DCT

1:26-cv-01394

Conair LLC v. Cocco Hair Professional LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:26-cv-01394, N.D. Ohio, 06/18/2026
  • Venue Allegations: Venue is alleged to be proper in the Northern District of Ohio because Defendant Cocco Hair Professional LLC has committed acts of infringement in the district and maintains a regular and established place of business or sales channels within the district.
  • Core Dispute: Plaintiff alleges that Defendant's line of professional hair trimmers, which feature a "Zero Gap T-Blade," infringes a patent related to a system for adjusting the gap between trimmer blades without disassembling the device.
  • Technical Context: The technology addresses a long-standing challenge for professional barbers: the ability to precisely and easily adjust the cutting length of a hair trimmer, known as setting the "zero gap," to achieve very close cuts.
  • Key Procedural History: The complaint alleges that Plaintiff provided Defendant with written notice of the patent and its infringement on June 14, 2024, approximately two years before filing the suit. 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
2024-06-14 Date of alleged written notice to Defendant
2026-06-18 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 "'017 Patent").

The Invention Explained

  • Problem Addressed: The patent's background describes the difficulty in adjusting the cutting gap on conventional hair trimmers, which often required the user to physically remove the entire blade assembly from the handle, align the blades by hand, and reattach the assembly-an operation described as "difficult" and prone to creating inconsistent cuts due to misalignment '017 Patent, col. 1:26-38 Compl. ¶3
  • The Patented Solution: The invention is a hair cutting system designed to allow for blade gap adjustment while the blade assembly remains mounted to the handle '017 Patent, col. 1:45-47 The core of the solution is a "fixed strut" that physically separates the cutting blade assembly from the trimmer's handle '017 Patent, col. 4:45-50 This spacing creates room for an operator to use a driver tool to access and manipulate "alignment fasteners" (e.g., screws) that control the position of the movable blade relative to the stationary blade, thereby adjusting the cutting gap without disassembly '017 Patent, col. 6:3-8
  • Technical Importance: This design enables a "clean, consistent and easily controllable cut" by simplifying the process of achieving a precise "zero gap" setting, a critical capability for professional barbers and stylists Compl. ¶4

Key Claims at a Glance

  • The complaint asserts infringement of independent claim 15 and dependent claims 16, 17, 18, and 19 Compl. ¶29
  • Independent Claim 15 recites the following essential elements Compl. ¶28:
    • A handle with a rotating shaft.
    • A hair cutting blade assembly that includes a fixed strut, a stationary blade secured to the strut, and a movable blade coupled to the rotating shaft.
    • The movable and stationary blades are movable relative to each other along the handle's longitudinal axis to adjust the distance (gap) between their blade edges.
    • One or more alignment fasteners to releasably secure the movable blade in a selected position.
    • A "wherein" clause specifying that 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 other claims that may be identified during discovery Compl. ¶29

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are the "COCCO Zero Gap Products," which include the COCCO Veloce Pro Trimmer, the COCCO Hyper Veloce Pro Trimmer, and the Veloce Lite Trimmer Compl. ¶5

Functionality and Market Context

  • The complaint identifies these products as professional hair trimmers featuring a "Zero Gap T-Blade" Compl. ¶5 The complaint alleges these products are manufactured in China and are imported, distributed, and sold in the United States by Defendant Compl. ¶11 The complaint includes a side-by-side image comparing a drawing from the '017 Patent to a photograph of an accused product to allege their structural identity Compl. ¶6

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 accused products include a handle body with an internal motor-driven rotating shaft. ¶30 col. 3:40-50
a fixed strut configured for securement to the handle and extend outwardly therefrom The accused products contain a component, identified as a "fixed strut," that attaches to the handle and extends outward to hold the blade assembly. ¶32 col. 4:45-50
a stationary blade defining cutting teeth having blade edges, the stationary blade secured to the strut A stationary cutting blade is secured to the aforementioned strut component. ¶33 col. 5:28-31
a movable blade coupled to the rotating shaft of the handle... capable of reciprocal movement... [and] movable relative to each other... to selectively vary a distance between the blade edges The accused products have a movable blade that oscillates side-to-side for cutting and is also adjustable toward or away from the stationary blade to set the cutting gap. ¶¶34-35 col. 5:5-7; col. 6:39-54
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 use screws, identified as "alignment fasteners," to lock the movable blade's position after adjustment. ¶36 col. 6:43-44
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 strut component allegedly spaces the blade assembly far enough from the handle to allow a tool to access the alignment fasteners while the unit is fully assembled. A photograph shows a screwdriver accessing an alignment screw on the blade assembly while it remains attached to the trimmer handle, illustrating this accessibility Compl. ¶37 ¶37 col. 6:3-8

Identified Points of Contention

  • Scope Questions: A central issue may be the interpretation of the term "strut". The dispute could focus on whether the accused component, which Plaintiff labels a "strut," meets the structural and functional definition of the term as used in the '017 Patent, or whether it is a more conventional mounting piece that does not embody the claimed invention.
  • Technical Questions: The infringement analysis will likely turn on the functional aspect of the "wherein" clause. The key question for the court will be whether the accused product's "strut" is merely a mounting bracket or if it is specifically "configured to... facilitate access" to the fasteners without disassembly, as claimed. Evidence regarding the design intent and physical constraints of the accused device will be critical.

V. Key Claim Terms for Construction

  • The Term: "strut"

    • Context and Importance: This term is the central structural element of the claim. How broadly or narrowly it is defined will be critical to the infringement analysis, as the Defendant's device must possess a "strut" to infringe. Practitioners may focus on this term because the complaint's case hinges on mapping this claim element to a specific component in the accused trimmers Compl. ¶32
    • Intrinsic Evidence for a Broader Interpretation: The patent specification describes the strut as being "dimensioned to displace the cutting blade assembly 18 away from the handle 16" '017 Patent, col. 4:47-49 This functional language could support an argument that any component performing this spacing function is a "strut."
    • Intrinsic Evidence for a Narrower Interpretation: The patent also provides detailed depictions of the strut, showing specific features like a "central opening 48" and "two side openings 52" '017 Patent, col. 4:50-53 '017 Patent, Fig. 9 A party could argue these features are essential characteristics, limiting the term to structures that are highly similar to the depicted embodiment.

  • The Term: "configured to... facilitate access"

    • Context and Importance: This phrase from the "wherein" clause recites the purpose and function of the strut. Whether the accused device is "configured" for this purpose, as opposed to achieving it incidentally, will be a key point of contention.
    • Intrinsic Evidence for a Broader Interpretation: The patent states that "the presence of the strut 46 displaces the alignment screws 84 a sufficient distance from the handle 16 such that the operator can readily access" them '017 Patent, col. 6:3-6 This language suggests that the result of facilitated access is the key consideration, potentially supporting a finding of infringement if the accused device's structure achieves this result.
    • Intrinsic Evidence for a Narrower Interpretation: The term "configured to" can imply intentional design. A party could argue that the strut must be specifically designed and shaped for the purpose of facilitating access, not just incidentally allowing it. The specification's discussion of the close-tolerance fit between the strut and an "adjustment tool" could be cited to support a narrower interpretation requiring a more specific and intended configuration '017 Patent, col. 6:11-20

VI. Other Allegations

  • Indirect Infringement: The complaint focuses on direct infringement under 35 U.S.C. § 271(a) and does not make explicit allegations of induced or contributory infringement Compl. ¶29 Compl. ¶40
  • Willful Infringement: The complaint alleges that Defendant had actual knowledge of the '017 Patent at least as early as June 14, 2024, due to a written notice letter from Plaintiff's counsel Compl. ¶42 The complaint further alleges that Defendant's infringement continued after receiving this notice, forming the basis for the claim of willful infringement and a request for enhanced damages under 35 U.S.C. § 284 Compl. ¶44

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

The resolution of this case will likely depend on the court's determination of the following key questions:

  • A core issue will be one of claim construction: Will the term "strut" be defined broadly as any component that spaces the blade assembly from the handle, or will it be construed more narrowly to require structural features specific to the embodiments shown in the '017 Patent?

  • A central question of infringement will be: Does the evidence show that the accused trimmer's structure is "configured to facilitate access" to its adjustment screws as an intended function, as required by Claim 15, or is any such access an incidental byproduct of a conventional mounting design that falls outside the patent's scope?

  • Finally, a key evidentiary question for willfulness will be: Did the Defendant, after receiving notice of the patent in June 2024, act with the kind of objective recklessness that constitutes willful infringement, potentially justifying an award of enhanced damages?