DCT

2:23-cv-00845

Anova Applied Electronics Inc v. Inkbird Tech C L

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:23-cv-00845, W.D. Wash., 06/06/2023
  • Venue Allegations: Venue is alleged based on Defendants’ business dealings with Amazon.com, which is headquartered in Seattle, and the offering for sale and sale of accused products to customers within the State of Washington. As the defendants are not U.S. residents, venue is also alleged to be proper in any judicial district.
  • Core Dispute: Plaintiff alleges that Defendants’ "Inkbird Precision Cooker" line of sous-vide immersion circulators infringes a patent related to the mechanical design and functional layout of such devices.
  • Technical Context: The technology is in the field of sous-vide immersion circulators, a consumer kitchen appliance category that enables precise, low-temperature cooking by heating and circulating a water bath.
  • Key Procedural History: The complaint notes that the asserted patent was assigned to Plaintiff Anova Applied Electronics, Inc. on February 13, 2018. No other significant procedural events are mentioned.

Case Timeline

Date Event
2013-09-20 Priority Date for U.S. Patent No. 10,455,967
2019-10-29 U.S. Patent No. 10,455,967 Issued
2021-10-04 Anova alleges purchase of an Accused Product for analysis
2023-06-06 Complaint Filed

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

U.S. Patent No. 10,455,967 - “Circulator Cooker”

  • Patent Identification: U.S. Patent No. 10455967, titled “Circulator Cooker,” issued on October 29, 2019.

The Invention Explained

  • Problem Addressed: The patent background suggests that prior sous-vide circulators were often designed like "scientific equipment," implying they were not optimized for home kitchen use (’967 Patent, col. 1:33-37).
  • The Patented Solution: The invention describes a sous-vide circulator cooker with a specific three-part modular construction: a "head portion" with a display, a "middle portion" containing the pump motor, and a lower, immersible portion that houses the heating element, water intake, and a pump housing with a water outlet (’967 Patent, col. 6:25-47). A key claimed feature is that the pump housing at the bottom of the device is rotatable, allowing the user to direct the flow of circulated water (’967 Patent, col. 19:50-54).
  • Technical Importance: The design appears aimed at creating a more ergonomic and functionally flexible device specifically for the consumer "home sous-vide cooking" market, as opposed to commercial or laboratory settings (’967 Patent, col. 2:55-59).

Key Claims at a Glance

  • The complaint asserts infringement of at least independent claim 1 (Compl. ¶31).
  • The essential elements of independent claim 1 include:
    • A head portion comprising a display.
    • A middle portion extending from the head portion, containing a pump motor.
    • A lower portion extending from the middle portion, which comprises:
      • a skirt with liquid intake openings.
      • a heating element inside the skirt.
      • a pump housing at the distal end of the skirt, with an outlet opening oriented away from the device's longitudinal axis.
      • The pump housing is "rotatable about the longitudinal axis to a plurality of different positions."
    • A pump impeller inside the housing, connected to the motor, which generates a flow of liquid from the intake, past the heater, and out through the outlet. (Compl. ¶29).

III. The Accused Instrumentality

Product Identification

The "Inkbird Precision Cooker" products, specifically models ISV-100W and ISV-200W (the "Accused Products") (Compl. ¶¶ 11, 24).

Functionality and Market Context

The Accused Products are WiFi-enabled sous-vide immersion circulators sold online in the United States through retailers like Amazon.com and directly from the Defendants’ website (Compl. ¶¶ 19, 21, 32). An Amazon.com product listing for the "Inkbird WIFI Sous Vide Machine ISV-100W" shows the device's external appearance and lists its features (Compl. p. 17). The complaint alleges that the two accused models are "structurally identical enough to directly infringe the '967 Patent for nearly the same reasons" (Compl. ¶31).

IV. Analysis of Infringement Allegations

The complaint does not contain the referenced claim chart exhibit (Ex. 10). The following chart summarizes the infringement allegations for Claim 1 based on the recitation of the claim in the complaint and the general allegations of infringement against the Accused Products.

’967 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a head portion comprising a display The top portion of the Accused Products, which contains the user interface and display screen for setting time and temperature ¶¶29, 31 col. 6:33-39
a middle portion extending along a longitudinal axis from the head portion and having a pump motor therein The central cylindrical body of the Accused Products, which is alleged to contain the pump motor ¶¶29, 31 col. 6:48-51
a lower portion extending along the longitudinal axis from the middle portion...the lower portion comprising: a skirt having...one or more liquid intake openings passing therethrough The immersible bottom section of the Accused Products, which includes a removable sheath or skirt with slots for water intake ¶¶29, 31 col. 6:51-53
a heating element located within the skirt A heating coil alleged to be located inside the immersible lower portion of the Accused Products ¶¶29, 31 col. 19:44-45
a pump housing attached at the distal end of the skirt...the pump housing having an outlet opening passing therethrough, wherein the outlet opening is oriented away from the longitudinal axis, and the pump housing is rotatable about the longitudinal axis... The structure at the bottom of the Accused Products that allegedly encloses the pump impeller and directs water flow outward in a manner that can be rotated ¶¶29, 31 col. 19:46-54
a pump impeller rotatably mounted within the pump housing and operatively connected to the pump motor, the pump impeller being configured to selectively generate a flow of liquid... The component within the Accused Products' lower section that is driven by the motor to circulate water through the device ¶¶29, 31 col. 19:55-67

Identified Points of Contention

  • Technical Questions: The complaint makes a blanket allegation of infringement but provides no specific evidence showing that the Accused Products meet certain key functional limitations. This raises the question: what evidence demonstrates that the accused Inkbird cookers' "pump housing is rotatable about the longitudinal axis" and that their "outlet opening is oriented away from the longitudinal axis" as required by claim 1? The publicly available product information cited in the complaint does not appear to address these specific features.
  • Scope Questions: The dispute may turn on the scope of the structural elements. For example, does the accused product's physical construction map onto the claimed three-part structure of a "head portion," "middle portion," and "lower portion" containing a "skirt" and a "pump housing" as distinct, identifiable components?

V. Key Claim Terms for Construction

Term: "pump housing is rotatable about the longitudinal axis"

  • Context and Importance: This limitation appears to be a key feature distinguishing the invention from a simple, fixed-flow circulator. Infringement will depend heavily on whether the accused product’s pump housing can, in fact, be rotated to change the direction of water flow. Practitioners may focus on this term because it describes a specific, verifiable function that may not be present in all consumer sous-vide devices.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification suggests this feature is for user convenience, allowing an operator to "angle or rotate the entire system to vector or angle the pump output or to turn the system for better display viewing angle" (’967 Patent, col. 2:51-55). A plaintiff might argue this supports a broad reading that covers any mechanism allowing the direction of flow to be changed relative to the cooking vessel.
    • Evidence for a Narrower Interpretation: Claim 1 specifically requires the pump housing itself to be rotatable. A defendant could argue this is limited to embodiments where the housing component at the distal end of the device rotates independently of the middle and head portions, as opposed to the entire device rotating within a mounting clamp. The language "rotatable about the longitudinal axis to a plurality of different positions relative to one or more other portions of the sous-vide circulator cooker" may support this narrower reading (’967 Patent, col. 19:51-54).

Term: "outlet opening is oriented away from the longitudinal axis"

  • Context and Importance: This term dictates the direction of the circulated water. Its construction is critical because if the accused device ejects water straight down (parallel to the axis), it may not infringe. The geometry of the water flow is a central aspect of the claimed device's operation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: "Away from" could be argued to mean any vector that is not perfectly parallel with the longitudinal axis, thereby covering side-facing or angled outlets.
    • Evidence for a Narrower Interpretation: The term implies a directional, non-axial flow. A defendant might argue that an outlet on the bottom of the device, which ejects water downwards, directs flow along the axis (albeit in the opposite direction of the head) rather than "away from" it. The patent states the outlet opening passes "therethrough," which, when read with "oriented away from the longitudinal axis," suggests a side-wall opening rather than a bottom opening (’967 Patent, col. 19:49-51).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement.
    • Inducement is alleged based on Defendants actively and knowingly encouraging infringement, including by providing guidance to customers on how to use the accused products via an online community forum on Facebook (Compl. ¶¶ 23, 36).
    • Contributory infringement is alleged on the basis that Defendants sell and import components of the Accused Products that are a material part of the invention and are not staple articles of commerce suitable for substantial non-infringing use (Compl. ¶38).
  • Willful Infringement: The complaint alleges that Defendants "have known of the existence of the '967 Patent" and that their infringement has been willful, knowing, and intentional (Compl. ¶¶ 39, 40). The complaint does not, however, allege a specific factual basis for this knowledge, such as a notice letter or prior litigation.

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

  1. A central issue will be one of claim construction and scope: can the phrase "pump housing is rotatable about the longitudinal axis" be construed to read on the accused Inkbird cookers? The case may depend on whether this requires an independently rotating component, a feature not apparent from the complaint's evidence, or if it can be satisfied by a less specific functionality.
  2. The case will also present a key evidentiary question: beyond the general structural similarities, what specific proof will Plaintiff offer to demonstrate that the Accused Products perform the claimed functions, particularly the rotation of the pump housing and the orientation of the water outlet "away from the longitudinal axis"? The resolution of the infringement claim will likely depend on a detailed technical comparison that is not yet present in the initial pleadings.