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. (People's Republic of China)
  • Plaintiff’s Counsel: Vitale, Vickrey, Niro, Solon & Gasey LLP
• Case Identification: 1:26-cv-05134, N.D. Ill., 09/30/2026
• Venue Allegations: Venue is alleged to be proper under 28 U.S.C. § 1391(c)(3), which states that a defendant not resident in the United States may be sued in any judicial district.
• Core Dispute: Plaintiff alleges that Defendant’s hair trimmers, which feature an adjustable blade gap, infringe a patent related to a system for adjusting the gap between trimmer blades without removing the blade assembly.
• Technical Context: The technology concerns professional and consumer hair clippers, where the ability to finely adjust the blade gap (the distance between the stationary and moving blades) allows for varying cutting lengths, including a "zero gap" for very close trims.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit. Plaintiff notes that its own products sold under the "BaByliss" brand name are covered by the patent claims and are marked pursuant to 35 U.S.C. § 287.

Case Timeline

Date	Event
2019-05-31	'017 Patent Priority Date
2021-08-31	'017 Patent Issue Date
2026-09-30	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, "Hair Cutter Blade Gap Adjustment System," issued August 31, 2021.

The Invention Explained

• Problem Addressed: The patent's background section describes that, in conventional hair clippers, adjusting the "gap" between the stationary and reciprocating blades to change the cut length was a difficult operation that often required physically removing the entire blade assembly from the clipper's handle Compl. ¶3 ’017 Patent, col. 1:27-33 This process was cumbersome and could lead to inconsistent blade alignment ’017 Patent, col. 1:35-39
• The Patented Solution: The invention solves this problem by introducing a "strut" that mounts between the handle and the blade assembly ’017 Patent, col. 3:45-54 This strut physically spaces the blade assembly away from the handle, creating enough clearance for an operator to access "alignment fasteners" (e.g., screws) with a tool ’017 Patent, col. 6:4-8 By loosening these fasteners, the movable blade can be adjusted relative to the stationary blade to change the gap, and then re-secured, all without detaching the blade assembly from the handle Compl. ¶29
• Technical Importance: This innovation provides a method for barbers and users to quickly and precisely adjust the cutting length, particularly to achieve a "zero gap" setting, while the blades remain attached to the device Compl. ¶4

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 15 and dependent claims 16, 17, 18, and 19 Compl. ¶35
• Independent Claim 15 of the ’017 Patent recites the following essential elements:
  • A handle with 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 cutting movement, where the movable and stationary blades are also movable relative to each other along the handle's longitudinal axis to adjust the blade gap.
    • One or more alignment fasteners to releasably secure the movable blade's position relative to the stationary blade.
  • A final "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."
• The complaint reserves the right to assert infringement under the doctrine of equivalents Compl. ¶47

III. The Accused Instrumentality

Product Identification

• The accused products are the "Kemei Zero Gap Products," which include the KEMEI KM-2299 Professional Hair/Beard Trimmer, the Baldheaded Hair Clippers for Men Professional Cordless Hair Trimmer Beard Trimmer with T Blade Zero Gapped Rechargeable Grooming Kit, and the KM-2210 products Compl. ¶6

Functionality and Market Context

• The accused products are electric hair trimmers marketed as having a "Zero Gap T-Blade" feature Compl. ¶6 The complaint alleges that these products are promoted and sold in the United States via a website Compl. ¶12
• The core of the infringement allegation rests on the assertion that the Kemei products are "identical to the drawings of the '017 Patent" Compl. ¶7 A side-by-side visual in the complaint compares Figure 15 of the patent with a photograph of an accused product to support this claim Compl. ¶7 The complaint further alleges that these products are imported and sold through U.S.-based online platforms, generating substantial revenue Compl. ¶18 Compl. ¶21

IV. Analysis of Infringement Allegations

The complaint provides a detailed, element-by-element breakdown of its infringement theory for Claim 15, supported by annotated photographs of an accused Kemei product Compl. ¶¶36-43

• ’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 handle body containing a motor with a rotating shaft. An annotated image points to the "handle defining a longitudinal axis" and the "handle including a rotating shaft."	¶36	col. 3:37-44
a fixed strut configured for securement to the handle and extend outwardly therefrom;	The accused products are alleged to have a fixed strut that secures to the handle. A photograph shows the disassembled blade head with an arrow pointing to the component identified as the "fixed strut."	¶38	col. 3:45-54
a stationary blade defining cutting teeth having blade edges, the stationary blade secured to the strut;	The accused products include a stationary blade with cutting teeth that is secured to the alleged strut. An image shows the blade assembly with arrows pointing to the "Cutting teeth" and "A stationary blade."	¶39	col. 4:57-60
a movable blade coupled to the rotating shaft of the handle... the movable blade and the stationary blade being movable relative to each other in a direction relative to the longitudinal axis... to selectively vary a distance between the blade edges...	The accused products allegedly have a movable blade that reciprocates for cutting and can also be moved longitudinally to adjust the gap from a "Zero gap" to a larger "Gap." A comparative photograph illustrates this adjustment.	¶40; ¶41	col. 4:60-65
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 are shown to have screws that function as alignment fasteners to secure the movable blade. An image shows a screwdriver engaging one of these fasteners.	¶42	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 the strut provides the necessary spacing for access. A supporting visual shows a screwdriver accessing a fastener on an assembled product, mirroring Figure 15 of the patent.	¶43	col. 6:4-8

• Identified Points of Contention:
  • Structural Identity: The complaint's central argument is that the accused products are "identical to the drawings of the '017 Patent" Compl. ¶7 A key question will be whether discovery reveals any subtle but material structural or functional differences between the accused products and the patent's specific embodiments.
  • Scope Questions: The final "wherein" clause requires that the strut "facilitate access" to the fasteners "without requiring removal of the cutting blade assembly." A potential point of dispute may be the degree of access required to meet this limitation and whether the accused design truly achieves this function in the manner claimed.

V. Key Claim Terms for Construction

• The Term: "strut"

• Context and Importance: This term is the central structural element enabling the invention. Its construction will be critical, as the complaint's infringement theory relies on identifying a corresponding "fixed strut" in the accused products Compl. ¶38 Practitioners may focus on this term to determine if it covers any component that spaces the blade assembly from the handle, or if it is limited to a structure with the specific characteristics and relationships described in the patent's preferred embodiments.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claims describe the strut functionally as being "configured for securement to the handle" and to "space the cutting blade assembly." A party might argue this functional language suggests any component achieving this spacing purpose is a "strut."
  • Evidence for a Narrower Interpretation: The specification describes the strut in detail, including its "outer dimension 'w1' which generally approximates the internal dimension 'd1' of the proximal wall 24a of the adjustment tool" ’017 Patent, col. 3:52-59 A party could argue these specific dimensional relationships and interactions with other components, like the adjustment tool, are necessary limitations of the term "strut."

• The Term: "movable relative to each other in a direction relative to the longitudinal axis"

• Context and Importance: This phrase defines the non-reciprocating, adjustable movement that allows for setting the blade gap. It distinguishes the inventive gap adjustment from the conventional side-to-side cutting motion. The complaint's evidence of a "Zero gap" and a larger "Gap" directly maps to this claimed functionality Compl. ¶41

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language is general, describing a relative movement to "selectively vary a distance." An argument could be made that any mechanism allowing longitudinal adjustment of the gap meets this element, regardless of the precise mechanical means.
  • Evidence for a Narrower Interpretation: The specification describes a specific mechanism where an "adjustment tool 14 is advanced upwardly" causing "the movable blade 58 to move upwardly closing the gap" ’017 Patent, col. 6:23-29 One might argue that the term implies a linear, non-rotational movement facilitated by the interaction between the strut and an adjustment tool, as depicted in Figures 16-18.

VI. Other Allegations

• Willful Infringement: The complaint alleges that Defendant's infringement was "deliberate, intentional, and willful" after having "knowledge of the '017 Patent" Compl. ¶49 The complaint does not specify facts supporting when or how Defendant allegedly gained this knowledge (e.g., pre-suit vs. post-suit).

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

• A central issue will be one of structural equivalence: Given the complaint’s strong reliance on the visual similarity between the accused product and the patent’s drawings Compl. ¶7, a key question for the court will be whether the accused "strut" and "alignment fastener" components are structurally and functionally the same as those claimed, or if there are material differences that place them outside the scope of the claims.
• A second key question will involve the functional limitation of facilitating access: The case may turn on what it means for the strut to "facilitate access to the one or more fasteners without requiring removal of the cutting blade assembly" ’017 Patent, claim 15 The dispute could focus on whether the accused design provides the specific type and degree of access contemplated by the patent, or if its adjustment mechanism operates in a fundamentally different way.