Marmon Foodservice Technologies, Inc. v. Duke Manufacturing Co.

District Court, E.D. Missouri·Decided September 3, 2026·No. 4:25-cv-01491·Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

MARMON FOODSERVICE ) TECHNOLOGIES, INC., ) ) Plaintiff, ) ) v. ) Case No. 4:25-CV-1491-ZMB ) DUKE MANUFACTURING CO., ) ) Defendant. )

MEMORANDUM AND ORDER Before the Court is Defendant Duke Manufacturing’s Motion to Partially Dismiss the Complaint. Doc. 24. Because Plaintiff Marmon Foodservice Technologies has not established prior knowledge of the relevant patents, the Complaint fails to state a claim for induced, contributory, and willful theories of patent infringement. But Marmon has pled a facially plausible design patent infringement claim, so Counts VIII and IX survive at this stage. As such, the Court grants in part and denies in part the motion for partial dismissal. BACKGROUND I. Factual Background1 Marmon is a leading manufacturer of foodservice equipment, supplying major restaurant chains like Burger King. Doc. 1 ¶¶ 36–37, 39, 41. Duke is a competitor that sells to some of the same customers. Id. ¶ 38. In 2015, Marmon’s predecessor introduced a new food-holding oven product known as the “Extended Holding Bin” (EHB). Id. ¶ 40. The EHB product features “innovative technology” that allows foodservice providers to “enhance holding times and product quality” through “independently controllable temperature zones.” Id. ¶ 41.

1 As required at this stage, the Court accepts as true the well-pled facts from the Complaint. See Doc. 1; infra at 3–4. In 2016, after Marmon gained market share with its multi-zone technology, Duke launched a “copycat product.” Id. ¶¶ 43, 45. Like Marmon’s EHB product, Duke’s HS2 holding bin has independently controllable temperature zones that enhance holding times and product quality. Id. ¶ 46. Duke later introduced the ReadyFlex holding bin, which boasts the same features. Id. ¶¶ 47–49. Between these two products, Marmon claims that Duke infringed on seven utility patents and two design patents it owns for food-holdings bins. Id. ¶¶ 7–33 (detailing relevant patents). II. Procedural Background Marmon brought this action in October 2025, asserting nine counts for the infringement of these patents. Id. ¶¶ 73–163. The utility patent infringement counts advance three distinct claims for violations of 35 U.S.C. § 271(a), (b), and (c). Id. ¶¶ 73–149. Likewise, the design patent infringement counts assert two distinct claims for violations of 35 U.S.C. §§ 271(a) and 289. Id. ¶¶ 150–163. All counts assert willful infringement, id. ¶¶ 82–162, and Marmon also seeks injunctive relief, treble damages, interest, and attorney’s fees and costs. Id. at 24–25. Duke moved to partially dismiss the Complaint. Doc. 24. Specifically, Duke targets the section 271(b)–(c) claims in Counts I–VII, the willful infringement claims, and Counts VIII and IX in their entirety, arguing that those claims rely on conclusory statements or fail as a matter of law. Id. Marmon opposed dismissal, and after Duke replied, the motion is ripe for review. Docs. 30, 32. LEGAL STANDARD “Federal Circuit law governs questions of patent law, while the law of the regional circuit applies to procedural questions that are not specific to patent law.” Furminator v. Ontel Prods. Corp., 246 F.R.D. 579, 583 (E.D. Mo. 2007) (citing Madey v. Duke Univ., 307 F.3d 1351, 1358 (Fed. Cir. 2002)); see also Fair Isaac Corp. v. Fed. Ins. Co., 763 F. Supp. 3d 800, 805 n.5 (D. Minn. 2025) (same). The general standard for dismissal under Rule 12(b)(6) is “a matter of procedure” that calls for the application of regional circuit precedent. Deere & Co. v. Kinze Mfg., 2023 WL 9472300, at *5 (S.D. Iowa May 1, 2023) (citing Ferguson Beauregard/Logic Controls v. Mega Sys., 350 F.3d 1327, 1334 (Fed. Cir. 2003)). However, “the specific question of whether a complaint states a claim of patent infringement” is governed by Federal Circuit law. AlexSam v. Aetna, 119 F.4th 27, 35 (Fed. Cir. 2024). I. Motions to Dismiss for Failure to State a Claim in the Eighth Circuit Under Federal Rule of Civil Procedure 12(b)(6), a defendant may move to dismiss for “failure to state a claim upon which relief can be granted.” The purpose of such motions “is to test the legal sufficiency of the complaint.” Ford v. R.J. Reynolds Tobacco Co., 553 F. Supp. 3d 693, 697 (E.D. Mo. 2021). To survive a Rule 12(b)(6) motion, the complaint must include “a short and plain statement of the claim showing that the [plaintiff] is entitled to relief” and providing notice of the grounds on which the claim rests. Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007) (quoting FED. R. CIV. P. 8(a)(2)). Additionally, the complaint must include sufficient detail to make

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Marmon Foodservice Technologies, Inc. v. Duke Manufacturing Co., (E.D. Mo. 2026).

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