Baby Jogger, LLC v. Baby Generation, Inc. d/b/a Mockingbird

District Court, D. Delaware·Decided September 16, 2026·No. 1:24-cv-00725·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE BABY JOGGER, LLC, Plaintiff, v. Civil Action No. 24-725-GBW BABY GENERATION, INC. d/b/a MOCKINGBIRD, Defendant.

MEMORANDUM ORDER Pending before the Court is Defendant Baby Generation, Inc. d/b/a Mockingbird’s (“Baby Generation” or “Defendant”) Motion to Dismiss Plaintiff Baby Jogger, LLC’s (“Baby Jogger” or “Plaintiff’) First Amended Complaint (D.I. 18) (“Defendant’s Motion”), which has been fully briefed. D.I. 19; D.I. 20; D.J. 21. For the reasons set forth below, the Court grants-in-part and denies-in-part Defendant’s Motion. I. BACKGROUND The following are factual allegations from Plaintiff's First Amended Complaint (D.I. 14) that are taken as true for the purpose of resolving Defendant’s Motion. Plaintiff is the assignee of five patents relating to a seat attachment for a stroller: U.S. Patent Nos. 8,955,869 (the “’869 Patent”), 9,403,550 (the “550 Patent”), 11,192,568 (the “568 Patent”), 11,505,231 (the “’231 Patent”), and 11,878,729 (the “’729 Patent”) (together, the “Asserted Patents”). D.I. 14 at 3-10; but see D.I. 19 at 1-2 (disputing whether Plaintiff holds rights to the ’869, ’550, °231, and ’729 Patents). Defendant “makes, uses, sells, and/or offers to sell in the United States” various products which infringe the Asserted Patents, including the “Mockingbird Single-to-Double Stroller (2023 model) and Mockingbird Single-to-Double Stroller

2.0, [] when used in combination with its 2nd Seat Kit (2023 model) or 2nd Seat Kit 2.0.” D.I. 14 741. The 2nd Seat Kit (2023 model) and 2nd Seat Kit 2.0 “allow the Mockingbird Single-to- Double Stroller (2023 model) and Mockingbird Single-to-Double Stroller 2.0 to convert from a single stroller into a double stroller.” Jd. 4 42. Plaintiff filed the Original Complaint in this action on June 18, 2024, alleging direct infringement of various claims of the Asserted Patents, and willful, induced, and contributory infringement of the 550, °568, ’231, and ’729 Patents. D.I. 1. Plaintiff filed the operative Amended Complaint on September 9, 2024, in which it withdrew its willful infringement allegations. D.I. 14. Il. LEGAL STANDARDS A. Standing Once a court’s jurisdiction is challenged, it must presume that it lacks jurisdiction unless the party asserting that jurisdiction exists can prove otherwise. G. W. v. Ringwood Bd. of Educ., 28 F.4th 465, 468 (3d Cir. 2022); accord Carney v. Adams, 592 U.S. 53, 59 (2020) (“[Plaintiff] bears the burden of establishing standing as of the time he brought this lawsuit and maintaining it thereafter.”). “Under [Rule] 12(b)(1), a court must grant a motion to dismiss if it lacks subject- matter jurisdiction to hear a claim.” Shibles v. Bank of Am., N.A., 730 F. App’x 103, 105 (3d Cir. 2018) (alteration in original) (quoting Jn re Schering Plough Corp. Intron/Temodar Consumer Class Action, 678 F.3d 235, 243 (3d Cir. 2012)). Article III of the United States Constitution extends “[t]he judicial Power” only to “Cases” and “Controversies.” U.S. Const. art. III, § 2. Thus, the plaintiff must have “a personal stake in the case — in other words, standing.” TransUnion LLC v. Ramirez, 594 U.S. 413, 423 (2021) (internal quotation marks and citation omitted). “Absent Article III standing, a federal court does not have subject matter jurisdiction to address a plaintiff's claims, and they must be dismissed.” Davis, 824 F.3d at 346 (citation omitted). “To establish

standing, a plaintiff must show ‘(i) that he suffered an injury in fact that is concrete, particularized, and actual or imminent; (ii) that the injury was likely caused by the defendant; and (iii) that the injury would likely be redressed by judicial relief.’” Boley v. Universal Health Servs., Inc., 36 F.4th 124, 130-31 (d Cir. 2022) (quoting TransUnion, 594 U.S. at 423). Courts traditionally recognize “physical harms and monetary harms” as “providing a basis for a lawsuit ... .” TransUnion, 594 U.S. at 423. “For an injury to be ‘particularized,’ it ‘must affect the plaintiff in a personal and individual way.’” Spokeo, Inc. v. Robins, 578 U.S. 330, 339 (2016), as revised (May 24, 2016) (citation omitted). In addition to Article III standing, a party asserting patent infringement must have a right to sue under 35 U.S.C. § 281, which affords “patentee[s]” the right to sue for infringement. 35 U.S.C. § 281. “The term patentee includes the original patentee (whether the inventor or original assignee) and ‘successors in title.’” Lone Star Silicon Innovations LLC v. Nanya Tech. Corp., 925 F.3d 1225, 1229 (Fed. Cir. 2019) (quoting 35 U.S.C. § 100(d)). Ifthe party asserting infringement is not the original patentee, the party must possess “all substantial rights to the patents,” i.e., have been assigned substantial rights to the patent, to have a right to sue under § 281. Jd. Otherwise, if the party merely has a license to the patent, “it may still bring suit along with the patentee so long as it possesses ‘exclusionary rights.’” Jd. (emphasis added) The Federal Circuit has held that the right to sue under § 281 “does not implicate standing or subject-matter jurisdiction.” Jd at 1235. B. Motion to Dismiss Under Rule 12(b)(6) “To state a viable claim, a plaintiff must offer a short and plain statement showing that he is entitled to relief, including ‘allegations plausibly suggesting (not merely consistent with)’ such entitlement.” Bah v. United States, 91 F.4th 116, 119 Gd Cir. 2024) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 557 (2007)). A complaint must include more than mere “labels and

Free access — add to your briefcase to read the full text and ask questions with AI

Baby Jogger, LLC v. Baby Generation, Inc. d/b/a Mockingbird, (D. Del. 2026).

Baby Jogger, LLC v. Baby Generation, Inc. d/b/a Mockingbird (Baby Jogger, LLC v. Baby Generation, Inc. d/b/a Mockingbird) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Lujan v. Defenders of Wildlife
504 U.S. 555 (Supreme Court, 1992)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Mayer v. Belichick
605 F.3d 223 (Third Circuit, 2010)
Fujitsu Limited v. Netgear Inc.
620 F.3d 1321 (Federal Circuit, 2010)
United States v. Auckland Holmes
452 F.2d 249 (Seventh Circuit, 1972)
Hunt Ltd. v. Lifschultz Fast Freight, Inc.
889 F.2d 1274 (Second Circuit, 1989)
General Refractories Co. v. First State Insurance
500 F.3d 306 (Third Circuit, 2007)
Utility Lines Construction Services Inc. v. Hoti, Inc.
799 F. Supp. 2d 331 (D. Delaware, 2011)
Wright v. Cuyler
517 F. Supp. 637 (E.D. Pennsylvania, 1981)
Wood v. Moss
134 S. Ct. 2056 (Supreme Court, 2014)
Spokeo, Inc. v. Robins
578 U.S. 330 (Supreme Court, 2016)
Intellectual Ventures I LLC v. Erie Indemnity Company
850 F.3d 1315 (Federal Circuit, 2017)
Lifetime Industries, Inc. v. Trim-Lok, Inc.
869 F.3d 1372 (Federal Circuit, 2017)