DCT

2:25-cv-00954

Foshan MacJerry Technology Co Ltd v. SharkNinja Operating LLC

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00954, W.D. Wash., 05/19/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Western District of Washington because Defendant submitted its patent infringement complaint to Amazon.com, Inc., which has a place of business in Seattle, constituting a substantial part of the events giving rise to the action.
  • Core Dispute: Plaintiff seeks a declaratory judgment that its slushie machines do not infringe Defendant’s patent related to internal baffles for mixing vessels in frozen drink makers.
  • Technical Context: The technology concerns the mechanical design of mixing vessels for appliances like slushie machines, specifically the use of internal structures (baffles) to control the flow and prevent buildup of the frozen product.
  • Key Procedural History: The action was precipitated by an infringement report Defendant SharkNinja filed with Amazon.com against Plaintiff FSMQ. This notice from Amazon prompted FSMQ to file this declaratory judgment action to resolve the infringement question and prevent its product from being removed from the Amazon marketplace.

Case Timeline

Date Event
2024-01-18 Priority Date for U.S. Patent No. 12,279,629
2025-04-22 U.S. Patent No. 12,279,629 Issued
2025-04-30 Plaintiff receives infringement notice from Amazon.com
2025-05-19 Complaint for Declaratory Judgment Filed

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

  • Patent Identification: U.S. Patent No. 12,279,629, "Mixing Vessel Baffles For A Drink Maker," issued April 22, 2025 (’629 Patent).
  • The Invention Explained:
    • Problem Addressed: The patent addresses deficiencies in existing frozen drink makers, particularly for household units which cannot be very tall. In such compact devices, there is a need for features to effectively control the slushy mixture, preventing it from migrating up the sidewalls or sticking to the top of the chamber, which can lead to poor circulation and waste (’629 Patent, col. 3:51-62).
    • The Patented Solution: The invention is a mixing vessel with at least one, and up to three, specific internal baffles: a "side baffle" extending laterally, a "front baffle" extending across the top-front, and a "corner baffle" positioned at a top corner, which may physically connect the other two (’629 Patent, col. 5:1-15; FIG. 6A). These baffles work together to direct the flow of contents away from the top of the vessel and keep the mixture circulating properly (’629 Patent, col. 14:1-11).
    • Technical Importance: The claimed configuration of baffles is presented as a solution to enable more compact, household-sized frozen drink makers that can still effectively process slush without the large headspace common in commercial models (’629 Patent, col. 3:58-62).
  • Key Claims at a Glance:
    • The complaint identifies independent claims 1, 13, and 20 as being at issue (Compl. ¶18).
    • Independent Claim 1: A mixing vessel comprising:
      • a curved sidewall defining a vessel chamber;
      • a corner baffle positioned at the front and the top of the vessel chamber... configured to direct slush flow; and
      • a front baffle positioned at the front of the vessel chamber extending from the left side toward the right side across the top.
    • Independent Claim 13: A mixing vessel comprising the elements of claim 1 but also requiring a "side baffle extending laterally."
    • Independent Claim 20: A frozen drink maker system comprising a mixing vessel with "at least two internal baffles" including a "front baffle."
    • The complaint seeks a declaration of non-infringement for all claims, which includes the dependent claims (Compl. ¶28).

III. The Accused Instrumentality

  • Product Identification: The accused instrumentality is Plaintiff’s "slushie machines" (the "Accused Product") sold on Amazon under the FSMQ brand (Compl. ¶¶19, 21).
  • Functionality and Market Context:
    • The complaint describes the Accused Product as employing a "distinct design" that does not incorporate the baffle configurations of the ’629 Patent (Compl. ¶22).
    • A visual provided in the complaint shows the Accused Product's mixing vessel, which contains what Plaintiff identifies as a "side baffle" and "mold-release beveled edge[s]" (Compl., p. 7, Chart 1). This side-by-side comparison of the patent figure and a photo of the Accused Product is the primary evidence offered to show the product's distinct, non-infringing structure (Compl., p. 7, Chart 1).
    • The complaint alleges that the Amazon marketplace is Plaintiff's "primary sales channel in the United States," making the threat of removal due to the infringement notice a source of "immediate and irreparable harm" (Compl. ¶¶9, 12).

IV. Analysis of Infringement Allegations

The complaint asserts non-infringement of claims 1, 13, and 20, stating the Accused Product fails to meet one or more elements of each (Compl. ¶18). The core of the non-infringement argument is that the Accused Product lacks both the claimed "front baffle" and "corner baffle" (Compl. ¶23). The complaint references an "Exhibit C for detailed non-infringement contentions," but this exhibit was not attached to the filed complaint (Compl. ¶25).

  • ’629 Patent Infringement Allegations
Claim Element (from Independent Claim 1) Alleged Non-Infringing Functionality (Plaintiff's Position) Complaint Citation Patent Citation
a curved sidewall defining a vessel chamber therein, wherein the vessel chamber includes a front, a rear, a right side, a left side, and a top The complaint does not dispute this element. The provided photograph of the Accused Product depicts a vessel with a generally curved sidewall (Compl., p. 7, Chart 1). ¶19 col. 16:26-29
a corner baffle positioned at the front and the top of the vessel chamber on either the right side or the left side... Plaintiff alleges its Slushie Machine "lacks the claimed 'corner baffle'" (Compl. ¶23). ¶23 col. 16:30-34
a front baffle positioned at the front of the vessel chamber extending from the left side toward the right side across the top Plaintiff alleges its Slushie Machine "at least lacks the 'front baffle' limitation" (Compl. ¶23). The complaint identifies this structure as a "mold-release beveled edge" (Compl., p. 7, Chart 1). ¶23 col. 16:35-38
  • Identified Points of Contention:
    • Scope Questions: A central dispute will be whether the structures identified by Plaintiff as "mold-release beveled edge[s]" in its product (Compl., p. 7, Chart 1) fall within the scope of the terms "front baffle" and "corner baffle" as recited in the claims. The case raises the question of whether a feature with a manufacturing purpose (mold release) can also meet the structural and functional requirements of a claimed baffle.
    • Technical Questions: Does the Accused Product's "mold-release beveled edge" perform the function recited in the patent for the baffles, namely to "direct slush flow" and "urge contents away from the top surface of the vessel chamber" (’629 Patent, col. 16:33-34, col. 14:1-4)? The complaint provides no functional analysis, relying instead on structural distinctions.

V. Key Claim Terms for Construction

  • The Term: "front baffle"

  • Context and Importance: This term is recited in all asserted independent claims (1, 13, and 20) and is a primary basis for Plaintiff's non-infringement argument (Compl. ¶23). The court's construction of this term will be critical to determining whether the "mold-release beveled edge" in the Accused Product is an infringing structure.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The patent states the front baffle is "configured to urge contents away from the top surface of the vessel chamber" and "reduces the amount of frozen material that could otherwise form on the top front interior surface" (’629 Patent, col. 14:1-6). Defendant may argue that any structure at the claimed location performing this function meets the definition.
    • Evidence for a Narrower Interpretation: The specification describes the front baffle as forming an angle of "100°-150°" relative to the front face of the vessel chamber and potentially connecting to the side baffle via a corner baffle (’629 Patent, col. 13:55-58, col. 14:7-11). Plaintiff may argue these more specific geometric and relational characteristics are required limitations not present in its product.

  • The Term: "corner baffle"

  • Context and Importance: This term appears in independent claims 1 and 13 and is also explicitly identified by Plaintiff as a feature its product lacks (Compl. ¶23). Its construction is central to the infringement analysis for those claims.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The patent claims a corner baffle "configured to direct slush flow" and describes it as being positioned "at a front top side of the vessel chamber" (’629 Patent, col. 5:6-7, col. 16:32-33). Defendant could argue this is a broad functional and locational definition.
    • Evidence for a Narrower Interpretation: The specification describes the corner baffle as a structure that "physically joins the side baffle to the front baffle" and has a "convex" curved surface (’629 Patent, col. 14:12-13, col. 14:22). Plaintiff will likely argue that its product, which it alleges lacks a front baffle, cannot have a structure that "joins" a side baffle to a non-existent front baffle.

VI. Other Allegations

The complaint does not provide sufficient detail for analysis of other allegations.

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

This declaratory judgment action appears to hinge on a classic claim construction dispute, focused on the structural and functional identity of features in the accused device.

  1. A core issue will be one of definitional scope: Can the terms "front baffle" and "corner baffle," described in the patent as specific functional components for directing slush flow, be construed to cover structures that the Plaintiff identifies as "mold-release beveled edges" with a purported manufacturing purpose?

  2. A key evidentiary question will be one of structural and functional comparison: Assuming a claim construction is reached, what evidence will demonstrate whether the accused product's internal geometry performs the specific functions of directing, redirecting, and controlling slush flow in the manner required by the patent's claims and described in its specification? The resolution will depend on whether the accused structures are found to be equivalent, in form and function, to the claimed baffles.