DCT

2:26-cv-00297

Ningbo Moetree Furniture Co Ltd v. SharkNinja Operating LLC

Key Events
Complaint
complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-00297, W.D. Wash., 01/27/2026
  • Venue Allegations: Venue is based on the Defendant’s patent enforcement activities directed at the Plaintiff’s product listings on Amazon.com, which allegedly involved communications and actions by Amazon personnel located in Seattle, Washington.
  • Core Dispute: Plaintiff seeks a declaratory judgment that its air fryer products do not infringe Defendant’s patent related to the structural design of cooking devices, and further alleges that the patent is invalid in light of prior art.
  • Technical Context: The technology relates to countertop cooking appliances, specifically focusing on the mechanical and structural interface between a cooking vessel and its support base or handles.
  • Key Procedural History: This declaratory judgment action was precipitated by an infringement report filed by the Defendant with Amazon, which resulted in the removal of the Plaintiff's product listings from the online marketplace.

Case Timeline

Date Event
2023-08-01 ’739 Patent - Earliest Priority Date
2024-09-12 ’739 Patent - Application Filing Date
2025-09-30 ’739 Patent - Issue Date
2026-01-23 Amazon Issues Takedown Notice to Plaintiff
2026-01-27 Complaint for Declaratory Judgment Filed

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

U.S. Patent No. 12,426,739 - "Cooking Devices and Components Thereof"

  • Patent Identification: U.S. Patent No. 12,426,739, titled “Cooking Devices and Components Thereof,” issued on September 30, 2025 (’739 Patent).

The Invention Explained

  • Problem Addressed: The patent background describes a need for more efficient countertop cooking systems that can integrate both the cooking and subsequent storage of food, addressing the inconvenience of using and cleaning multiple containers '739 Patent, col. 22:1-14
  • The Patented Solution: The invention is a modular cooking system comprising a cooking device (with a heating element and fan) that can be removably placed on top of a separate vessel to form a cooking chamber '739 Patent, Abstract This allows the vessel itself, which can be made of materials like borosilicate glass, to be used for cooking and then sealed with a separate storage lid for transport or storage, improving user convenience '739 Patent, col. 22:1-14 The claims focus on specific structural arrangements of the vessel and its associated base and handles.
  • Technical Importance: This modular approach separates the active heating/air-circulating components from the passive food-holding vessel, aiming to streamline the cook-and-store workflow for consumers. Compl. ¶19-27 ’739 Patent, col. 22:1-23

Key Claims at a Glance

  • The complaint asserts non-infringement of independent claims 1, 7, and 14 (Compl. ¶31, 32, 33).
  • Independent Claim 1: A vessel assembly including:
    • A unitary vessel with a top opening and closed bottom.
    • A U-shaped base fixed to opposed sidewalls of the vessel.
    • The base is configured to rest on a support surface and support the vessel's bottom.
  • Independent Claim 7: A vessel assembly including:
    • A vessel with a cavity and an opening.
    • A handlebar positioned under the vessel.
    • A gap between the vessel wall and the handlebar, configured as a thermal break.
  • Independent Claim 14: A vessel assembly including:
    • A vessel with a sidewall having a first indent and a first detent.
    • A base positioned below the vessel.
    • A flexible connector plate extending from the base with a second indent and a second detent.
    • The first and second detents/indents are configured to interlock when the base is connected to the vessel.
  • The complaint also seeks a declaratory judgment of non-infringement for dependent claims 2-6, 8-13, and 15-23 (Compl. ¶31, 32, 33).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies the accused products as "Plaintiff's Air Fryer products," referencing specific Amazon Standard Identification Numbers (ASINs) B0FSLF4ZK7 and B0FSLF7T1K (Compl. ¶11, 23).

Functionality and Market Context

  • The complaint describes the accused Air Fryer as comprising a vessel and a base with a "continuous peripheral wall that encloses the bottom of the vessel on all sides," which it characterizes as a "receptacle" or "bowl" rather than a bracket Compl. ¶31
  • It alleges the product's handles are attached to the exterior of this base housing and are positioned laterally adjacent to the vessel, not underneath it Compl. ¶32
  • The product's connection mechanism is described as a "protruding lock bolt" on the vessel that engages the handle assembly, which is alleged to be "rigid and non-flexible" Compl. ¶33
  • The complaint notes that Amazon is the Plaintiff's primary sales channel in the United States for these products Compl. ¶14
  • No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement. The following table summarizes the Plaintiff's asserted distinctions between the patent claims and its accused product.

’739 Patent Infringement Allegations

Claim Element (from Independent Claim X) Alleged Non-Infringing Functionality Complaint Citation Patent Citation
(from Claim 1) a U-shaped base fixed to opposed sidewalls of the vessel The accused product’s base is a continuous peripheral wall that encloses the vessel on all four sides, which the Plaintiff argues cannot be "U-shaped" as that term implies openness on two sides. ¶31 col. 40:52-53
(from Claim 7) a handlebar positioned under the vessel The product's handle structures are attached to the exterior of the base housing and are positioned laterally adjacent to the vessel’s sidewalls, with no portion located vertically beneath the vessel’s bottom surface. ¶32 col. 41:15-16
(from Claim 7) a gap ... configured to be a thermal break between the vessel and the handlebar The product employs a structural interface with direct mechanical contact via reinforcing ribs, which is alleged not to be a "gap configured as a thermal break." ¶32 col. 41:19-21
(from Claim 14) a vessel having a cavity therein and a sidewall having a first indent and a first detent positioned thereon The accused product's vessel has a single "protruding lock bolt" (or tongue) and lacks the claimed reciprocal "indent" on the sidewall to receive a corresponding detent from the handle structure. ¶33 col. 42:5-7
(from Claim 14) the connector plate is flexible The relevant structure on the accused product (the handlebar assembly) is described as "rigid and non-flexible." ¶33 col. 42:16

Identified Points of Contention

  • Scope Questions: A central dispute concerns the interpretation of "U-shaped base." The case may explore whether this term is limited to a two-sided bracket structure or if it can be construed to read on a continuous, four-sided housing that performs a similar support function.
  • Technical Questions: Factual questions are raised regarding the physical configuration of the accused product. Specifically, what is the precise location of the handles relative to the vessel (i.e., "laterally adjacent" vs. "under")? Does the presence of reinforcing ribs between the handle and base negate the existence of a "gap configured to be a thermal break"? Does the accused product's "protruding lock bolt" and rigid handlebar assembly meet the claim requirements for a reciprocal, flexible indent-and-detent system?

V. Key Claim Terms for Construction

The Term: "U-shaped base" (Claim 1)

  • Context and Importance: This term is the foundation of the non-infringement argument for Claim 1. The Plaintiff contends its product's fully enclosing, four-sided base is definitionally not "U-shaped." The outcome of the case may depend heavily on the construction of this term.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification does not appear to provide an explicit definition. A party might argue the term should be interpreted functionally to mean a base that attaches to "opposed sidewalls" to support the vessel from below, regardless of whether other sides are enclosed.
    • Evidence for a Narrower Interpretation: The plain and ordinary meaning of "U-shaped" suggests a structure with an open side. This is reinforced by Claim 23, which further specifies that the base is "U-shaped at a vertical cross-section," suggesting a specific structural profile that may not be met by a bowl-like housing ’739 Patent, col. 42:38-40

The Term: "handlebar positioned under the vessel" (Claim 7)

  • Context and Importance: This positional limitation is critical to the non-infringement argument for Claim 7. Practitioners may focus on this term because the Plaintiff alleges its handles are entirely lateral to the vessel, not "under" it.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party could argue "under the vessel" means any position below the top plane or rim of the vessel, which could include laterally-mounted handles.
    • Evidence for a Narrower Interpretation: The common meaning implies a location vertically beneath the main body or bottom surface of the vessel. The complaint makes this argument directly Compl. ¶32 Figures in the patent, such as FIG. 31 showing handlebar (2036), depict a structure located beneath the bottom plane of the vessel (2004).

VI. Other Allegations

The complaint seeks a declaratory judgment that it does not infringe "directly or indirectly" but does not contain specific factual allegations regarding indirect or willful infringement for analysis Compl. ¶34

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

  1. Definitional Scope: A primary issue will be one of claim construction. Can the term "U-shaped base," as described in the patent, be interpreted to cover the accused product's continuous, four-sided housing, or is its meaning restricted to a two-sided, open bracket-like structure?
  2. Structural and Functional Mismatch: Key evidentiary questions will concern factual disputes over the accused product's design. Does the lateral placement of the handles fall outside the scope of being "positioned under the vessel"? And does the product's rigid, single-bolt connection mechanism perform the same function in the same way as the claimed "flexible" connector plate with a reciprocal "indent and detent"?
  3. Validity in View of Prior Art: The complaint presents a substantial challenge to the patent's validity, citing numerous prior art references. A central question for the court will be whether the combination of these references renders the claimed structural arrangements—such as a base "fixed to opposed sidewalls"—obvious to a person of ordinary skill in the art at the time of the invention.