IP Law Daily, PATENT—D. Del.: Seakeeper denied preliminary injunction and TRO against Dometic in gyroscope patent dispute, (Jul 8, 2025)

By Saurabh Kashyap, B.A., M.A., LL.B., LL.M.

Seakeeper had not shown a likelihood of success on the merits due to a substantial obviousness challenge against the asserted patent and failed to establish irreparable harm.

A Delaware federal court denied Seakeeper Inc.'s motions for a preliminary injunction and temporary restraining order (TRO) in its infringement lawsuit against Dometic Corporation, holding that Seakeeper failed to establish a likelihood of success on the merits or irreparable harm warranting injunctive relief. Although the court found that Dometic’s accused gyrostabilizer DG3 likely infringed the asserted patent, it concluded that the patent claims faced a strong prima facie case of obviousness, precluding the interim relief (Seakeeper Inc. v. Dometic Corp., No. 1:25-cv-00484-JCB (D. Del. July 7, 2025)).

Background. The plaintiff, Seakeeper Inc., is a Maryland-based marine technology firm that designs and sells gyroscopic stabilizers that reduce boat roll at low speeds or while at rest. The defendant, Dometic Corporation, is a Delaware company and a U.S. subsidiary of Dometic Group AB, a Swedish multinational that manufactures marine and vehicle equipment. Dometic launched the DG3 marine stabilizer in 2025 as a potential rival to Seakeeper’s products.

In this lawsuit, Seakeeper asserted its U.S. Patent Nos. 7,546,782 (the ’782 patent) and 8,117,930 (the ’930 patent). However, only the ’782 patent was relevant for the purposes of this motion. The ’782 patent is titled "Cooling Apparatus for a Flywheel Device," which addresses heat dissipation generated by high-speed flywheels used in gyroscopic stabilizers for small boats. The invention claims a system of interleaved cylindrical vanes, some rotating with the flywheel and others fixed to the enclosure, that transfer heat from the spinning member through the enclosure to the exterior. The asserted claim, dependent claim 17, specifies that the apparatus is used in a boat’s gyroscopic roll stabilizer.

Seakeeper sued Dometic on April 21, 2025, alleging that the DG3 product infringed claim 17 of the ’782 patent. The company sought a preliminary injunction and TRO in May 2025 to block the DG3’s June shipment, arguing that it would cause irreparable competitive harm. Dometic responded that its device used a different, actively cooled system that avoided the patented configuration.

Substantial validity. Although the court agreed with Seakeeper that the DG3 was likely to infringe the ’782 patent’s cooling architecture, finding that some heat from the DG3’s vanes could reach the enclosure’s exterior, the court ultimately ruled against Seakeeper because Dometic had raised a “strong prima facie case of obviousness.” This conclusion stemmed from four prior art references: the Adams publication (by the same inventors), which disclosed a similar gyroscope needing cooling; the Sibley patent, which taught interleaved cooling fins in a vacuum enclosure; the Jäger publication, which dissipated bearing heat via shaft-mounted fins; and the Bimshas patent, which disclosed cylindrical interleaved vanes for heat transfer.

Applying the test from Graham v. John Deere Co., 383 U.S. 1 (1966), the court concluded that all claim limitations of the ’782 patent were disclosed in the prior art, and that a person of ordinary skill in the art would have had ample reason to combine them. The court cited the Supreme Court’s decision in KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398 (2007), for the proposition that common-sense combinations addressing known problems, such as dissipating heat in high-speed rotating systems, could render a patent obvious.

The court also noted that Seakeeper’s arguments concerning differences in use environments (energy storage vs. marine stabilization) did not diminish the substantial overlap in the underlying engineering challenges. Although Seakeeper highlighted minor distinctions and design choices in the cited references, the court found these insufficient to overcome the strong showing of obviousness.

Secondary considerations. Seakeeper argued that its commercial success, industry praise, and pioneering status in the marine gyroscope market weighed against a finding of obviousness. It claimed that its gyrostabilizers had solved a long-felt industry problem, overcome initial skepticism, and achieved strong market recognition. However, the court found that Seakeeper failed to establish the required nexus between the patented features, particularly the ability to “readily transfer heat” to the enclosure’s exterior, and its commercial achievements.

Citing Fox Factory, Inc. v. SRAM, LLC, 944 F.3d 1366 (Fed. Cir. 2019), and Wyers v. Master Lock Co., 616 F.3d 1231 (Fed. Cir. 2010), the court emphasized that market success must result from the novel aspects of the claimed invention, not marketing or unrelated technical features. The breadth of claim 11 made this connection difficult to prove, especially since Seakeeper’s commercial products included additional cooling mechanisms beyond what was claimed.

Infringement likely, but not decisive. On infringement, the court adopted a preliminary construction of “exterior of the enclosure” to mean the enclosure’s outer surface. Under this interpretation, it found that the DG3’s cooling vanes, which made metal-on-metal contact with the enclosure, likely enabled some heat to reach the device’s surface, even if the primary heat dissipation method involved liquid coolant loops. This was sufficient for Seakeeper to meet the infringement prong under Trebro Mfg., Inc. v. Firefly Equip., LLC, 748 F.3d 1159 (Fed. Cir. 2014).

Nonetheless, the Federal Circuit’s decision in BlephEx, LLC v. Myco Indus., Inc., 24 F.4th 1391 (Fed. Cir. 2022) guided the court's conclusion that a substantial question of validity alone can defeat an injunction request, regardless of the infringement showing.

Harm not irreparable. The court also rejected Seakeeper’s assertion that it faced irreparable harm. While it acknowledged that Seakeeper would likely lose market share and may face price erosion due to DG3 competition, it held that such losses were “clearly quantifiable.” Noting that Seakeeper’s patents expire in under two years, the court found that any temporary exclusivity loss could be compensated with monetary damages. It relied on ActiveVideo Networks, Inc. v. Verizon Commc’ns, Inc., 694 F.3d 1312 (Fed. Cir. 2012), to support its conclusion that even short-term harms must be shown to be legally irreparable.

Seakeeper’s arguments about loss of customer goodwill, erosion of brand identity, and negative impacts on R&D investment were found to be speculative or unsubstantiated. Moreover, Dometic’s financial strength and willingness to pay damages weighed against the need for equitable relief.

Mootness and jurisdiction. The court also rejected Dometic’s argument that Seakeeper’s motions were moot due to an alleged product redesign. Citing Friends of the Earth, Inc. v. Laidlaw Env’t Servs. (TOC), Inc., 528 U.S. 167 (2000), the court held that Dometic failed to meet the “formidable standard” of making it “absolutely clear” that the allegedly infringing conduct would not recur.

On the jurisdictional front, the court found it had general personal jurisdiction over Dometic Corporation (a Delaware entity), and that Seakeeper had sufficiently tied Dometic’s own conduct, such as website sales and trade show demonstrations, to the accused DG3 product. Even though Dometic Marine Canada (DMC) designed and manufactured the DG3, the court found a preliminary agency relationship between DMC and Dometic Corporation based on co-branding, shared promotional materials, and overlapping personnel. Nevertheless, the court declined to enjoin DMC directly, citing Additive Controls & Measurement Sys., Inc. v. Flowdata, Inc., 96 F.3d 1390 (Fed. Cir. 1996), but left open the possibility of contempt proceedings if DMC aided or abetted future violations.

The Case is No. 1:25-cv-00484-JCB.

Judge: Barker, J.

Attorneys: Kelly E. Farnan (Richards, Layton & Finger, PA) for Seakeeper Inc. Andrew Colin Mayo (Ashby & Geddes, P.A.) for Dometic Corp.

Companies: Seakeeper Inc.; Dometic Corp.

Cases: Patent DelawareNews GCNNews