1:26-cv-05134
Conair LLC v. Yiwu Kemei Electric Appliance Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Conair LLC (Delaware)
- Defendant: Yiwu Kemei Electric Appliance Co., Ltd. (China); YIWU CAITONG ELECTRIC CO., LTD. (China)
- Plaintiff's Counsel: Vitale, Vickrey, Niro, Solon & Gasey LLP
- Case Identification: 1:26-cv-05134, N.D. Ill., 05/04/2026
- Venue Allegations: Venue is asserted on the basis that both defendants are foreign companies, which may be sued in any judicial district under 28 U.S.C. § 1391(c). The complaint also alleges defendants conduct business and commit infringing acts within the district through sales and advertising.
- Core Dispute: Plaintiff alleges that Defendants' hair trimmers, which feature an adjustable "Zero Gap T-Blade," infringe a patent for a hair cutter blade gap adjustment system.
- Technical Context: The technology relates to professional and consumer hair trimmers, specifically to the mechanism for adjusting the gap between the stationary and moving cutter blades to achieve a very close shave, known as a "zero gap."
- Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit. Plaintiff notes that it marks its own products that embody the invention in compliance with 35 U.S.C. § 287.
Case Timeline
| Date | Event |
|---|---|
| 2019-05-31 | '017 Patent Priority Date |
| 2021-08-31 | '017 Patent Issued |
| 2026-05-04 | Complaint Filed |
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, "Hair Cutter Blade Gap Adjustment System," issued August 31, 2021.
The Invention Explained
- Problem Addressed: The patent's background section describes a deficiency in conventional hair clippers where adjusting the cutting "gap" between the stationary and reciprocating blades was a difficult operation that often required completely removing the blade assembly from the trimmer's handle '017 Patent, col. 1:26-39 This process was cumbersome and could lead to inconsistent blade alignment '017 Patent, col. 1:35-39
- The Patented Solution: The invention provides a hair cutting system that allows a user to adjust the gap between the blades without detaching the blade assembly from the handle '017 Patent, col. 2:44-46 This is achieved through a "strut" that physically separates the blade assembly from the handle, providing access to "alignment fasteners" (e.g., screws) '017 Patent, col. 4:47-54 A user can loosen these fasteners, reposition the movable blade relative to the stationary blade to set the desired gap, and then retighten the fasteners to lock the new position '017 Patent, col. 6:1-6 '017 Patent, FIG. 15
- Technical Importance: This design sought to simplify a common but tedious maintenance task for barbers and stylists, enabling quick and precise on-the-fly adjustments to the closeness of the cut '017 Patent, col. 1:7-11
Key Claims at a Glance
- The complaint asserts infringement of independent claim 15 and dependent claims 16-19 Compl. ¶44 Compl. ¶61
- The essential elements of independent claim 15 are:
- A handle with a longitudinal axis and a rotating shaft.
- A hair cutting blade assembly that includes:
- A fixed strut secured to the handle.
- A stationary blade secured to the strut.
- A movable blade coupled to the rotating shaft for reciprocal movement.
- The movable and stationary blades are also movable relative to each other along the handle's longitudinal axis to adjust the cutting gap.
- One or more alignment fasteners to releasably secure the movable blade in a selected position.
- A "wherein" clause stating the strut is 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."
III. The Accused Instrumentality
Product Identification
- The accused products are the "Kemei Zero Gap Products" and the "ATVOXIS Zero Gap Products," which include various models of professional hair and beard trimmers Compl. ¶6 Compl. ¶8 Specific models named include the KEMEI KM-2299 and KM-2210 Compl. ¶6
Functionality and Market Context
- The complaint alleges these products are hair trimmers that feature an adjustable "Zero Gap T-Blade" Compl. ¶6 Compl. ¶8 This feature allows users to adjust the distance between the cutting blades Compl. ¶50 Compl. ¶67 The complaint presents photographic evidence suggesting the accused products have a physical construction that is "identical to the drawings of the '017 Patent" Compl. ¶7 Compl. ¶9
- The defendants are alleged to manufacture, import, and sell these products in the United States through their own website and online platforms like Amazon.com Compl. ¶14 Compl. ¶16
IV. Analysis of Infringement Allegations
The complaint provides a side-by-side comparison of elements from the accused products with patent drawings to support its infringement allegations. The image in paragraph 51 of the complaint shows screws on the accused Kemei product, which are identified as the claimed "alignment fasteners" Compl. ¶51 The image in paragraph 52 juxtaposes the accused Kemei product with Figure 15 from the patent to allege that the product's strut facilitates access to these fasteners without removal of the blade assembly Compl. ¶52 Similarly, the image in paragraph 67 shows the adjustable gap on an ATVOXIS product, comparing a "Zero gap" configuration to a standard "Gap" Compl. ¶67 The image in paragraph 69 makes the same comparison as paragraph 52 for the ATVOXIS product Compl. ¶69
'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 accused products include a main body or handle that contains a motor with a rotating shaft. | ¶45; ¶62 | col. 3:41-43 |
| a hair cutting blade assembly including: a fixed strut configured for securement to the handle and extend outwardly therefrom | The accused products allegedly possess a "fixed strut" that attaches to the handle and supports the blade assembly. | ¶47; ¶64 | col. 4:45-47 |
| a stationary blade defining cutting teeth having blade edges, the stationary blade secured to the strut | The accused products have a stationary blade with cutting teeth, which is secured to the alleged strut. | ¶48; ¶65 | col. 4:62-63 |
| a movable blade coupled to the rotating shaft of the handle, the movable blade defining cutting teeth having blade edges and capable of reciprocal movement relative to the stationary blade... | The accused products have a movable blade with cutting teeth that is coupled to the rotating shaft and reciprocates side-to-side relative to the stationary blade. | ¶49; ¶66 | col. 5:4-8 |
| ...the movable blade and the stationary blade being movable relative to each other in a direction relative to the longitudinal axis defined by the handle to selectively vary a distance between the blade edges of the stationary blade and the blade edges of the movable blade | The complaint alleges the movable blade can be adjusted relative to the stationary blade to change the cutting gap, as shown in photographs comparing a "Gap" to a "Zero gap." | ¶50; ¶67 | col. 6:23-31 |
| one or more alignment fasteners to releasably secure the movable blade at a plurality of select positions relative to the stationary blade | The accused products allegedly use screws that function as alignment fasteners to lock the movable blade in place after its position has been adjusted. | ¶51; ¶68 | col. 2:17-21 |
| 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 complaint alleges that the accused products' strut provides sufficient clearance to access the alignment fasteners with a tool while the blade assembly remains attached to the trimmer handle. | ¶52; ¶69 | col. 6:3-6 |
- Identified Points of Contention:
- Scope Questions: The case may turn on the interpretation of the "wherein" clause of claim 15. The dispute could focus on whether the accused strut is "configured to" facilitate access, implying a specific design purpose, or whether it merely has the incidental effect of allowing access. The complaint's allegation that the accused products are "identical to the drawings" suggests Plaintiff will argue for an interpretation based on inherent structure and function Compl. ¶7 Compl. ¶9
- Technical Questions: A factual question may arise regarding the function of the components identified as "alignment fasteners." The court may need to determine if the screws on the accused products are used to "releasably secure the movable blade at a plurality of select positions" in the manner claimed, or if they serve a different primary function, such as simply holding the entire blade assembly together.
V. Key Claim Terms for Construction
The Term: "fixed strut"
Context and Importance: This term is a central structural element of the invention. Its presence and function-spacing the blade assembly from the handle-is the primary enabler of the patent's solution. Practitioners may focus on this term because the defendants could argue that the corresponding part in their products is not a "strut" as defined by the patent, but a standard mounting block or part of the housing.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not provide an explicit definition of "strut." The claims describe it functionally as something "configured for securement to the handle" that extends "outwardly therefrom" '017 Patent, claim 15 This could support an interpretation covering any component that connects the blade assembly to the handle and creates space.
- Evidence for a Narrower Interpretation: The specification consistently shows the strut 46 as a distinct component that "is dimensioned to displace the cutting blade assembly 18 away from the handle 16" '017 Patent, col. 4:47-49 An argument could be made that the term is limited to a separate piece with the primary design purpose of creating this displacement, as depicted in figures like FIG. 9.
The Term: "alignment fasteners"
Context and Importance: These fasteners are the key to the adjustability and locking features of the claim. The dispute will hinge on whether the screws in the accused products perform the claimed function of "releasably secur[ing] the movable blade at a plurality of select positions."
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term "fastener" is general. The claim language only requires that it "releasably secure the movable blade." This could encompass any screw, clamp, or latch that performs this function. The patent states the "alignment fastener may include an alignment screw" '017 Patent, col. 2:20-21, suggesting "alignment screw" is one example, not the only possibility.
- Evidence for a Narrower Interpretation: The specification describes a specific mechanism where the alignment screws 84 engage with threaded anchors 82 in a slider 60, which in turn holds the movable blade 58 '017 Patent, col. 5:19-27 A defendant might argue that "alignment fasteners" should be limited to fasteners that interact with a slider mechanism as described in the preferred embodiment.
VI. Other Allegations
- Indirect Infringement: The complaint does not contain specific counts for indirect infringement (inducement or contributory).
- Willful Infringement: The complaint alleges "deliberate, intentional, and willful infringement" against both Kemei and ATVOXIS "after having knowledge of the '017 Patent" Compl. ¶58 Compl. ¶75 However, it does not specify facts supporting pre-suit knowledge, suggesting the willfulness claim may be based on the filing of the lawsuit itself.
VII. Analyst's Conclusion: Key Questions for the Case
A central issue will be one of structural identity and function: Does the component identified as a "strut" in the accused products meet the claim limitation of being "configured to space the cutting blade assembly... to facilitate access," or can the defense argue this is an incidental, unintended property of a standard mounting structure? The complaint's assertion of the products being "identical" to patent drawings will be tested against this functional language.
A key evidentiary question will be one of operational equivalence: Do the screws in the accused products function as "alignment fasteners" by "releasably secur[ing] the movable blade at a plurality of select positions," as claimed? The analysis will likely require a detailed technical breakdown of how adjustments are made on the accused devices versus the specific mechanism detailed in the '017 patent specification.
The claim of willfulness will depend on establishing when the defendants gained knowledge of the '017 patent. As the complaint does not plead specific facts showing pre-suit knowledge, the viability of this claim for enhanced damages may initially be limited to post-filing conduct.