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.
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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.
3
Id.
Case 2:23-cv-02144 Document 1 Filed 03/20/23 Page 5 of 11 PageID #: 5
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