Ninja BL685 User manual

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
ANGELA CAPPELLETTI,
Plaintiff,
- against –
SHARKNINJA OPERATING, LLC
Defendant.
Docket No.: 2:23-cv-02144
COMPLAINT AND DEMAND FOR
JURY TRIAL
Plaintiff, by and through her attorneys, JOHNSON BECKER, PLLC and MILBERG
COLEMAN BRYSON PHILLIPS GROSSMAN, PLLC, upon information and belief, at all
times hereinafter mentioned, alleges as follows:
NATURE OF THE CASE
1. Defendant designs, manufactures, markets, imports, distributes and sells consumer
products such as blenders, including the subject “Ninja Blender,” which specifically includes the
BL685 model (referred to hereafter as "Ninja blender(s)”) that is at issue in this case.
2. The Ninja blenders are defectively designed and manufactured in that the unit’s
stacked blade assembly does not lock into place and is not secured to the gear shaft. When used
in its normal and intended manner by consumers, the blade assembly can fall out of the pitcher,
putting the user at risk of sustaining sever lacerations and injuries requiring medical attention. The
Ninja blenders pose a safety risk to consumers and to other individuals who may be in close
proximity to the Ninja blenders while they are in use.
3. Defendant knew or should have known of these defects, but has nevertheless put
profit ahead of safety by continuing to sell its Ninja blenders to consumers and failing to recall the
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dangerously defective Ninja blenders regardless of the risk of significant injuries to Plaintiff and
consumers like her.
4. Defendant ignored its knowledge of these defects in its Ninja blenders in order to
continue generating a profit from the sale of said Ninja blenders, demonstrating a callous, reckless,
willful, depraved indifference to the health, safety and welfare of Plaintiff and consumers like her.
5. As a direct and proximate result of Defendant’s conduct, the Plaintiff in this case
incurred significant and painful bodily injuries, medical expenses, physical pain, mental anguish,
and diminished enjoyment of life.
PLAINTIFF ANGELA CAPPELLETTI
6. Plaintiff is a resident and citizen of the city of Central Islip, County of Suffolk,
State of New York.
7. On or about March 26, 2020, Plaintiff suffered serious and substantial lacerations
as the direct and proximate result of the Ninja blender’s blade detaching from blade base during
the normal, intended use of the Ninja blender. The incident occurred as the result of the Ninja
blenders’ defect(s), namely, the Ninja blender’s use of an unsecured blade assembly.
DEFENDANT SHARKNINJA OPERATING, LLC
8. Defendant SharkNinja designs, manufacturers, markets, imports, distributes and
sells a variety of consumer products, including the subject Ninja blender. Defendant SharkNinja
is a Massachusetts Limited Liability Corporation incorporated in the State of Delaware and has a
principal place of business located at 89 A St. # 100, Needham, MA 02494. Defendant SharkNinja
has a registered service address Corporation Trust Center, 1209 Orange Street, Wilmington, DE
19801.
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9. At the time of the initiation of this lawsuit, the sole member of SharkNinja
Operating, LLC was EP Midco, LLC, a Massachusetts Limited Liability Company created and
organized under the law of the State of Delaware and located at 89 A St. # 100, Needham, MA
02494.
10. Accordingly, Defendant SharkNinja is a resident and citizen of the State of
Massachusetts for purposes of diversity jurisdiction under 28 U.S.C. § 1332.
JURISDICTION & VENUE
11. This Court has subject matter jurisdiction over this case pursuant to diversity
jurisdiction prescribed by 28 U.S.C. § 1332 because the matter in controversy exceeds the sum or
value of $75,000, exclusive of interest and costs, and there is complete diversity between the
parties.
12. Venue is proper in this Court pursuant to 28 U.S.C. §1391 because all or a
substantial part of the events or omissions giving rise to this claim occurred in this District.
13. Venue is also proper in this Court pursuant to 28 U.S.C. § 1391 because Defendant
has sufficient minimum contacts with the State of New York and intentionally availed itself of the
markets within New York through the promotion, sale, marketing, and distribution of its products.
FACTUAL BACKGROUND
14. Ninja blenders, including the Ninja blender that injured the Plaintiff, essentially
have three main components: a base unit which contains a high-speed motor and a gear shaft
(“motor base”); a pitcher, which locks on to the motor base; and a stacked blade assembly with six
sharp blades which is dropped onto the gear shaft (“blade assembly”). and a plastic lid mounted
with metal blades (“blade base”), which screws into the cup and is energized by the base.
15. To assemble the unit, the user first aligns and lowers the pitcher onto the motor
base, then rotates the pitcher clockwise until the pitcher locks in to place. Next the user takes the
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blade assembly and places it onto the gear shaft. Once the user has added the desired ingredients,
the lid is placed on top of the pitcher and locked into place.
See Ninja BL685 Owner’s Guide, pg. 5.
16. Unlike the pitcher and the pitcher lid, the blade assembly does not lock into place,
and is not otherwise secured to the gear shaft. Instead, the blade assembly sits “loosely on the drive
gear.”
1
17. As a result, if the user pours the pitcher after removing the lid, or if the lid falls off
the pitcher during pouring, the loose blade assembly can easily fall out of the pitcher and onto
consumers, resulting in physical injuries such as severe lacerations.
18. Defendant SharkNinja became aware of this defect as early as November 12, 2015,
when, in conjunction with the Consumer Product Safety Commission (CPSC), it recalled roughly
1.1 million of its Ninja BL660 series blenders for this exact defect.
2
1
See Ninja BL685 Owner’s Guide, pg. 8. A copy of the Owner’s Guide is attached hereto as
“Exhibit A.”
2
See the CPSC Recall Notice from November 12, 2015
(https://www.cpsc.gov/Recalls/2016/Laceration-Injuries-Prompt-SharkNinja-to-Recall-Ninja-
BL660-Blenders), a copy of which is attached hereto as “Exhibit B.”
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19. According to the CPSC, the firm received 53 reports of lacerations caused by the
stacked blade assembly falling out of the pitcher when consumers poured or inverted the pitcher
after removing the lid with the blade assembly still inside.3
20. Despite its knowledge of this defect, Defendant SharkNinja has continued to sell
and design blenders with loose, unsecured blade assemblies, including blenders like the BL685
blender involved in this case.
21. The Ninja blenders have been designed and manufactured such that consumers
cannot safely use them in the intended manner without risk of physical injury.
22. By reason of the forgoing acts or omissions, the above-named Plaintiff purchased
the Ninja blender with the reasonable expectation that it was properly designed and manufactured,
free from defects of any kind, and that it was safe for its intended, foreseeable use of blending.
23. Plaintiff used her Ninja blender for its intended purpose of preparing meals for
herself and/or family and did so in a manner that was reasonable and foreseeable by Defendant.
24. However, the aforementioned Ninja blender was defectively designed and
manufactured by Defendant in that its loose, unsecured blade assembly is able to fall out of the
pitcher during the normal, intended use of the Ninja blender, putting consumers, such as Plaintiff,
at risk of lacerations and other physical injuries.
25. Defendant’s Ninja blenders possess defects that make them unreasonably
dangerous for their intended use by consumers because the stacked blade assembly does not lock
into place and is not otherwise secured to the gear shaft.
26. Economic, safer alternative designs were available that could have prevented the
Ninja blender’s blade assembly from easily falling out of the pitcher when it is poured or inverted.
3Id.
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Examples of such designs include, but are not limited to, securing or affixing the blade assembly
to the gear shaft or designing a blade assembly that locks into place.
27. As a direct and proximate result of Defendant’s intentional concealment of such
defects, its failure to remove a product with such defects from the stream of commerce, and its
negligent design of such products, Plaintiff used an unreasonably dangerous blender, which
resulted in significant and painful bodily injuries.
28. Consequently, the Plaintiff in this case seeks damages resulting from the use of
Defendant’s blender as described above, which has caused the Plaintiff to suffer from serious
bodily injuries, medical expenses, physical pain, mental anguish, diminished enjoyment of life,
and other damages.
CLAIMS FOR RELIEF
COUNT I
STRICT LIABILITY
29. Plaintiff incorporates by reference each preceding and succeeding paragraph as
though set forth fully at length herein.
30. At the time of Plaintiff’s injuries, Defendant’s Ninja blenders were defective and
unreasonably dangerous for use by foreseeable consumers, including Plaintiff.
31. Defendant’s Ninja blenders were in the same or substantially similar condition as
when they left the possession of Defendant.
32. Plaintiff did not misuse or materially alter the Ninja blender.
33. The Ninja blenders did not perform as safely as an ordinary consumer would have
expected them to perform when used in a reasonably foreseeable way.
34. Further, a reasonable person would conclude that the possibility and serious of harm
outweighs the burden or cost of making the Ninja blenders safe. Specifically:
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a. The Ninja blenders designed, manufactured, sold, and supplied by Defendant were
defectively designed and placed into the stream of commerce in a defective and
unreasonably dangerous condition for consumers;
b. The seriousness of the potential burn injuries resulting from the product drastically
outweighs any benefit that could be derived from its normal, intended use;
c. Defendant failed to properly market, design, manufacture, distribute, supply, and
sell the Ninja blenders, despite having extensive knowledge that the
aforementioned injuries could and did occur;
d. Defendant failed to warn and place adequate warnings and instructions on the Ninja
blenders;
e. Defendant failed to adequately test the Ninja blenders; and
f. Defendant failed to market an economically feasible alternative design, despite the
existence of the aforementioned economical, safer alternatives, that could have
prevented the Plaintiff’ injuries and damages.
35. Defendant’s actions and omissions were the direct and proximate cause of the
Plaintiff’s injuries and damages.
WHEREFORE, Plaintiff demands judgment against Defendant for damages, together
with interest, costs of suit, and all such other relief as the Court deems proper.
COUNT II
NEGLIGENT DESIGN DEFECT
36. Plaintiff incorporates by reference each preceding and succeeding paragraph as
though set forth fully at length herein.
37. Defendant is the manufacturer, seller, distributor, marketer, and supplier of the
subject Ninja blenders, which were negligently designed.
38. Defendant failed to exercise reasonable care in designing, developing,
manufacturing, inspecting, testing, packaging, selling, distributing, labeling, marketing, and
promoting its Ninja blenders, which were defective and presented an unreasonable risk of harm to
consumers, such as the Plaintiff.
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39. As a result, the subject Ninja blenders, including Plaintiff’s Ninja blender, contain
defects in their design which render them unreasonably dangerous to consumers, such as the
Plaintiff, when used as intended or as reasonably foreseeable to Defendant, which causes an
unreasonable increased risk of injury.
40. Plaintiff in this case used her Ninja blender in a reasonably foreseeable manner and
did so as substantially intended by Defendant.
41. The subject Ninja blender was not materially altered or modified after being
manufactured by Defendant and before being used by Plaintiff.
42. As a direct and proximate result of Defendant’ negligent design of its Ninja
blenders, the Plaintiff in this case suffered injuries and damages described herein.
WHEREFORE, Plaintiff demands judgment against Defendant for damages, together
with interest, costs of suit, and all such other relief as the Court deems proper.
COUNT III
NEGLIGENT FAILURE TO WARN
43. Plaintiff incorporates by reference each preceding and succeeding paragraph as
though set forth fully herein.
44. At the time in which the Ninja blender was purchased, up through the time Plaintiff
was injured, Defendant knew or had reason to know that its Ninja blenders were dangerous and
created an unreasonable risk of harm to consumers.
45. Defendant had a duty to exercise reasonable care to warn consumers of the
dangerous conditions or the facts that made its Ninja blenders likely to be dangerous.
46. As a direct and proximate result of Defendant’s failure to warn of the dangers of its
Ninja blenders, the Plaintiff in this case suffered injuries and damages described herein.
WHEREFORE, Plaintiff demands judgment against Defendant for damages, together
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with interest, costs of suit, and all such other relief as the Court deems proper.
COUNT IV
NEGLIGENCE
47. Plaintiff incorporates by reference each preceding and succeeding paragraph as
though set forth fully at length herein.
48. Defendant has a duty of reasonable care to design, manufacture, market, and sell
non-defective Ninja blenders that are reasonably safe for their intended uses by consumers, such
as Plaintiff and her family.
49. Defendant failed to exercise ordinary care in the manufacture, sale, warnings,
quality assurance, quality control, distribution, advertising, promotion, sale and marketing of its
Ninja blenders in that Defendant knew or should have known that said Ninja blenders created a
high risk of unreasonable harm to the Plaintiff and consumers alike.
50. Defendant negligent in the design, manufacture, advertising, warning, marketing
and sale of its Ninja blenders in that, among other things, it:
a. Failed to use due care in designing and manufacturing the Ninja blenders to avoid
the aforementioned risks to individuals;
b. Placed an unsafe product into the stream of commerce;
c. Aggressively over-promoted and marketed its Ninja blenders through television,
social media, and other advertising outlets; and
d. Were otherwise careless or negligent.
51. Even though Defendant knew or should have known of the aforementioned defects,
Defendant continued to market (and continue to do so) its Ninja blenders to the general public.
WHEREFORE, Plaintiff demands judgment against Defendant for damages, together
with interest, costs of suit, and all such deems proper.
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DEMAND FOR JURY TRIAL
Plaintiff demands that all issues of fact of this case be tried to a properly impaneled jury to
the extent permitted under the law.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff demands judgment against the Defendant for damages,
including exemplary damages if applicable, to which they entitled by law, as well as all costs of
this action, interest and attorneys’ fees, to the full extent of the law, whether arising under the
common law and/or statutory law, including:
a. judgment for Plaintiff and against Defendant;
b. damages to compensate Plaintiff for her injuries, economic losses and pain and
suffering sustained as a result of the use of the Defendant’s Ninja blenders;
c. pre and post judgment interest at the lawful rate;
d. a trial by jury on all issues of the case;
e. an award of attorneys’ fees; and
f. for any other relief as this Court may deem equitable and just, or that may be
available under the law of another forum to the extent the law of another forum is
applied, including but not limited to all reliefs prayed for in this Complaint and in
the foregoing Prayer for Relief.
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Date: March 20, 2023 Respectfully submitted,
MILBERG COLEMAN BRYSON PHILLIPS
GROSSMAN, PLLC
/s/ Randi Kassan, Esq.
Randi Kassan, Esq.
100 Garden City Plaza
Suite 500
Garden City, NY 11530
516-741-5600 / 516-741-0128 (fax)
[email protected]
In association with:
JOHNSON BECKER, PLLC
Adam J. Kress, Esq. (#0397289)
Pro Hac Vice to be filed
444 Cedar Street, Suite 1800
Saint Paul, MN 55101
[phone] / [phone] (fax)
[email protected]
Attorneys for Plaintiff
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Professional Kitchen System
I BL685_Series_lB_170428_press.indd 1
ninjakitchen.com
1-877-646-5288
BL685
OWNER'S GUIDE
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IMPORTANT SAFETY INSTRUCTIONS
For Household Use Only
WHEN USING ELECTRICAL APPLIANCES ,
BASIC SAFETY PRECAUTIONS SHOULD
ALWAYS BE FOLLOWED, INCLUDING THE
FOLLOWING:
READ ALL INSTRUCTIONS BEFORE USING
YOUR NINJA® PROFESSIONAL KITCHEN
SYSTEM .
POLARIZED PLUG
A WARNING: To reduce the risk of
electric shock, this appliance has a
polarized plug (one blade is wider than the
other). This plug will fit into a polarized
outlet only one way . If the plug does not fit
fully into the outlet , reverse the plug. If it
still does not fit , contact a qualified
electrician to install the proper outlet . DO
NOT modify the plug in any way.
A WARNING: Extension cords are
not recommended for use with this
product.
A CAUTION: Blades are sharp,
handle with care. When handling the
blades, always hold by the shaft.
THIS BOOK COVERS MODEL NUMBER:
Bl685
TECHNICAL SPECIFICATIONS
Voltage: 120V ., 60Hz.
Power: 1200 Watts
Pitcher Capacity : 72 oz . (9 cups, 2.1 l)
MAX Liquid Capacity : 64 oz . (8 cups, 1.9 l)
Bowl Capacity: 64 oz. (8 cups, 1.8 l)
Nutri Ninja ® Capacity: 18 oz. (2¼ cups, 530 ml)
24 oz. (3 cups, 710 ml)
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BL685_Series_lB_170428_pres s. indd 2
A WARNING:
TO REDUCE THE RISK OF FIRE, ELECTRIC
SHOCK OR INJURY :
1 A
WARNING: Remove utensils prior to
processing. Failure to remove may cause
the jar to be damaged or to shatter which
may cause personal injury .
2 A
WARNING: The blade assemblies are
sharp, not locked in place and removable,
handle with care. When handling the
blade assemblies, always hold by the
shaft. Failure to do so will result in a risk
of laceration .
3 A
WARNING: Stacked Blade Assembly is
sharp and not locked in place. If using the
pour spout, ensure the lid is fully locked
onto the pitcher. If pouring with the lid
removed, carefully remove the Stacked
Blade Assembly first, holding it by the
shaft. Failure to do so will result in a risk
of laceration.
4 A WARNING: Chopping Blade Assembly
is sharp and not locked in place . Before
emptying contents carefully remove lid
and Chopping Blade Assembly, holding it
by the shaft. Failure to do so will result in
a risk of laceration .
5 A
CAUTION: Do not blend hot liquids,
doing so may cause excessive pressure
build-up , resulting in risk of the user
being burned.
6 A CAUTION: We do not recommend
grinding in any of our Nutri Ninja® Cups .
7 A
CAUTION: Remove the Pro Extractor
Blades Assembly from the Nutri Ninja cup
upon completion of blending. Do not store
ingredients before or after blending them
in the cup with the blade assembly
attached. Some foods may contain active
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ingredients or release gases that will
expand if left in a sealed container,
resulting in excessive pressure buildup
that can pose a risk of injury. For
ingredient storage in the cup, use only
Spout Lid to cover.
8 To protect against electrical shock, do not submerge
the appliance or allow the power cord to come into
contact with water or any other liquid.
9 DO NOT allow young children to operate the
appliance or use as a toy. Close supervision
is necessary when any appliance is used near
children.
1O Never leave an appliance unattended when in use.
11 Turn the appliance Off and remove the power cord
from the electrical outlet when not in use, before
assembling or disassembling parts and before
cleaning. To unplug, grasp the plug and pull from
the electrical outlet. Never pull from the power cord.
12 DO NOT abuse the power cord. Never carry the
appliance by the power cord or yank it to disconnect
from electrical outlet; instead grasp the plug and
pull to disconnect.
13 This appliance has important information on the
plug prong. The power cord is not suitable for
replacement. If damaged, contact SharkNinja for
service.
14 DO NOT operate any appliance with a damaged
cord or plug, or after the appliance malfunctions,
has been dropped or damaged in any manner.
This appliance has no serviceable parts. Return
the appliance to SharkNinja Operating LLC for
examination, repair or adjustment.
15 DO NOT let the power cord hang over the edge of
table or counter or touch hot surfaces such as the
stove.
16 Always use appliance on a dry, level surface.
17 Keep hands, hair, clothing, as well as utensils out
of container while processing to reduce the risk of
severe injury to persons or damage to the appliance.
A scraper may be used but only when the appliance
is not running.
18 Avoid contact with moving parts.
BL685_Series_lB_170428_press. indd 3
19 DO NOT attempt to sharpen blades.
20 DO NOT use the appliance if blade assembly is bent
or damaged.
21 To reduce risk of injury, never place the blade
assembly on base without pitcher or bowl properly
attached.
22 DO NOT operate this appliance on or near any hot
surfaces (such as gas or electric burner or in a
heated oven).
23 The use of attachments or accessories including
canning jars, not recommended by the manufacturer
may result in fire, electric shock or personal injury.
24 DO NOT remove the container from the motor base
while the appliance is in operation.
25 To reduce the risk of injury, NEVER operate the
appliance without the lid in place.
26 DO NOT try to defeat the interlock mechanism;
make sure that the blade assembly is properly
installed before operating the appliance.
27 DO NOT expose containers to extreme temperature
changes.
28 DO NOT overfill. Never fill past the "Max" line.
29 DO NOT operate the appliance empty.
30 To reduce the risk of burns, always allow the
appliance to cool before taking off parts and before
cleaning.
31 In the event that the unit overheats, the control
panel lights will flash and the unit will shut down.
Unplug the unit and wait 15 minutes to reset.
32 THIS PRODUCT IS INTENDED FOR HOUSEHOLD
USE ONLY. Do not use this appliance for anything
other than its intended use. Do not use outdoors.
33 The maximum rating is based on the Stacked Blade
Assembly ~itcher) that drives the greatest power
and other recommended attachments may draw
significantly less power or current.
SAVE THESE
INSTRUCTIONS
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What's Inside
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ID)
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~ t
v~
Small 18oz .
Regular 24 oz .
Pro Extractor Spout Lid
Stacked Blade
Pitcher Lid
Nutri Ninja ® Cup
Nutri Ninja Cup
Blades ® Assembly Assembly
(Pitcher)
i
~ ~
W)
Pitcher
Chopping Blade
Dough Blade
Food Processor Food Processor Motor Base
Assembly Assembly
Bowl Lid Bowl
(Processor Bowl)
(Processor Bowl)
NOTE: Blades are not i nterchangeable .
FEATURES:
• 1200 Watts
• Extra Large , 72 oz . Pitcher (64 oz . Max . Liquid Capacity) - BPA Free
• 64 oz . Bowl with Drizzle Hole - BPA Free
• 18 oz. & 24 oz . Nutri Ninja Cups - BPA Free
• 5 Speeds , Pulse and Nutri Ninja Functionality
• Sturdy , Non-Slip Base
• Total Crushing ® Technology
• Lock-In Lid, Featuring Pour Spout
• Easy to Clean Electronic Control Panel
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Before First Use
PLEASE KEEP THESE IMPORTANT
SAFEGUARDS IN MIND WHEN USING THE
APPLIANCE:
IMPORTANT: Make sure that the motor base
is plugged in for use.
IMPORTANT: Never add ingredients into the
container before placing the Blade Assembly
in first.
IMPORTANT: Blade Assemblies are not
interchangeable.
IMPORTANT: DO NOT attempt to operate the
appliance without the lid on.
IMPORTANT: Never run the appliance empty.
IMPORTANT: Appliance accessories are not
intended to be used in the microwave as it
may result in damage to the accessories.
I BL685_Series_lB_170428_press.indd s
A
WARNING: Stacked
Blade Assembly is
sharp and not locked in
place . If using the pour
spout, ensure the lid
is fully locked onto the
pitcher. Failure to do so
will result in a risk of
laceration.
A WARNING : Stacked
Blade Assembly is sharp
and not locked in place .
If pouring with the lid
removed, carefully
remove the Stacked
Blade Assembly first,
holding it by the shaft. Failure to do so
will result in a risk of laceration .
A
WARNING : Chopping 4
Blade Assembly is sharp and , '
not locked in place . Before
11
~ 3' !
emptying contents carefully 11 ~
remove lid and Chopping
Blade Assembly, holding it by
the shaft. Failure to do so will result in a
risk of laceration.
A CAUTION: Do not immerse the motor base into
water or any other liquid.
1 Remove all packaging material and labels from the
appliance . Separate/remove all parts from each other.
2 Wash the lids, pitcher, bowl, Nutri Ninja ® cups and
Blade Assemblies in warm, soapy water . When washing
the blade assemblies, use a dish-washing utensil with a
handle to avoid direct hand contact with blades .
A WARNING: Handle the Blade Assemblies with care
when washing as they are very sharp.
3 Handle blade assemblies with care to avoid contact with
sharp edges. Rinse and air dry thoroughly .
4 The pitcher, bowl, Nutri Ninja cups, lids and Blade
Assemblies are all dishwasher safe. It is recommended
that the lids and blade assemblies be placed on the top
rack. Ensure that the blade assemblies are removed
from the containers before placing in the dishwasher.
5 Wipe the motor base clean with a damp cloth.
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Assembly and Use of the Pitcher
A WARNING : Handle the Stacked Blade Assembly with care, as the blades are sharp.
A WARNING : Remove utensils pr i or to processing. Failure to remove may cause the pitcher to be damaged or
to shatter, which may cause personal injury.
A WARNING : Never leave the appliance unattended while in use .
A CAUTION : Do not blend hot liquids, do i ng so may cause excess i ve pressure buildup, resulting in risk of the
user being burned.
IMPORTANT: Make sure that the motor base is plugged in for use .
ASSEMBLY
Fig. 1 Fig.2
Review warning and caution statements above before
proceeding to number 2.
2 Place the motor base on a clean, dry , level surface such
as a counter or table top.
3 Align and lower the pitcher onto the motor base .
(Fig. 1) Handle should be aligned slightly to the right of
the "LOCK" symbol on the motor base .
4
Rotate the pitcher clockwise until it locks in place . You
will hear a click when the lock is engaged . (Fig. 2)
5 The pitcher can be placed on the motor base two ways ;
the handle can be on the front right corner or the front
left corner . (F ig. 3a , Fig . 3b)
6 Holding the Stacked Blade Assembly by the top of the
shaft, place it onto the drive gear inside the pitcher .
Ensure that the Stacked Blade Assembly is seated
properly and is standing upright. (F ig. 4)
NOTE : The Stacked Blade Assembly will fit loosely on
the drive gear .
7
Add the ingredients to the pitcher, making sure that
they do not exceed the highest measured marking line
on the side of the pitcher .
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Fig. 4
I= ~I
i
Fig. 5
NOTE: If you need to add additional ingredients while
the appliance is processing , open the pour spout cap
and pour the ingredients in through the opening.
NOTE: When blending any kind of liquids, such as
mi x tures of any drinks or smoothies , do not ex ceed the
" Max liquid " mark (64 ounces) on the pitcher.
8 Plug the power cord into the electrical outlet and press
the power button (6).
IMPORTANT: As a safety feature , the power
button (6) will flash and the motor will not work
if the pitcher and lid are not i nstalled correctly .
When the pi tcher and lid are i nstalled properly ,
the power button (6) will be solid, indicating that
the appliance is ready for use.
9 Holding the lid by the handle in the upright position ,
place it on top of the pitcher aligning the arrow
('Y) located on the lid with the arrow (&) located on the
pitcher 's handle . (Fig. 5) Press the handle down until
you hear a click. The triangles on the lid and the pitcher
handle MUST be aligned in order for the blender to
turn on .
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USE
Fig. 6 Fig. 7
10 Select the speed that best suits your needs. (Fig. 6)
NOTE: Pulse ingredients for even chopping by pressing
down in short intervals .
11 When you have reached your desired consistency, stop
the appliance by pressing the power button (6) and
wait for the stacked blade assembly to stop turning .
(Fig . 7)
12 To remove the lid , press the release button on the lid,
pull the lid handle up to a go
0
angle and lift the lid off.
Turn the pitcher counter clockwise and then lift off the
base. (Fig. 7, Fig . 8)
.A CAUTION: Never insert your hands in the pitcher
as the blades are sharp . Always use a spatula to
dislodge food that has stuck to the sides of the
pitcher.
BL685_Series_lB_170428_press.indd 7
REMOVAL
Fig. 8 Fig. 9
13 Open the pour spout cap and use the spout to empty
liquid contents.
14 For thicker consistencies , remove the lid and stacked
blade assembly carefully (by its shaft) , then empty
contents from the container . To remove the lid, press
the release button on the lid and pull the lid handle
up to a go
0
angle and lift the lid off the pitcher. Then ,
carefully remove the Stacked Blade Assembly by the
top of the shaft. Place Stacked Blade Assembly away
from the work area to avoid accidental contact. Finally ,
empty contents from the pitcher .
15 Make sure that the unit is unplugged when not in use .
16 To release the motor base from the counter or table top ,
place your hands underneath both sides of the motor base
and gently pull the unit up and towards you . (Fig. 9)
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Case 2:23-cv-02144 Document 1-1 Filed 03/20/23 Page 7 of 16 PageID #: 18

Assembly and Use of the Nutri Ninja® Cup
A WARNING: Handle the Pro Extractor Blades<» Assembly with care , as the blades are sharp .
A
WARNING : Remove utensils prior to processing. Failure to remove may cause the Nutri Ninja cup to be damaged or to
shatter, which may cause personal injury .
A
WARNING : Never leave the appliance unattended while in use .
A
CAUTION : Do not blend hot liquids, doing so may cause excessive pressure buildup, resulting in risk of the user being
burned .
A
CAUTION : Remove the Pro Extractor Blades Assembly from the Nutri Ninja cup upon completion of blending . Do not
store ingredients before or after blending them in the cup with the blade assembly attached . Some foods may contain
active ingredients or release gases that will expand if left in a sealed container, resulting in excessive pressure
buildup that can pose a risk of injury . For ingredient storage in the cup, use only Spout Lid to cover.
IMPORTANT : Make sure that the motor base is plugged in for use .
ASSEMBLY PULSE
Fig . 1 Fig . 3
1
Review warning and caution statements above before
proceeding to number 2.
2 Place the motor base on a clean, dry, level surface such
as a counter or table top.
3 Add ingredients to the Nutri Ninja cup.
NOTE: Do not overfill! To avoid spilling, do not add
ingredients past the "Max" fill line.
4 Place the Pro Extractor Blades ® Assembly onto the cup
and tightly screw it on clockwise until you have a good
seal. (Fig. 1)
5 Turn the Nutri Ninja cup upside down and place it onto
the motor base, aligning the tabs on the cup with the
motor base. Rotate the Nutri Ninja cup clockwise until it
is locked in place , you will hear a click when the lock is
engaged. (Fig. 2) Turn the power button on, the Nutri
Ninja button and Pulse will illuminate .
6
Press down on the Pulse button in short intervals to
break down tough ingredients . Press the Nutri Ninja
button to activate the 30 second continuous run .
(Fig. 3) The unit will stop after 30 seconds.
7 Once you have reached your desired consistency, turn
the power button off and wait for the Pro Extractor
Blades Assembly to stop turning. Turn the Nutri Ninja
cup counterclockwise and pull straight up to remove.
(Fig. 4, Fig . 5)
7 I B? 1-877-646-5288
BL685_Series_lB_170428_press.indd 8
REMOVAL
8 T
I
Fig . 4 Fig . 5
Fig. 6
8
Turn the cup upright and remove the Pro Extractor
Blades Assembly by twisting the blade assembly
counterclockwise.
9 Turn the cup upright and remove the Pro Ex tractor
Blades Assembly by twisting counter clockwise.
(Fig. 6)
10 Do not store blended contents with the Pro Extractor
Blade Assembly attached .
11 Place the spout lid onto the Nutri Ninja cup, twist to
seal and enjoy!
12 For storage, only use the spout lid to cover.
13 Be sure to store the Pro Extractor Blades Assembly
attached to an empty cup when not in use.
14 Make sure that the motor base is unplugged when
not in use.
15 To release the motor base from the
counter or table top, place your hands
underneath both sides of the motor
base and gently pull the unit up and .
towards you. f
NOTE: To order additional Nutri Ninja
Cups, please visit our website : ninjakitchen . com or
feel free to contact customer service: 1-877-646-5288.
2017-05-01 9:08 AM I
Case 2:23-cv-02144 Document 1-1 Filed 03/20/23 Page 8 of 16 PageID #: 19

Assembly and Use of the Processor Bowl
A
WARNING : Chopping Blade Assembly is sharp and not locked in place. Before emptying contents carefully
remove lid and Chopping Blade Assembly , hold i ng it by the shaft. Failure to do will result in risk of
laceration .
A
WARNING: Remove utensils prior to process i ng. Failure to remove may cause the bowl to be damaged or to
shatter, which may cause personal injury .
A
WARNING: Never leave the appliance unattended while in use .
A
CAUTION : Do not blend hot li qu i ds, doing so may cause excessive pressure buildup, resulting in risk of the
user being burned .
A
CAUTION : Remove the lid from the bowl upon completion of process i ng. Some ingred i ents have the potential
to expand after blend i ng resulting in excessive pressure buildup that can pose a risk of i njury .
IMPORTANT : Make sure that the motor base is plugged in for use.
ASSEMBLY
Fig . 3a
Fig. 1 Fig . 2 Fig . 3b
1 Review warning and caution s tatements above before
proceeding to number 2.
2
Place the motor base on a clean , dry , level surface such
as a counter or table top .
3
Align and lower the Bowl onto the motor base .
(Fig . 1) Handle should be aligned slightly to the right of
the " LOCK " symbol on the motor base .
4
Rotate the bowl clockwise until you hear a click , you will
hear a click when the lock is engaged . (Fig. 2)
5 The bowl can be pla c ed on the motor base two ways ;
the handle can be on the front right corner or the front
left corner . (F i g. 3a, Fig . 3b)
6 Holding the desired blade assembly by the top of the
shaft , place it onto the drive gear inside the bowl.
Ensure that the blade assembly is seated properly and
is standing upright. (Fig. 4)
NOTE: The blade assembly will fit loosely on the drive
gear.
7 Add the ingredients to the bowl , making sure that they
do not ex ceed the highest measured marking line on
the side of the bowl.
BL685_Series_lB_170428_press.indd 9
OR
Fig . 4 Fig . 5
NOTE : The food processor bowl is not intended
for blending dr i nks . Do not overfill.
8 Holding the lid by the handle in the upright position,
place it on top of the bowl aligning the arrow (• )
located on the lid with the arrow (&) located on the
bowl's handle. (Fig. 5) Press the handle down until you
hear a click. I
NOTE : To add liquids during blending , open
the drizzle hole on the top of the lid and
pour the liquid slowly into the mi x ture .
9
Plug the power cord into the electrical outlet and press
the power button (C9) .
IMPORTAN T: As a safety feature, the power
button (c!.l) will flash and the motor will not work
if the bowl and lid are not installed correctly .
When the bowl and lid are i nstalled properly, the
power button (C9) will be solid , i ndicating that the
appliance is ready for use .
NOTE : Do not ex ceed the highest measured marking line
on the side of the bowl. For meats do not exceed 34 oz
bowl mark.
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