Conair LLC v. Tehrani Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Conair LLC (Delaware)
  • Defendant: Tehrani Corp d/b/a Supreme (California)
  • Plaintiff's Counsel: VITALE, VICKREY, NIRO, SOLON & GASEY LLP; THE KNEAFSEY FIRM, INC.
• Case Identification: 2:26-cv-06756, C.D. Cal., 06/22/2026
• Venue Allegations: Venue is alleged in the Central District of California based on Defendant allegedly committing acts of infringement and maintaining a regular and established place of business within the district.
• Core Dispute: Plaintiff alleges that Defendant's line of professional hair trimmers, marketed as "Supreme Zero Gap Products," infringes a patent related to a system for adjusting the gap between trimmer blades without removing the blade assembly from the device.
• Technical Context: The technology addresses a need in the professional hair styling market for trimmers that allow for quick and precise adjustment of the blade gap to achieve a "zero gap" or very close cut, an operation that was historically cumbersome.
• Key Procedural History: The complaint alleges that Plaintiff provided Defendant with a detailed notice letter on June 13, 2024, which identified the patent-in-suit and included claim charts analyzing the alleged infringement. This pre-suit notice forms the basis for the willfulness allegation.

Case Timeline

Date	Event
2019-05-31	'017 Patent Priority Date
2021-08-31	'017 Patent Issue Date
2024-06-13	Plaintiff sent notice letter to Defendant
2026-06-22	Complaint Filing Date

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

U.S. Patent No. 11,104,017 - "Hair Cutter Blade Gap Adjustment System"

Patent Identification: U.S. Patent No. 11,104,017, issued August 31, 2021.

The Invention Explained

• Problem Addressed: The patent's background section describes deficiencies in conventional hair clippers where adjusting the "gap" between the cutting and stationary blades required physically removing the blade assembly from the handle, an operation described as often proving difficult and potentially resulting in misalignment of the blades '017 Patent, col. 1:25-39 Compl. ¶3
• The Patented Solution: The invention is a hair cutting system that allows the blade gap to be adjusted while the blade assembly remains mounted to the handle '017 Patent, col. 2:44-48 This is achieved through a "strut" that spaces the blade assembly away from the handle, creating sufficient clearance for an operator to access "alignment fasteners" (e.g., screws) to adjust the relative position of the movable blade '017 Patent, col. 6:3-11 '017 Patent, abstract The design aims to facilitate direct, linear movement of the blade to ensure a consistent, aligned cut '017 Patent, col. 6:31-39
• Technical Importance: The patented solution simplified a critical adjustment for professional barbers, allowing them to easily and precisely set a "zero gap" for very close shaves without disassembling the trimmer Compl. ¶4

Key Claims at a Glance

• The complaint asserts independent claim 15.
• The essential elements of independent claim 15 include:
  • A handle including a rotating shaft.
  • A hair cutting blade assembly that includes a fixed strut, a stationary blade, and a movable blade.
  • The movable blade is coupled to the rotating shaft for reciprocal movement and is also movable relative to the stationary blade along the longitudinal axis to adjust the distance (gap) between their blade edges.
  • One or more alignment fasteners to releasably secure the movable blade at a selected position.
  • A "wherein" clause requiring the strut to be configured to space the blade assembly from the handle to "facilitate access to the one or more fasteners without requiring removal of the cutting blade assembly from the handle." Compl. ¶30 '017 Patent, col. 9:1-35
• The complaint also asserts dependent claims 16, 17, 18, and 19 and reserves the right to assert additional claims Compl. ¶31

III. The Accused Instrumentality

Product Identification

The accused products are the T-SHAPER, the RECHARGE, the DARKSTAR, and the VADER models, collectively referred to as the "Supreme Zero Gap Products" Compl. ¶6

Functionality and Market Context

The accused products are professional hair trimmers that feature a "Zero Gap T-Blade" Compl. ¶10 The complaint alleges these products are marketed with the ability to be adjusted to a "0 gap" Compl. p. 14 The core accused functionality is the system that allegedly allows users to loosen screws, adjust the blade position, and retighten the screws to set the desired gap, all while the blade assembly remains attached to the trimmer handle Compl. ¶39 Compl. p. 15 The complaint includes a photograph of one of the accused products being adjusted with a screwdriver to illustrate this functionality Compl. p. 3

IV. Analysis of Infringement Allegations

'017 Patent Infringement Allegations

Claim Element (from Independent Claim 15)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a handle defining a longitudinal axis, the handle including a rotating shaft	The body of the accused trimmers, which houses a motor with a rotating shaft. The complaint provides an annotated photo identifying these components.	¶32	col. 3:41-44
a fixed strut configured for securement to the handle and extend outwardly therefrom	A fixed component that connects the blade assembly to the handle. An annotated photograph points to this structure on the accused product.	¶34	col. 4:45-50
a stationary blade defining cutting teeth having blade edges, the stationary blade secured to the strut	The fixed blade of the accused trimmer's blade assembly, which is secured to the alleged strut.	¶35	col. 4:57-59
a movable blade... movable relative to each other in a direction relative to the longitudinal axis... to selectively vary a distance between the blade edges...	The reciprocating cutting blade, which is alleged to be adjustable relative to the stationary blade to create a "Zero gap" or a larger "Gap," as shown in photographs.	¶37	col. 4:57-65
one or more alignment fasteners to releasably secure the movable blade at a plurality of select positions relative to the stationary blade	Screws on the blade assembly that, when loosened, permit adjustment of the movable blade and, when tightened, secure it in place.	¶38	col. 2:22-24
wherein the strut is configured to space the cutting blade assembly relative to the handle along the longitudinal axis to facilitate access to the one or more fasteners without requiring removal of the cutting blade assembly from the handle	The structure of the accused trimmer, which allegedly positions the blade assembly and its fasteners away from the main handle, allowing a tool to access the screws. A photograph shows a screwdriver accessing these screws.	¶39	col. 6:3-11

Identified Points of Contention

• Scope Questions: The infringement analysis may turn on the construction of the term "fixed strut." The patent's figures depict the strut as a discrete component '017 Patent, Fig. 9, whereas the complaint's allegations appear to identify an integrated part of the accused trimmer's housing as the "strut" Compl. ¶34 This raises the question of whether an integral housing element falls within the scope of the claimed "strut."
• Technical Questions: The patent describes a system that ensures "direct linear movement" of the movable blade, preventing it from "tilting, angulating, rotating etc." during adjustment '017 Patent, col. 6:31-35 A key factual question will be whether the accused products' adjustment mechanism provides this same controlled linear movement, or if it simply allows for a less constrained adjustment that may not meet the specific functional requirements described in the patent's specification.

V. Key Claim Terms for Construction

The Term: "fixed strut"

• Context and Importance: This term is central to the claimed structure that enables the invention's primary benefit: tool access for adjustment without disassembly. The dispute may hinge on whether the part identified on the accused products qualifies as a "strut." Practitioners may focus on this term because the accused products appear to use an integral part of the housing, whereas the patent specification heavily features figures showing a distinct, separate component.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim requires a "fixed strut configured for securement to the handle" '017 Patent, col. 9:5-6 Plaintiff may argue this is functional language that does not require a separate component, only a fixed structure that performs the claimed spacing and securement functions. The specification notes the strut is "directly mounted to the handle" '017 Patent, col. 4:45-46, which does not explicitly forbid an integral construction.
  • Evidence for a Narrower Interpretation: The detailed description and, most notably, the exploded-view Figure 9, consistently depict the strut (46) as a standalone component assembled between the handle (16) and the blade assembly (18) '017 Patent, Fig. 9 Defendant may argue that this consistent depiction limits the term's scope to a structurally separate element, distinguishing it from a molded, integral piece of a larger housing.

The Term: "alignment fasteners"

• Context and Importance: This term defines the mechanism used to lock the blade's position after adjustment. The complaint identifies simple screws on the accused products as meeting this limitation Compl. ¶38 The validity of this assertion depends on the proper construction of the term.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language is broad, referring to "one or more alignment fasteners" '017 Patent, col. 9:21 The specification provides an example, stating the "alignment fastener may include an alignment screw" '017 Patent, col. 2:22-24, suggesting that screws are a contemplated embodiment but not necessarily the only one. This supports reading the term broadly to cover the screws on the accused products.
  • Evidence for a Narrower Interpretation: Defendant could argue that the term must be read in the full context of the patent's described embodiment, which includes not just screws (84) but also a "slider" (60) and "threaded anchors" (82) that form a more complex adjustment system '017 Patent, col. 5:15-24 This could support an argument that "alignment fasteners" refers to this entire system, not merely the screws in isolation.

VI. Other Allegations

Willful Infringement

The complaint alleges that Defendant's infringement was and continues to be willful Compl. ¶45 The basis for this allegation is Defendant's alleged knowledge of the '017 Patent since at least June 13, 2024, the date Plaintiff allegedly sent a "detailed notice letter" including "claim charts and an analysis comparing the accused products to the asserted patent claims" Compl. ¶43

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

• A core issue will be one of definitional scope: can the term "fixed strut," which the patent's figures consistently depict as a discrete component, be construed to cover the seemingly integrated housing portion of the accused trimmers that serves a similar spacing function?
• A second central issue will be one of functional infringement: does the accused products' adjustment mechanism, which appears to rely on loosening and tightening screws, perform the adjustment in substantially the same way as the patented invention, which emphasizes ensuring "direct linear movement" and preventing blade angulation during the process? The case may turn on whether simple adjustability is sufficient for infringement, or if this specific control over the blade's path is a required claim limitation.