Ningbo Peitebobi Chongwu Yongping Ltd v. SharkNinja Operating LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Ningbo Peitebobi Chongwu Yongping Ltd. (People's Republic of China)
  • Defendant: SharkNinja Operating LLC (Delaware)
  • Plaintiff’s Counsel: Glacier Law LLP
• Case Identification: 2:26-cv-00474, W.D. Wash., 02/09/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Washington because Defendant purposefully directed patent enforcement activities into the district by initiating an Amazon patent-enforcement proceeding that foreseeably caused actions by Amazon personnel located in Seattle, constituting a substantial part of the events giving rise to the action.
• Core Dispute: Plaintiff seeks a declaratory judgment that its air fryer products do not infringe Defendant's U.S. Patent No. 12,426,739 and that the patent is invalid.
• Technical Context: The dispute centers on the mechanical and structural design of countertop air fryers, a popular category of kitchen appliances that cook food by circulating heated air.
• Key Procedural History: The complaint was precipitated by Defendant's submission of a patent infringement report to Amazon, which resulted in the removal of Plaintiff's air fryer product listing from the online marketplace. Plaintiff also raises invalidity arguments based on several prior art references.

Case Timeline

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

U.S. Patent No. 12,426,739 - "Cooking Devices and Components Thereof"

• Patent Identification: U.S. Patent No. 12,426,739, "Cooking Devices and Components Thereof," issued September 30, 2025 (the "’739 Patent").

The Invention Explained

• Problem Addressed: The patent background describes air fryers as a popular kitchen appliance for cooking with less oil than traditional deep-fryers ʼ739 Patent, col. 1:28-44 The summary suggests a need for versatile cooking systems that can accommodate different cooking operations and vessel sizes ʼ739 Patent, col. 3:50-59
• The Patented Solution: The invention describes a modular cooking system where a removable cooking device, containing a heating element and an air movement device, can be positioned over a vessel to create a cooking chamber ʼ739 Patent, abstract The patent discloses various mechanical and structural configurations for the vessel and its base, including specific handle arrangements and locking mechanisms designed for stability, thermal insulation, and user safety ʼ739 Patent, col. 11:24-67 ʼ739 Patent, col. 12:20-47
• Technical Importance: The technology aims to provide structural improvements for air fryer vessel assemblies, focusing on how a base or handle structure attaches to and supports a cooking pot for improved thermal management and mechanical stability ʼ739 Patent, col. 12:12-19 ʼ739 Patent, col. 12:57-64

Key Claims at a Glance

• The complaint identifies independent claims 1, 7, and 14 as being central to the non-infringement dispute Compl. ¶¶31-33
• Independent Claim 1:
  • A vessel assembly comprising a unitary vessel with a top opening and closed bottom.
  • A U-shaped base fixed to opposed sidewalls of the vessel.
  • The base is configured to rest on a support surface and support the closed bottom of the vessel.
• Independent Claim 7:
  • A vessel assembly comprising a vessel with a cavity and an opening.
  • A handlebar positioned under the vessel and configured to be contacted by a user, with the handlebar extending upward along a portion of the vessel's height.
  • A gap positioned between the vessel wall and the handlebar, configured as a thermal break.
• Independent Claim 14:
  • A vessel assembly comprising a vessel with a sidewall having a first indent and a first detent.
  • A base positioned below the vessel.
  • A connector plate extending from the base with a second indent and a second detent, where the first detent is received in the second indent and the second detent is received in the first indent.
  • The connector plate is flexible.
• The complaint notes that because the independent claims are not infringed, the associated dependent claims (2-6, 8-13, and 15-23) are also not infringed Compl. ¶¶31-33

III. The Accused Instrumentality

Product Identification

• Plaintiff's "Air Fryer" products sold on Amazon.com Compl. ¶¶10, 23

Functionality and Market Context

• The complaint describes the accused product's features primarily in the context of distinguishing them from the ’739 Patent's claims.
• Relative to Claim 1, the product is alleged to have a "continuous peripheral wall that encloses the bottom of the vessel on all sides," which functions as a "receptacle" or "housing," not a "U-shaped base" Compl. ¶31
• Relative to Claim 7, the product's handle structures are described as being "attached to the exterior periphery of the base housing" and positioned "laterally adjacent to the sidewalls," rather than "vertically beneath the vessel's bottom surface" Compl. ¶32 The product also allegedly lacks a "gap configured as a 'thermal break'" and instead uses an interface with "direct mechanical contact via reinforcing ribs" Compl. ¶32
• Relative to Claim 14, the product is alleged to feature a "single 'protruding lock bolt' (or locking tongue)" and lacks the claimed reciprocal "indent" on the sidewall Compl. ¶33 Further, its handlebar assembly is described as "rigid and non-flexible," not a "flexible" connector plate Compl. ¶33
• Plaintiff alleges that Amazon is its primary sales channel in the United States and that the delisting caused by Defendant's infringement report has resulted in significant harm Compl. ¶¶13-14 No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement. The following tables summarize the Plaintiff's allegations regarding the structural differences between its product and the patent's claims.

’739 Patent Infringement Allegations

’739 Patent Infringement Allegations

’739 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A primary dispute will concern the interpretation of structural and positional terms. For instance, does the term "U-shaped base" read on a structure that fully encloses the vessel's bottom Compl. ¶31? Does "positioned under the vessel" require a location vertically beneath the bottom surface, or can it encompass structures that are laterally adjacent to the sidewalls Compl. ¶32?
  • Technical Questions: The analysis may require factual determinations about the function of the accused device's components. For example, does the alleged "direct mechanical contact via reinforcing ribs" in the accused product's handle assembly preclude the existence of a "gap configured to be a thermal break" as claimed Compl. ¶32? Does a "single 'protruding lock bolt'" satisfy the "reciprocal 'indent and detent' arrangement" required by claim 14 Compl. ¶33?

V. Key Claim Terms for Construction

• The Term: "U-shaped base" (from Claim 1)

• Context and Importance: This term is central to the non-infringement argument for Claim 1. Plaintiff contends its product's fully enclosed "continuous peripheral wall" cannot be "U-shaped," which it argues implies openness on two sides Compl. ¶31 The court's construction of this term may determine infringement of Claim 1 and its dependents.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent does not appear to provide an explicit definition. Defendant may argue that "U-shaped" refers to the vertical cross-section of the base, as depicted in Claim 23 ("The cooking vessel of claim 1, wherein the U-shaped base is U-shaped at a vertical cross-section of the base") ʼ739 Patent, col. 42:32-34, and does not require the overall base to be open on two sides.
  • Evidence for a Narrower Interpretation: Plaintiff may point to the common understanding of "U-shaped" as a three-sided structure and argue that the specification does not redefine it. The complaint also raises the possibility of prosecution history estoppel, suggesting the term was added to narrow the claim scope Compl. ¶¶31-32

• The Term: "handlebar positioned under the vessel" (from Claim 7)

• Context and Importance: Plaintiff's non-infringement argument for Claim 7 relies on its handles being "laterally adjacent" to the vessel, not "under" it Compl. ¶32 The construction of this positional term is therefore critical.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: Defendant may argue that "under the vessel" does not exclusively mean "vertically beneath the bottom surface" but could encompass any position below the vessel's top opening, including laterally adjacent to the lower portion of the vessel's sidewall.
  • Evidence for a Narrower Interpretation: Plaintiff may argue that the plain and ordinary meaning of "under" implies a vertical relationship. The patent specification discusses a "base positioned below a bottom surface of the vessel" in the context of a different claim (Claim 14), suggesting the patentee used more specific language when intending to define a vertical position relative to the bottom surface ʼ739 Patent, col. 42:7-8

VI. Other Allegations

The complaint does not provide sufficient detail for analysis of indirect or willful infringement.

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

This declaratory judgment action will likely focus on claim construction and the subsequent comparison of the construed claims to the accused product's structure. The central questions for the court appear to be:

• A core issue will be one of definitional scope: Can the term "U-shaped base," as used in the context of supporting a cooking vessel, be construed to cover a base with a "continuous peripheral wall" that fully encloses the vessel's bottom?
• A second key issue will be positional interpretation: Does the claim language "handlebar positioned under the vessel" require the handlebar to be located vertically beneath the vessel's bottom, or can it encompass handles that are attached to the exterior periphery and extend outward from the vessel's sides?
• A final question will be one of mechanical structure: Does the accused product's "single 'protruding lock bolt'" meet the claim requirement for a "reciprocal 'indent and detent' arrangement," and is its handlebar assembly "flexible" as required by the claim?