On Monday, Impossible Foods Inc. filed its first amended complaint in the Delaware District Court against Motif FoodWorks, Inc. alleging patent infringement.
According to the complaint, Impossible Foods is a Delaware corporation headquartered in California that develops and distributes plant-based meat products including the Impossible Burger. Further, the complaint states that Motif is a Delaware corporation headquartered in Massachusetts that advertises itself as a provider of plant-based food ingredients, ingredient systems and finished formulations of plant-based food.
The complaint states that Impossible Foods has several registered products for its plant-based meat products including the methods and composition of its plant-based foods that imitate the texture, taste, appearance and aroma of meat. The complaint states that Impossible Foods products imitate meat by incorporating soy-derived heme, a molecule that gives meat its bloody taste when raw and creates the intense, meaty flavors and aromas when it’s cooked.
The complaint states that in the summer of 2021, Motif partnered with a Dalla- based restaurant chain, Coolgreens, to produce and sell meat replicas containing HEMAMI and is now selling HEMAMI to customers to integrate it into their own plant-based meat alternatives. Impossible Foods alleges that HEMAMI and the plant-based meat alternatives produced by Motif infringe on its patents including its patents for the methods and composition of heme.
The complaint alleges that Motif had opportunities to obtain non-public information regarding Impossible Foods’ proprietary methods of making its proprietary heme-containing protein which it exploited to produce and sell HEMAMI. Further, Impossible Foods alleges that Motif was and is currently aware that the inclusion of HEMAMI in meat replica products violates Impossible Foods’ patent rights and that Motif actively claims that HEMAMI is a substitute for Impossible Foods’ patented technology.
Accordingly, Impossible Food’ filed the present complaint alleging patent infringement of five of its registered patents and seeking declaratory relief stating that Motif willfully infringed on the patents, injunctive relief, pre- and post-judgment interest and attorney’s fees.