DCT

2:25-cv-01137

Whirlpool Corp v. Samsung Electronics Co Ltd

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: Whirlpool Corp. v. Samsung Electronics Co., Ltd., 2:25-cv-01137, E.D. Tex., 11/18/2025
  • Venue Allegations: Plaintiff asserts venue is proper as to Samsung Electronics Co., Ltd. because it is a foreign entity. Venue is alleged to be proper as to Samsung Electronics America, Inc. on the basis that it maintains a regular and established place of business within the Eastern District of Texas, with specific corporate offices and facilities cited in Plano and Frisco, Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s low-profile microwave hood combination appliances infringe five U.S. patents related to space-saving component layouts and ventilation systems.
  • Technical Context: The market for over-the-range appliances combines microwave cooking with cooktop ventilation, where the overall vertical height of the unit is a critical design constraint and a key competitive differentiator.
  • Key Procedural History: The complaint alleges that Defendant had pre-suit knowledge of the asserted patent family, citing a Canadian patent application filed by Samsung on October 1, 2017, that references the family as prior art; this allegation forms the basis for a claim of willful infringement.

Case Timeline

Date Event
2016-04-12 Earliest Priority Date for all Asserted Patents
2017-10-01 Samsung files Canadian patent application citing the asserted patent family
2021-08-03 U.S. Patent No. 11,079,118 Issued
2024-05-07 U.S. Patent No. 11,979,967 Issued
2024-09-24 U.S. Patent No. 12,101,865 Issued
2024-10-29 U.S. Patent No. 12,133,317 Issued
2025-04-29 U.S. Patent No. 12,289,819 Issued
2025-11-18 Complaint Filed

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

U.S. Patent No. 11,079,118 - Combination Microwave and Hood System

The Invention Explained

  • Problem Addressed: The patent’s background section describes that conventional combination microwave and ventilation hood systems have a "significant overall vertical dimension," which can restrict access to the cooking regions of the range below (ʼ118 Patent, col. 1:23-32).
  • The Patented Solution: The invention achieves a "low-profile" design with a reduced vertical height by relocating key components. Specifically, one or more ventilation fans are disposed on the "lateral sides" of the microwave cooking cavity, rather than in the traditional position above or behind it, thereby saving vertical space (ʼ118 Patent, col. 7:49-65; Fig. 8).
  • Technical Importance: This architectural change allows a combination microwave and hood to be installed in spaces previously only large enough for a standalone ventilation hood, expanding the potential market for such dual-function appliances (ʼ118 Patent, col. 4:58-65).

Key Claims at a Glance

  • The complaint asserts claims 1-5 and 18, with independent claim 1 detailed as an example (Compl. ¶¶28-29).
  • The essential elements of independent claim 1 include:
    • An external enclosure with a base plate defining first and second vent inlets.
    • A cooking cavity defined within the enclosure.
    • A first vent fan disposed on a "first lateral side of the cooking cavity" and in fluid communication with the first vent inlet.
    • A second vent fan disposed on a "second lateral side of the cooking cavity" and in fluid communication with the second vent inlet.
  • The complaint reserves the right to assert dependent claims (Compl. ¶28).

U.S. Patent No. 11,979,967 - Combination Microwave and Hood System

The Invention Explained

  • Problem Addressed: Similar to the ’118 Patent, this patent addresses the technical challenge of building a compact, low-profile microwave hood combination by efficiently arranging internal components (’967 Patent, col. 1:46-54).
  • The Patented Solution: The patent claims a specific configuration that includes not only laterally-disposed hood fans for ventilation but also a distinct cooling fan with a specific airflow path. This path directs cooling air vertically through an inlet, then "through the cooking cavity," then vertically through the top surface of the cavity, and finally out through a cooling air outlet, providing a defined route for cooling internal electronics (’967 Patent, col. 22:49-67, Claim 1).
  • Technical Importance: The claimed solution provides a specific method for cooling heat-sensitive electronics within a tightly constrained, low-profile appliance architecture, a critical consideration for product reliability and performance.

Key Claims at a Glance

  • The complaint asserts claims 1-5 and 7-23, with independent claim 1 detailed as an example (Compl. ¶¶39-40).
  • The essential elements of independent claim 1 include:
    • An external enclosure with top, bottom, and side portions.
    • A hood assembly with first and second hood fans disposed between the cooking cavity and the first and second side portions, respectively.
    • A "cooling fan" that is distinct from the hood fans.
    • The cooling fan is configured to direct air along a specific path: vertically through a cooling air inlet, "through the cooking cavity," vertically through the top surface of the cavity, and out a cooling air outlet.
  • The complaint reserves the right to assert dependent claims (Compl. ¶39).

Multi-Patent Capsule: U.S. Patent No. 12,101,865

  • Patent Identification: U.S. Patent No. 12,101,865, titled “Combination Microwave and Hood System,” issued September 24, 2024 (’865 Patent).
  • Technology Synopsis: Continuing the same theme of a low-profile appliance, this patent claims a system with a specific component architecture. The claims focus on the spatial relationship and airflow connections between dual hood fans, a separate cooling fan, and the cooking cavity, all arranged to achieve a reduced vertical dimension (Compl. ¶23; ’865 Patent, Abstract).
  • Asserted Claims: Claims 1-21 are asserted, with independent claim 1 cited as an example (Compl. ¶50).
  • Accused Features: The "Type B Accused Products" are alleged to infringe by incorporating the claimed component layout and ventilation structure (Compl. ¶50).

Multi-Patent Capsule: U.S. Patent No. 12,133,317

  • Patent Identification: U.S. Patent No. 12,133,317, titled “Combination Microwave and Hood System,” issued October 29, 2024 (’317 Patent).
  • Technology Synopsis: This patent describes a microwave oven with a specific cooling air path defined by passages through the sidewall and top wall of the internal cooking cavity. The claims are directed at the structure enabling a cooling fan to direct air through the cooking component area and then through the cooking cavity itself via these defined passages (’317 Patent, Abstract).
  • Asserted Claims: Claims 1-6 and 8 are asserted, with independent claim 1 cited as an example (Compl. ¶61).
  • Accused Features: Both "Type A and Type B Accused Products" are alleged to infringe by incorporating the claimed internal structure and cooling airflow path (Compl. ¶61).

Multi-Patent Capsule: U.S. Patent No. 12,289,819

  • Patent Identification: U.S. Patent No. 12,289,819, titled “Combination Microwave and Hood System,” issued April 29, 2025 (’819 Patent).
  • Technology Synopsis: This patent claims a microwave hood system that includes both a standard microwave oven and a secondary "heating system" with a broiler element. The invention integrates these dual cooking functionalities with a dual hood ventilation system, all within a compact form factor (’819 Patent, Abstract; Compl. ¶25).
  • Asserted Claims: Claims 1-23, 25-26, and 28-30 are asserted, with independent claims 1 and 30 cited as examples (Compl. ¶72).
  • Accused Features: Both "Type A and Type B Accused Products" are alleged to infringe by incorporating the claimed combination of microwave, secondary heating, and ventilation systems (Compl. ¶72).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies two categories of accused products: "Type A Accused Products" (e.g., SKU ME11CB751012) and "Type B Accused Products" (e.g., SKU ME11A7710DS) (Compl. ¶18).

Functionality and Market Context

  • The accused products are over-the-range microwave ovens marketed by Samsung for their compact, "low profile" design (Compl. ¶17). The complaint includes a screenshot from Samsung's marketing materials that advertises a "New Low profile, high performance" microwave, which Plaintiff alleges is a term it coined (Compl. ¶17). The complaint also provides photographs from teardowns of both Type A and Type B products, showing their internal component layouts, including fans and other electronics (Compl. ¶¶19-20). These images appear to form a core part of the factual basis for the infringement allegations (Compl. ¶¶19, 20).

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits for each asserted patent (Exhibits F-L) that were submitted with the filing but are not included in the provided document (Compl. ¶¶29, 40, 51, 62, 73). Therefore, the infringement allegations are summarized below in prose based on the complaint's narrative.

  • ’118 Patent Infringement Allegations
    The complaint alleges that the Type B Accused Products directly infringe at least Claim 1 of the ’118 patent (Compl. ¶¶28-29). The narrative theory of infringement is that these products achieve their low-profile design by incorporating the core invention: a ventilation system with fans placed on the lateral sides of the cooking cavity. The complaint points to its internal photographs of a Type B product as evidence of this allegedly infringing configuration (Compl. ¶20).

  • ’967 Patent Infringement Allegations
    The complaint alleges that the Type B Accused Products directly infringe at least Claim 1 of the ’967 patent (Compl. ¶¶39-40). The infringement theory for this patent appears to focus on both the laterally-disposed hood fans and the specific airflow path of a separate cooling fan. The complaint alleges the accused products' cooling systems direct air through the cooking cavity in the manner required by the claim, again citing internal photographs as evidence (Compl. ¶20).

  • Identified Points of Contention:

    • Scope Questions: The dispute may center on the construction of "disposed... on a... lateral side of the cooking cavity" (’118 Patent, Claim 1). A question for the court will be whether this requires the fan to be located entirely beside the cavity, as depicted in certain patent figures, or if it can be construed more broadly to cover configurations where the fan is partially behind or above the cavity but still generally to the side.
    • Technical Questions: A key technical question for the ’967 patent will be whether the accused products' cooling systems actually use the cooking cavity as an intentional part of the cooling airflow path. The analysis will likely require evidence demonstrating the specific function and route of cooling air, distinguishing it from incidental air exchange or the separate ventilation path of the hood fans.

V. Key Claim Terms for Construction

  • The Term: "disposed... on a... lateral side of the cooking cavity" (from ’118 Patent, Claim 1)

  • Context and Importance: This term is the central structural limitation of the ’118 patent's primary independent claim and defines the main point of novelty for achieving the low-profile design. The infringement determination will likely depend heavily on how this spatial relationship is defined.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification states generally that "one or more hood fans may be located on lateral sides of cooking cavity 34 to both minimize the vertical dimension" (’118 Patent, col. 7:49-52). This language suggests a functional goal rather than a precise geometric constraint, which could support a broader reading.
    • Evidence for a Narrower Interpretation: The patent’s primary embodiment illustrating this concept, Figure 8, shows the hood fan (74) positioned in a clear side-by-side arrangement with the cooking cavity (34). A party may argue this specific depiction limits the scope of "lateral side" to configurations that are strictly adjacent and not partially overlapping in the vertical or depth dimensions.

  • The Term: "a cooling fan... configured to direct air... through the cooking cavity" (from ’967 Patent, Claim 1)

  • Context and Importance: This limitation defines a specific functional path for cooling air that is distinct from the ventilation function. Practitioners may focus on this term because infringement depends not just on component location but on the operational path of airflow in the accused devices.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification describes and illustrates cooling air (94) passing "across cooking cavity 34" via specific passages on its surface (’118 Patent, col. 9:30-34, Fig. 16). This could be interpreted to mean any directed path that uses the volume of the cavity for transit.
    • Evidence for a Narrower Interpretation: A party may argue that "through the cooking cavity" requires the air to enter via one defined passage and exit via another, as shown in Figure 16 (passages 96, 98), and that incidental airflow into an open cavity from a nearby fan does not meet this functional requirement.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges Samsung induces infringement by providing marketing materials, product manuals, and websites that instruct and encourage customers to use the accused products in an infringing manner (Compl. ¶¶30-31, 41-42, 52-53, 63-64, 74-75).
  • Willful Infringement: The complaint alleges willful infringement based on both post-suit notice and alleged pre-suit knowledge. The basis for pre-suit knowledge is an allegation that Samsung Electronics Co., Ltd. filed a Canadian patent application in 2017 that cited the asserted patents' family as prior art (Compl. ¶¶33, 44, 55, 66, 77).

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

This dispute appears to center on allegations that Samsung adopted the core space-saving architecture of Whirlpool's patented low-profile microwaves. The case will likely turn on the following central questions:

  • A core issue will be one of structural scope: can the term "lateral side of the cooking cavity," which is central to the asserted patents, be construed to read on the specific internal geometry of Samsung’s accused products, or will evidence show a meaningful structural difference that places the products outside the claims' boundaries?
  • A key evidentiary question will be one of functional airflow: does the cooling system in Samsung's products operate by directing air "through the cooking cavity" as an intentional part of its design, as required by claims in patents like the ’967 patent, or does it follow a separate path, making any interaction with the cavity incidental?
  • Beyond the technical merits, a critical question for damages will be willful blindness: does Samsung's alleged 2017 citation of the patent family as prior art constitute pre-suit knowledge of the technology, potentially exposing the company to a finding of willfulness and enhanced damages if infringement is found?