2:26-cv-01692
Caswell Products LLC v. Schedule A
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Caswell Products LLC (Minnesota)
- Defendant: The Individuals, Partnerships, and Unincorporated Associations Identified in Schedule A (Foreign)
- Plaintiff's Counsel: DNL Zito
- Case Identification: 2:26-cv-01692, W.D. Pa., 08/18/2026
- Venue Allegations: Venue is asserted as proper because the defendants are foreign entities who do not reside in the United States and are therefore subject to venue in any judicial district. Personal jurisdiction is alleged based on defendants directing business activities toward consumers in Pennsylvania through online marketplaces.
- Core Dispute: Plaintiff alleges that Defendants' microwave splatter covers, sold through various e-commerce platforms, infringe a patent related to a reusable, magnetically storable microwave cover.
- Technical Context: The technology occupies the consumer kitchenware market, aiming to improve user convenience by combining a common cooking accessory with a novel storage solution.
- Key Procedural History: The filing is an Amended Complaint in an action targeting numerous foreign-based online sellers, a common strategy for enforcing intellectual property rights against diffuse sellers on e-commerce platforms.
Case Timeline
| Date | Event |
|---|---|
| 2016-06-13 | '802 Patent Priority Date |
| 2020-03-10 | '802 Patent Issue Date |
| 2026-08-18 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,582,802 - "Microwave Splatter Cover or Enclosure"
The Invention Explained
- Problem Addressed: The patent's background section identifies shortcomings with existing methods for preventing food splatter in microwaves (Compl., Ex. A, '802 Patent, col. 1:21-41). It notes that paper towels can fall into food, and conventional plastic covers can trap steam, making food soggy, while also being bulky and difficult to store in a kitchen (Compl., Ex. A, '802 Patent, col. 1:24-41).
- The Patented Solution: The invention is a reusable microwave cover designed to solve both the cooking and storage problems. It features a vented, dome-shaped housing to prevent steam buildup (Compl., Ex. A, '802 Patent, col. 2:6-8). Its key innovation is the integration of at least one "microwave-safe" magnetic member, which allows the cover to be stored by adhering to an interior surface of the microwave, such as the ceiling, when not in use (Compl., Ex. A, '802 Patent, col. 2:1-6; Compl., Ex. A, '802 Patent, fig. 1B). The magnet is described as being shielded by a "metal foil or metallic coating" to prevent interference with the microwave's operation (Compl., Ex. A, '802 Patent, col. 7:30-34).
- Technical Importance: This design provides a dual benefit: it functions as a splatter guard during cooking and offers a novel, built-in storage solution that does not occupy external cabinet or drawer space (Compl., Ex. A, '802 Patent, col. 2:38-44).
Key Claims at a Glance
- The complaint asserts independent claims 1 and 12 Compl. ¶37
- Independent Claim 1 includes these essential elements:
- A housing member for covering a food item, with an open end and outer rim.
- The outer rim includes a set of "leg posts" to facilitate air flow.
- At least one ventilation portion.
- At least one "magnetic member" integrated into the housing to allow adhering to an interior microwave surface.
- The magnetic member comprises a magnet and an "enveloping member."
- The enveloping member comprises a "metal foil or metallic coating configured to shield the magnet."
- Independent Claim 12 includes these essential elements:
- A housing member with a "closed end" and an open end.
- At least one "magnetic assembly" integrated into the closed end.
- The magnetic assembly allows adhering to an interior microwave surface.
- The magnetic assembly comprises a magnet member and an "enveloping member."
- The enveloping member comprises a "metal foil or metallic coating configured to shield the magnet member."
- The complaint does not explicitly reserve the right to assert dependent claims but alleges infringement of "one or more claims" Compl. ¶1
III. The Accused Instrumentality
Product Identification
- The Accused Products are microwave splatter covers sold by the Defendants through various "Defendant Internet Stores" on e-commerce platforms such as Amazon.com and Temu.com Compl. ¶2 Compl. ¶14
Functionality and Market Context
- The complaint alleges the Accused Products are "identical as far as their functional aspects in relation to the Asserted Patent" Compl. ¶10 This includes using "similar constructions" to the patented invention Compl. ¶10 The complaint includes a visual diagram from the Plaintiff's website showing how the product works: it is lowered to cover food, used during heating, and then lifted to "magnetize to the ceiling for out-of-the-way storage" Compl. p. 6 The complaint alleges Defendants are direct competitors causing price erosion and are using Plaintiff's own brand name, "Hover Cover," to market their products Compl. ¶2 Compl. p. 2 Compl. ¶18
IV. Analysis of Infringement Allegations
The complaint alleges that the Accused Products contain every element of at least independent claim 1 or 12 of the '802 Patent Compl. ¶37 While the complaint references claim charts in an un-provided exhibit Compl. ¶16, the narrative allegations form the basis of the infringement theory.
'802 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a housing member configured for covering a food item during microwave cooking... | The complaint alleges the Accused Products are microwave splatter covers that functionally replicate Plaintiff's patented invention. | ¶10; ¶37 | col. 4:31-33 |
| the outer rim includes a set of leg posts protruding therefrom configured to facilitate air flow up through the housing member | The complaint alleges the Accused Products use "similar constructions" to the patented invention, which includes features for structure and function. | ¶10; ¶37 | col. 4:34-36 |
| at least one magnetic member integrated into the housing member... configured to facilitate adhering of the housing member to an interior surface of a microwave oven | The complaint alleges the Accused Products possess the key functionality of magnetically attaching to a microwave ceiling for storage. | ¶10; ¶14; p. 6 | col. 4:45-50 |
| the at least one magnetic member comprising a magnet and an enveloping member, wherein the enveloping member further comprises one of a metal foil or metallic coating configured to shield the magnet during microwave cooking... | The complaint's global allegation that the Accused Products comprise "each and every element" of the claim implies the presence of a shielded magnetic assembly. | ¶37 | col. 7:30-34 |
- Identified Points of Contention:
- Technical Questions: A central technical question will be whether the Defendants' products actually contain the specific shielding element required by both asserted independent claims: a "metal foil or metallic coating configured to shield the magnet." The patent specification links this shielding to creating a "Faraday Cage" effect (Compl., Ex. A, '802 Patent, col. 5:59-64). The infringement analysis may hinge on evidence demonstrating that the accused magnetic assemblies are not merely magnets in plastic but include this specific shielding configuration.
- Scope Questions: The term "leg posts" in Claim 1 is described as protruding from the rim to facilitate airflow (Compl., Ex. A, '802 Patent, col. 4:34-37). A question for the court may be how to construe this term and whether the specific structures on the accused products meet this limitation, either literally or under the doctrine of equivalents.
V. Key Claim Terms for Construction
The Term: "configured to shield the magnet"
Context and Importance: This limitation appears in both asserted independent claims (Compl., Ex. A, '802 Patent, col. 8:1-34; col. 9:1-15). Its construction will be critical, as it requires more than just a magnet; it requires a magnet with a specific protective feature. Practitioners may focus on this term because it presents a potentially high bar for infringement that may not be met by a simple counterfeit product that omits this less-visible technical feature.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that any material enveloping the magnet that incidentally provides some shielding effect meets the limitation, focusing on the word "configured" as relating to the overall assembly's purpose.
- Evidence for a Narrower Interpretation: The specification provides a specific technical purpose for the shield, stating it creates a "'Faraday Cage' or 'Faraday Shield' effect which shields the magnet from radio frequency (RF) or electromagnetic energy or waves (e.g., microwaves)" (Compl., Ex. A, '802 Patent, col. 5:59-64). A party could argue this language defines "configured to shield" as requiring a structure capable of producing this specific electromagnetic effect, thereby narrowing the claim scope to structures with more than just a plastic or non-metallic covering.
The Term: "integrated into the housing member"
Context and Importance: This term, appearing in both asserted claims, describes the relationship between the magnetic assembly and the main body of the cover. Its definition could be dispositive if Defendants' products attach their magnets differently than what is contemplated by the patent.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term could be argued to cover any permanent or semi-permanent attachment, including gluing or snap-fitting the magnet assembly to the housing's surface.
- Evidence for a Narrower Interpretation: The specification describes specific methods for integration, such as "insert injection molding techniques to encase or envelop a magnetic member" (Compl., Ex. A, '802 Patent, col. 5:20-22) and "ultrasonic welding techniques" (Compl., Ex. A, '802 Patent, col. 5:35-37). Figures 5D and 5F depict the magnet fully encased within the plastic body. A party may argue "integrated into" requires the magnet to be encased within, not merely attached to the surface of, the housing.
VI. Other Allegations
- Indirect Infringement: The complaint does not contain a formal count for indirect infringement. However, it alleges facts that could support such a claim, noting that Defendants provide "instruction guides on how to use the Accused Products" Compl. ¶10, which may be construed as evidence of inducing infringement by end-users.
- Willful Infringement: The complaint alleges that Defendants are infringing "knowingly and intentionally, or at least with reckless disregard or willful blindness" Compl. ¶29 This allegation is supported by claims that Defendants use Plaintiff's own "Hover Cover" brand name, suggesting actual knowledge of Plaintiff's product, and engage in deceptive practices to conceal their identity Compl. p. 2 Compl. ¶21 Compl. ¶23
VII. Analyst's Conclusion: Key Questions for the Case
This case presents issues common to online enforcement against foreign sellers, blending technical patent questions with procedural challenges. The key questions for the court will likely be:
- A core evidentiary question of technical composition: Can the Plaintiff prove, through reverse engineering or other discovery, that the Defendants' mass-produced, low-cost Accused Products include the specific "metal foil or metallic coating configured to shield the magnet" as required by the asserted claims, or is this a technical nuance omitted in the alleged copies?
- A question of damages and remedy: Assuming infringement is found, what is the appropriate remedy against a diffuse and potentially transient group of foreign sellers? The allegations of willfulness, based on the use of Plaintiff's branding and other deceptive conduct, will be central to Plaintiff's effort to secure enhanced damages and meaningful injunctive relief, potentially through the enforcement mechanisms of the e-commerce platforms themselves.