) MVEF1323F and MVEF1323SS (collectively, “Type A Accused Products”) and MVEF1337F and MVEF1337SS (collectively, “Type B Accused Products”) (Compl. ¶¶18, 19). A screenshot from LG's website shows the product marketing, which uses the term "Low Profile" (Compl. p. 7).
Functionality and Market Context
- The complaint alleges these products are a "line of copycat products" that practice the asserted patents (Compl. ¶17). The complaint provides photographic evidence depicting the external appearance and internal components of both Type A and Type B products (Compl. pp. 8-10). These images show internal layouts with fans, electronic components, and ducting that Plaintiff alleges correspond to the claimed elements of the patents-in-suit. For example, a photograph shows the internal components of an exemplary Type A Accused Product, which includes various electronic components and fans arranged around a central cavity (Compl. p. 8, top image).
IV. Analysis of Infringement Allegations
The complaint does not contain detailed claim charts in its body, instead referencing exhibits not included in the public filing. The following charts summarize the infringement theory based on the complaint's narrative allegations and supporting photographic evidence.
’317 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an external enclosure having... a top surface... defining a cooling air inlet, a cooling air outlet, at least one vent outlet | The LG products have an outer metal casing with vents on the top surface for air intake and exhaust. | ¶¶17-19 | col. 6:40-45 |
| an internal enclosure... defining a cooking cavity within the external enclosure | The LG products contain an internal microwave cooking chamber inside the external casing. | ¶19 | col. 6:40-42 |
| a cooking component area is defined between the first sidewall of the internal enclosure and the external enclosure | Photographs show electronic components (e.g., magnetron, transformers) located to the side of the cooking cavity, within the external enclosure. | ¶19 | col. 2:15-18 |
| a cooling fan disposed within the cooking component area | The complaint's internal photographs of the accused products depict a fan located among the electronic components. | ¶19 | col. 2:18-19 |
| wherein the cooling air flowing along the cooling air path is... directed... through the first air passage... through the cooking cavity... and through the second air passage | The complaint alleges, on information and belief, that air is routed from the top inlet, across the side components, through the cooking cavity, and out the top outlet. | ¶25 | col. 10:2-27 |
| at least one hood fan disposed laterally adjacent to the internal enclosure | Photographs of the accused products' internals show fans located on the sides of the cooking cavity, separate from the alleged cooling fan. | ¶19 | col. 8:36-44 |
’819 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a microwave oven enclosure defining a cooking cavity therein | The LG products contain a primary cooking chamber for microwave cooking. | ¶¶19-20 | col. 15:31-33 |
| a heating system coupled to the microwave oven enclosure, the heating system defining a heating cavity therein | The complaint alleges on information and belief that the accused products contain a secondary system for heating, such as for broiling or warming functions. An internal view of a Type B product shows a complex assembly above the main cavity (Compl. p. 10, top image). | ¶35 | col. 15:34-40 |
| a heating element positioned in the heating cavity... a broiler element positioned within the heating cavity | The complaint alleges the accused products' heating system includes elements for warming and broiling food. | ¶35 | col. 16:25-45 |
| a dual hood system coupled to the microwave hood system | The complaint alleges the accused products contain a ventilation system with distinct left and right venting assemblies, constituting a dual hood system. Internal photographs show fan assemblies on opposing sides of the unit (Compl. p. 9, bottom image). | ¶35 | col. 18:1-11 |
- Identified Points of Contention:
- Scope Questions: For the ’317 patent, a key question may be whether the term "cooling air path" requires air to pass through the main cooking cavity, as opposed to around or over it. For the ’819 patent, a dispute may arise over whether the accused products contain a distinct "heating system" and "dual hood system" as claimed, or if their components are better characterized as a single, integrated microwave and ventilation system.
- Technical Questions: What evidence does the complaint provide that the airflow in the LG products follows the specific multi-stage vertical-horizontal-vertical path required by the ’317 claims? Does the upper assembly in the accused Type B product (Compl. p. 10, top image) function as a "heating system" with broiling capabilities, as required by claim 1 of the '819 patent, or does it serve another purpose?
V. Key Claim Terms for Construction
The Term: "cooling air path" (’317 Patent, Claim 1)
Context and Importance: This term is the central inventive concept for achieving the compact design of the ’317 patent. The infringement analysis will depend entirely on whether the path of cooling air in the accused products meets the specific, multi-stage definition in the claims.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A defendant may argue that any path that moves air from an inlet over components to an outlet for the purpose of cooling constitutes a "cooling air path."
- Evidence for a Narrower Interpretation: The claim itself defines a highly specific sequence: "directed in a first vertical direction through the cooling air inlet... directed in a horizontal direction through the first air passage and through the cooking cavity; directed in a second vertical direction through the second air passage to exit the cooking cavity" (’317 Patent, col. 22:1-13). This language suggests a narrow, step-by-step definition that may be difficult to broaden.
The Term: "dual hood system" (’819 Patent, Claim 1)
Context and Importance: This term is critical for the ’819 patent, as it distinguishes the invention from standard ventilation systems. Infringement will likely depend on whether the accused products' ventilation architecture, which includes fans on opposite sides, can be properly characterized as a "dual hood system."
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue the term simply means a system with two fans or two inlets, a feature present in many over-the-range microwaves.
- Evidence for a Narrower Interpretation: The specification describes the system as comprising a "first venting assembly" and a "second venting assembly" on "opposing sides" of the microwave, which may be construed to require two structurally distinct and separate assemblies rather than just two fans within a single integrated system (’819 Patent, col. 18:5-11).
VI. Other Allegations
- Indirect Infringement: The complaint alleges LG induces infringement by "actively encouraging others" through marketing materials, product manuals, and web pages that promote the sale and use of the accused products (Compl. ¶¶27-28, 37-38).
- Willful Infringement: The complaint alleges willfulness based on LG having knowledge of the patents "at least from the filing of this Complaint" (post-suit knowledge) and also alleges, on information and belief, that LG "knew of the ['317/'819] patent or was willfully blind to its existence" prior to the lawsuit (pre-suit knowledge) (Compl. ¶¶31, 41).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope and structural equivalence: Can the specific architectural elements claimed in the patents, such as the multi-stage "cooling air path" (’317) and the separate "heating system" and "dual hood system" (’819), be construed to read on the integrated component layout of the accused LG products? The case may depend on whether LG's design is found to be a mere colorable variation or a fundamentally different architecture.
- A key evidentiary question will be one of technical operation: Beyond structural similarity, what evidence will demonstrate that the accused products actually function as claimed? Specifically, does the air in the LG products follow the precise vertical-horizontal-vertical trajectory required by the ’317 patent, and do the accused components alleged to be a "broiler element" perform the high-temperature cooking function contemplated by the ’819 patent?