Think Green (Haakaa) vs. Medeia: Design Patent Dispute Settled over Haakaa Generation 2 Breast Pump
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📋 Case Summary
| Case Name | Think Green Limited v. Medeia |
| Case Number | 1:21-cv-05445 (N.D. Ill.) |
| Court | Northern District of Illinois |
| Duration | Oct 2021 – Mar 2026 4 years 5 months |
| Outcome | Settled — Stipulated Dismissal |
| Patents at Issue | |
| Accused Products | Medeia Silicone Breast Milk Collector |
Case Overview
The Parties
⚖️ Plaintiff
New Zealand-based consumer goods company widely credited with popularizing the passive silicone breast pump category globally. Its Haakaa pump has strong market penetration.
🛡️ Defendant
Competitor in the silicone breast milk collector market, offering products functionally and aesthetically similar to Haakaa’s flagship design.
The Patent at Issue
This case involved U.S. Design Patent **USD808006S** (Application No. 29/583,901) covering the ornamental appearance of the Generation 2 Haakaa breast pump. Design patents, registered with the U.S. Patent and Trademark Office (USPTO), protect visual characteristics, not function.
- • US D808,006S — Ornamental design of the Haakaa Generation 2 breast pump
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The Verdict & Legal Analysis
Outcome
The case concluded on **March 9, 2026**, via **stipulated dismissal under Fed. R. Civ. P. 41(a)(1)(A)(ii)**. All claims and counterclaims were dismissed with prejudice, **except Medeia’s Counterclaim Count I (design patent invalidity) which was dismissed without prejudice**. Each party agreed to bear its own costs, expenses, and attorney fees. No damages award or injunctive relief was publicly reported.
Key Legal Issues
The most legally significant element of this dismissal is the **deliberate preservation of Medeia’s invalidity counterclaim**. By securing a *without-prejudice* dismissal, Medeia retained the right to challenge the validity of USD808006S in future proceedings. This signals Medeia was not fully satisfied with the patent’s validity, and Think Green accepted this carve-out, suggesting an interest in avoiding a definitive invalidity ruling that could extinguish their design patent rights entirely.
Under the **ordinary observer test** established in *Egyptian Goddess, Inc. v. Swisa, Inc.* (Fed. Cir. 2008), design patent infringement requires that an ordinary observer, familiar with the prior art, would find the accused product substantially the same as the claimed design. Medeia’s invalidity counterclaim implies the defense identified prior art that could narrow or negate this scope, providing significant leverage in settlement discussions.
Freedom to Operate (FTO) Analysis for Maternal Care Devices
This case highlights critical IP risks in consumer health design. Choose your next step:
📋 Understand This Case’s Impact
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High Risk Area
Silicone breast pump/collector designs
Prior Art Considerations
Specific prior art identified in invalidity defense
Design-Around Options
Available for most claims
✅ Key Takeaways
Stipulated dismissals with strategic without-prejudice carve-outs are powerful resolution tools in design patent cases, preserving defendant options.
Search related case law →The *Egyptian Goddess* ordinary observer standard makes prior art scope central to both infringement and invalidity analysis in design patent litigation.
Explore precedents →Frequently Asked Questions
U.S. Design Patent USD808006S (Application No. 29/583,901), covering the ornamental design of the Haakaa Generation 2 silicone breast pump.
Medeia’s design patent invalidity counterclaim (Count I) was preserved without prejudice, meaning Medeia can reassert the invalidity challenge in future proceedings — a strategic concession by Think Green to avoid a definitive court ruling on patent validity.
It reinforces that design patent enforceability in consumer health products is vulnerable to prior art challenges, and that defendants with credible invalidity positions can leverage them effectively in settlement negotiations.
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References & Further Reading
- United States District Court, N.D. Illinois – Think Green Limited v. Medeia, No. 1:21-cv-05445
- U.S. Patent and Trademark Office — Design Patent Resources
- Egyptian Goddess, Inc. v. Swisa, Inc., 543 F.3d 665 (Fed. Cir. 2008)
- Cornell Legal Information Institute — Federal Rules of Civil Procedure Rule 41 (Dismissal of Actions)
- PatSnap — IP Intelligence Solutions for Consumer Products
This article is for informational purposes only and does not constitute legal advice. All case information is drawn from publicly available court records. For platform capabilities, visit PatSnap.