SharkNinja Operating LLC v. Guangdong Qiaokang Electrical Appliances Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: SharkNinja Operating LLC and SharkNinja Sales Company (Delaware)
  • Defendant: Guangdong Qiaokang Electrical Appliances Co., Ltd. (China)
  • Plaintiff's Counsel: Shook, Hardy & Bacon LLP.
• Case Identification: 1:26-cv-12117, D. Mass., 05/08/2026
• Venue Allegations: Venue is alleged to be proper based on Defendant's transaction of business and commission of infringing acts within the District of Massachusetts through interactive e-commerce storefronts accessible to consumers in the state.
• Core Dispute: Plaintiff alleges that Defendant's Tevolux-branded air fryers infringe a design patent and a utility patent related to Plaintiff's Ninja CRISPi line of portable air fryers.
• Technical Context: The technology at issue involves countertop air fryers featuring a novel architecture where a removable heating "pod" sits atop a separate cooking vessel, which is held by a base that doubles as a handle.
• Key Procedural History: The complaint alleges that Plaintiff has provided constructive notice of the patents-in-suit via its public patent-marking webpage since November 2025. No prior litigation, inter partes reviews, or licensing agreements are mentioned in the complaint.

Case Timeline

Date	Event
2023-08-01	'739 Patent Priority Date
2024-09-04	'567 Patent Priority Date (Application Filing)
2024-09-12	'739 Patent Application Filing Date
2024-09-26	Ninja CRISPi Product Launch
2025-09-30	'739 Patent Issue Date
2025-11-04	'567 Patent Issue Date
2025-11-05	'567 Patent constructive notice period begins
2025-11-12	'739 Patent constructive notice period begins
2026-05-08	Complaint Filing Date

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

U.S. Design Patent No. D1,100,567 - "Air Fryer"

• Patent Identification: U.S. Patent No. D1,100,567, titled "Air Fryer," issued on November 4, 2025. Compl. ¶30 Compl. ¶31

The Invention Explained

• Problem Addressed: Design patents do not address technical problems; they protect the ornamental, non-functional appearance of an object.
• The Patented Solution: The '567 Patent claims the specific ornamental design for a removable air-fryer pod. Compl. ¶20 The claimed design features a distinct shape with an upper user-interface section and a wider lower section, as shown in the patent's figures. Compl. ¶20 Ex. A
• Technical Importance: The complaint alleges that the ornamental design is an integral part of the commercial success and user-friendliness of the Plaintiff's Ninja CRISPi product. Compl. ¶22

Key Claims at a Glance

• Design patents contain a single claim for "the ornamental design for an air fryer, as shown and described." Ex. A, claim The infringement analysis is based on the patent's drawings.

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. Compl. ¶38 Compl. ¶39

The Invention Explained

• Problem Addressed: The patent's background section describes conventional air fryers that use a basket within a cooking chamber. Ex. B, col. 1:31-44 The overall context of the complaint and patent suggests an opportunity to improve convenience by moving beyond the traditional drawer-style basket design. Compl. ¶14
• The Patented Solution: The patent discloses a modular cooking system where a cooking device can be removably placed over a vessel to create a cooking chamber. '739 Patent, abstract A key aspect of the invention, articulated in the asserted claim, is a "vessel assembly" that includes a handlebar positioned under the vessel with a gap between the handlebar and the vessel wall. '739 Patent, col. 12:16-24 This gap is described as a "thermal break," intended to allow for safe handling of the vessel. '739 Patent, col. 12:23-24
• Technical Importance: This configuration allows a user to prepare, cook, serve, and potentially store food in the same vessel, differentiating it from prior art air fryers that relied on integrated drawers. Compl. ¶13 Compl. ¶14

Key Claims at a Glance

• The complaint explicitly asserts independent claim 7. Compl. ¶41
• The essential elements of claim 7 are:
  • A vessel comprising a cavity for food and an opening for accessing the cavity.
  • A handlebar positioned under the vessel and extending upward along a portion of the vessel's height, configured for user contact.
  • A gap positioned between the vessel wall and the handlebar, with the gap being configured as a thermal break.
• The complaint alleges infringement of "at least claim 7," reserving the right to assert other claims. Compl. ¶41

III. The Accused Instrumentality

Product Identification

• The accused products are "Tevolux-branded" air fryers, specifically the "4-in-1 Glass Air Fryer," identified with model number "KDF-G6402D." Compl. ¶25 Compl. ¶27

Functionality and Market Context

• The accused products are described as air fryers that, like the Ninja CRISPi, utilize a system with a removable top heating unit and a separate glass cooking vessel held in a base. Compl. ¶27 The complaint includes a marketing image of the Tevolux product alongside the Ninja CRISPi to highlight their similarities. Compl. ¶28 The complaint further alleges the accused products are sold through major e-commerce platforms, such as Amazon.com. Compl. ¶26 Compl. ¶28
• Plaintiff characterizes the accused product as an "obvious knock-off" and an "inferior imitation" of its "viral hit product," the Ninja CRISPi, alleging it was "intentionally designed to copy the form and function" of Plaintiff's product. Compl. ¶4 Compl. ¶41

IV. Analysis of Infringement Allegations

The complaint alleges the Accused Products directly infringe the '567 design patent by appropriating its overall ornamental appearance. Compl. ¶¶32-33 A side-by-side comparison provided in the complaint juxtaposes Figure 2 of the '567 Patent with an image of the accused Tevolux air fryer pod to support the allegation of substantial similarity. Compl. ¶34 The core of this allegation rests on the "ordinary observer" test, where infringement is found if the designs are similar enough to deceive an ordinary observer into purchasing one item thinking it is the other.

'739 Patent Infringement Allegations

Claim Element (from Independent Claim 7)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a vessel, comprising: a cavity configured to receive a food product therein; an opening positioned in a wall of the vessel and configured for accessing the cavity	The accused products include a glass cooking vessel with an internal volume (cavity) for food and an upper opening for access. The complaint includes a marketing image showing vessels of different quart sizes. Compl. ¶43	¶43; ¶44	col. 27:50-60
a handlebar positioned under the vessel and configured to be contacted by a user, the handlebar extending upward along a portion of a height of the vessel	The accused products feature a black plastic base that is positioned underneath the glass vessel and extends up its sides, which the complaint alleges functions as the claimed handlebar. A product image shows this configuration. Compl. ¶45	¶45	col. 38:23-35
a gap positioned between the wall of the vessel and the handlebar, the gap configured to be a thermal break between the vessel and the handlebar	The complaint alleges a visible space exists between the glass vessel and the plastic base/handlebar. It provides close-up photographs showing this gap and noting the presence of rubber standoffs, which are alleged to maintain the separation. Compl. ¶46	¶46	col. 38:55-64

• Identified Points of Contention:
  • Scope Questions: A potential dispute may arise over whether the accused product's integrated base structure, which cradles the vessel and provides handles, meets the definition of a "handlebar" as recited in the claim. The defense may argue that the patent's embodiments depict a more distinct bar-like structure, whereas the complaint alleges infringement by a more encompassing base.
  • Technical Questions: The infringement analysis for the "configured to be a thermal break" limitation will be a central issue. The complaint provides visual evidence of a gap and rubber standoffs to suggest this feature is intentional. Compl. ¶46 A key question for the court will be whether this physical arrangement is sufficient to prove the gap was "configured" for thermal insulation, or if the defense can argue the gap is an incidental aspect of the design without the specific claimed function.

V. Key Claim Terms for Construction

Term: "handlebar"

• Context and Importance: The construction of "handlebar" is critical because the accused product utilizes an integrated base that also serves as a handle, rather than a visually distinct bar. Practitioners may focus on this term because its scope will determine whether the accused product's structure can meet this claim limitation.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent does not provide an explicit definition, which may support a broader, plain-and-ordinary-meaning construction. The specification describes various embodiments, including "vessel protection handles" and a "handlebar positioned between" support arms, suggesting the term is not limited to a single, narrow form. '739 Patent, col. 7:10-12 '739 Patent, col. 30:25-26
  • Evidence for a Narrower Interpretation: The defense may point to figures like FIG. 12A, which shows a distinct, bar-shaped handlebar (1616a), to argue for a narrower construction. Furthermore, other claims in the patent family refer to a "U-shaped base," which could suggest the patentee deliberately chose the more specific term "handlebar" in claim 7. '739 Patent, claim 1 '739 Patent, claim 23

Term: "configured to be a thermal break"

• Context and Importance: This is a functional limitation. Infringement requires not just the existence of a gap, but proof that the gap was intentionally designed to function as a thermal break. The resolution of this issue will likely depend on evidence of the design's purpose.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself ascribes the function to the gap. Plaintiff will likely argue that if a structure is arranged in a way that creates a thermal break (e.g., by using standoffs as alleged in the complaint), it is "configured" as such. The specification states that the gap "enables safe handling by a user," directly linking the structure to the function. Compl. ¶47
  • Evidence for a Narrower Interpretation: A defendant may argue that "configured" requires more than an inherent or incidental property, but rather a specific design choice directed solely at that function. They could contend the gap is a result of manufacturing tolerances or component fit, not a deliberate thermal design. The specification's description that a similar gap "can act as a thermal break" could be used to argue this is a possible, but not required, function of the configuration. '739 Patent, col. 38:57

VI. Other Allegations

• Indirect Infringement: The complaint makes a general allegation of indirect infringement in its introductory paragraphs. Compl. ¶3 However, the specific claims for relief (Counts I and II) are pleaded exclusively as direct infringement under 35 U.S.C. § 271(a) and do not set forth specific factual allegations to support claims of inducement or contributory infringement. Compl. ¶32 Compl. ¶40
• Willful Infringement: While there is no explicit count for willful infringement, the complaint alleges that Defendant has had knowledge of both patents "since the filing date of this Complaint." Compl. ¶35 Compl. ¶49 This allegation lays the groundwork for a claim of post-filing willfulness. The complaint also asserts that Plaintiff has provided constructive notice through its patent marking webpage since November 2025, which may be used to argue for pre-suit knowledge. Compl. ¶35 Compl. ¶49

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

This case presents a dispute over both the aesthetic and functional aspects of a novel air fryer design. The key questions for the court will likely be:

1. A question of visual impression for the design patent: Is the overall ornamental design of the accused Tevolux air fryer pod "substantially the same" as the '567 Patent's claimed design from the perspective of an ordinary observer, or are the differences in appearance legally significant?

2. A question of claim scope for the utility patent: Can the term "handlebar" from claim 7 of the '739 Patent be construed to read on the accused product's integrated base-and-handle structure, or is its meaning limited to a more distinct, bar-like component as shown in some patent figures?

3. An evidentiary question of functional configuration: Does the evidence, including the physical product and potentially internal design documents, demonstrate that the gap between the accused product's vessel and base was intentionally "configured to be a thermal break" as required by claim 7, or is the gap an incidental feature without the claimed, purpose-driven function?