DCT
1:26-cv-12118
SharkNinja Operating LLC v. Shenzhen Henglang Technology Co Ltd
Key Events
Complaint
Table of Contents
complaint Intelligence
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: SharkNinja Operating LLC and SharkNinja Sales Company (Delaware)
- Defendant: Shenzhen Henglang Technology Co., Ltd. (China)
- Plaintiff's Counsel: Shook, Hardy & Bacon LLP.
- Case Identification: 1:26-cv-12118, D. Mass., 05/08/2026
- Venue Allegations: Venue is alleged based on Defendant's commission of infringing acts within the district and the transaction of business through interactive e-commerce storefronts accessible to consumers in Massachusetts.
- Core Dispute: Plaintiff alleges that Defendant's YUKO-branded portable air fryers infringe one design patent and one utility patent that protect features of Plaintiff's Ninja CRISPi product line.
- Technical Context: The technology relates to portable home-use air fryers, specifically a design featuring a removable heating "pod" that operates on a separate cooking vessel.
- Key Procedural History: The complaint alleges that Plaintiff provided constructive notice of the patents-in-suit via its public patent-marking webpage beginning in November 2025, which may be relevant to the calculation of potential damages.
Case Timeline
| Date | Event |
|---|---|
| 2021-08 | SharkNinja launches Ninja CREAMi ice-cream maker |
| 2023-03 | SharkNinja launches Ninja SPEEDi rapid cooker |
| 2023-07 | SharkNinja launches Ninja THIRSTi beverage maker |
| 2023-08-01 | Earliest priority date for '739 Patent |
| 2024-09-04 | Filing date / Priority date for '567 Patent |
| 2024-09-12 | Application filed for '739 Patent |
| 2024-09-26 | SharkNinja launches Ninja CRISPi portable air fryer |
| 2025-09-30 | '739 Patent issues |
| 2025-11-04 | '567 Patent issues |
| 2025-11-05 | Alleged constructive notice of '567 Patent begins |
| 2025-11-12 | Alleged constructive notice of '739 Patent begins |
| 2026-05-08 | Complaint filed |
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.
The Invention Explained
- Problem Addressed: Design patents do not articulate a technical problem; they protect the ornamental appearance of an article of manufacture.
- The Patented Solution: The '567 Patent claims the ornamental design of a removable air-fryer pod Compl. ¶20 Key visual features include the overall two-tiered shape, a circular top control surface, a distinctive recessed area on its side body intended for handling, and a squared lower housing that interfaces with a cooking vessel '567 Patent, FIG. 1 '567 Patent, FIG. 2
- Technical Importance: The complaint alleges that the distinctive ornamental design is a key element of the commercial success and user-friendly functionality of the Ninja CRISPi product Compl. ¶22
Key Claims at a Glance
- The patent contains a single claim: "The ornamental design for an air fryer, as shown and described" '567 Patent, claim
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.
The Invention Explained
- Problem Addressed: The patent background notes that traditional air fryers often use integrated cooking drawers, requiring users to clean both the drawer and a separate serving dish '739 Patent, col. 22:1-14 The design also seeks to improve safe handling of a hot cooking vessel.
- The Patented Solution: The invention is a cooking system with a removable heating unit ("cooking device") that can be placed over a vessel to create a cooking chamber '739 Patent, abstract This allows a user to cook, serve, and store food in the same container '739 Patent, col. 22:4-14 Asserted claim 7 specifically describes a vessel assembly with a handlebar positioned underneath and extending up the side, with a gap between the handlebar and the hot vessel wall that is "configured to be a thermal break" to facilitate safer handling '739 Patent, col. 42:12-22 Compl. ¶21
- Technical Importance: This "cook-and-serve" architecture, combined with safety features like the thermal break, creates a new category of portable air-fryer intended to be more convenient and versatile than traditional designs Compl. ¶14
Key Claims at a Glance
- The complaint asserts independent claim 7 and notes infringement of independent claim 1 Compl. ¶41 Compl. ¶49
- The essential elements of independent claim 7 are alleged to be Compl. ¶42:
- "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"
- "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"
- "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."
III. The Accused Instrumentality
Product Identification
The complaint identifies the "Accused Products" as YUKO-branded air-fryers, specifically an "8-in-1 Glass Air Fryer" sold on e-commerce marketplaces like Amazon.com Compl. ¶¶26-27
Functionality and Market Context
- The complaint alleges the Accused Products are "obvious knock-off[s]" that "were intentionally designed to copy the form and function of CRISPi" Compl. ¶41
- Based on allegations and visual evidence, the accused YUKO product is a portable air fryer system that includes a top heating pod and a separate glass cooking vessel held in a base with handles Compl. ¶¶43-46
- A side-by-side image shows the accused YUKO product next to the Ninja CRISPi, highlighting their similar overall configuration Compl. ¶28 The complaint asserts the accused products bear a "striking resemblance" to the Ninja CRISPi Compl. ¶27
IV. Analysis of Infringement Allegations
D1,100,567 Infringement Allegations
The complaint alleges that the Accused Products directly infringe the '567 Patent because they "embody and appropriate the overall visual appearance and ornamental features claimed" and are "substantially the same in overall impression to the patented design" Compl. ¶33 This allegation invokes the "ordinary observer" test for design patent infringement. To support this, the complaint provides a visual comparison between a figure from the '567 Patent and a photograph of the accused YUKO product's heating pod, highlighting the asserted similarity in their ornamental appearance Compl. ¶34
12,426,739 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 | The Accused Products include a glass cooking vessel with a cavity for holding food. | ¶43 | col. 41:12-14 |
| an opening positioned in a wall of the vessel and configured for accessing the cavity | The Accused Products' glass vessel has an upper opening for accessing the cavity. | ¶44 | col. 41:15-17 |
| 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 include a plastic base with a handlebar that sits under the glass vessel and extends up its sides for a user to hold. | ¶45 | col. 41:18-21 |
| 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 Accused Products have a visible gap between the glass vessel and the plastic handlebar, which is alleged to form a thermal break for safe handling. An image shows a user holding the product by this handlebar (Compl. ¶45). | ¶46; ¶47 | col. 41:22-25 |
- Identified Points of Contention:
- '567 Patent (Design): The infringement analysis will turn on whether an ordinary observer, giving such attention as a purchaser usually gives, would find the two designs substantially the same. The Defendant may point to differences in the control panel layout and button configuration on the top surface of the pod as evidence that the designs are not substantially similar Compl. ¶34
- '739 Patent (Utility): A primary point of contention may be the functional limitation "configured to be a thermal break." The dispute will likely focus on whether the gap in the accused product is merely an incidental space between components or if it was designed and functions as a thermal break, as required by the claim.
V. Key Claim Terms for Construction
For U.S. Patent No. 12,426,739
- The Term: "configured to be a thermal break"
- Context and Importance: This term appears in the final limitation of asserted claim 7 and imparts a specific function onto the claimed "gap." Infringement will depend on whether the accused product's structure is found to meet this functional requirement. Practitioners may focus on this term because it moves the analysis beyond a purely structural comparison to a functional one, requiring evidence of purpose and effect.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not provide a highly detailed structural definition for the thermal break. Plaintiff may argue that any gap that is positioned between the hot vessel and the handlebar and results in a cooler handle for safe use is, by its nature and effect, "configured to be" a thermal break '739 Patent, col. 41:22-25
- Evidence for a Narrower Interpretation: Defendant may argue that the term requires more than the mere existence of a space. They may point to language describing the "insulating body" in other embodiments as being "configured to protect the support surface from heat radiating from the vessel" to suggest that "configured to" implies a more specific design intent and structure than what is present in the accused product '739 Patent, col. 11:30-33
VI. Other Allegations
- Indirect Infringement: The complaint includes a general allegation of indirect infringement Compl. ¶3 but does not plead specific facts to support a claim for either induced or contributory infringement, such as knowledge of the patents combined with specific actions intended to cause infringement by others.
- Willful Infringement: The complaint does not explicitly use the term "willful infringement." However, it alleges pre-suit constructive notice of both patents via Plaintiff's patent-marking website beginning in November 2025 Compl. ¶35 Compl. ¶50 It also alleges knowledge of the patents as of the complaint's filing date. These allegations may form a basis for a future claim of willfulness and enhanced damages.
VII. Analyst's Conclusion: Key Questions for the Case
This case presents two distinct infringement inquiries, one for a design patent and one for a utility patent. The key questions for the court will likely be:
A question of visual perception: For the '567 design patent, is the overall ornamental appearance of the accused YUKO air fryer pod "substantially the same" as the patented design in the eyes of an ordinary observer, or are the differences, such as the control panel interface, significant enough to distinguish them?
A question of functional claim scope: For the '739 utility patent, what is the scope of the term "configured to be a thermal break"? The case may turn on whether Plaintiff can prove the gap in the accused product was specifically designed or arranged to perform this heat-insulating function, versus being an incidental by-product of its assembly.
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