DCT
1:25-cv-00795
Streamlight Inc v. Harbor Freight Tools USA Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Streamlight, Inc. (Delaware)
- Defendant: Harbor Freight Tools USA, Inc. (Delaware)
- Plaintiff’s Counsel: Connolly Gallagher, LLP
- Case Identification: 1:25-cv-00795, D. Del., 08/12/2025
- Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant is incorporated in Delaware, maintains a regular and established place of business in the state, and has committed the alleged acts of infringement in the district.
- Core Dispute: Plaintiff alleges that Defendant’s tactical gun-mounted light infringes a patent related to a removable mounting arrangement for firearms, and also infringes Plaintiff's registered trademark and unregistered trade dress rights.
- Technical Context: The technology concerns mounting systems for attaching accessories, such as lights, to standardized equipment rails on firearms, a key feature for military, law enforcement, and civilian users.
- Key Procedural History: The filing is a First Amended Complaint. The complaint does not mention any prior litigation between the parties or administrative proceedings, such as Inter Partes Reviews, concerning the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2004-11-15 | U.S. Patent No. 7,188,978 Priority Date |
| 2007-03-13 | U.S. Patent No. 7,188,978 Issued |
| 2025-08-12 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,188,978 - "Light mountable on a mounting rail"
The Invention Explained
- Problem Addressed: The patent describes conventional accessory mounts for firearms as often providing a loose fit, leading to undesirable "play" that could affect aiming. It also notes that different gun manufacturers used different rail configurations, requiring users to own multiple, non-interchangeable accessories, and that attaching or removing these accessories could require unsafe hand placement near the firearm's muzzle (’978 Patent, col. 1:32-61).
- The Patented Solution: The invention is a mounting arrangement that clamps onto a rail from the side using a fixed member and an opposing movable member, which can be tightened with a screw. This design allows for a secure, repeatable attachment. The system's adaptability comes from a "keying member" that is "removably disposed" in a recess on the light's body, allowing a user to swap out different keys to fit the specific groove dimensions of different firearm rails (’978 Patent, Abstract; col. 3:25-40).
- Technical Importance: The claimed solution provides a single, adaptable mounting system that can be securely and safely attached to various firearm rails, potentially without specialized tools (Compl. ¶22; ’978 Patent, col. 5:6-14).
Key Claims at a Glance
- The complaint asserts independent claim 43 (’978 Patent, Compl. ¶70).
- Claim 43 requires:
- A mounting arrangement for an object on a rail with a keying feature.
- First and second clamp members on the object that are movable to clamp the rail.
- A recess located on the object between the clamp members.
- A keying member that is "removably disposed" in the recess.
- The keying member has a feature that engages the keying feature of the mounting rail.
- The complaint does not explicitly reserve the right to assert dependent claims but makes allegations concerning "at least claim 43" (Compl. ¶¶70, 108).
III. The Accused Instrumentality
Product Identification
- The accused product is the "BRAUN Tactical Rail Mount LED Light" (the "Infringing Product") (Compl. ¶52).
Functionality and Market Context
- The complaint describes the accused product as a gun-mounted light that directly competes with Plaintiff's products (Compl. ¶55). Its functionality includes a mounting system for attaching to firearms equipped with Picatinny-style rails (Compl. p. 24). The complaint alleges the product is sold with five distinct, removable keying members, each labeled for a specific type of firearm, to adapt the light to different mounting rails (Compl. p. 25). The complaint also includes a side-by-side photograph comparing Plaintiff's Streamlight TLR-1 HL product with the Defendant's product to illustrate their similar appearance (Compl. ¶9, p. 3).
IV. Analysis of Infringement Allegations
’978 Patent Infringement Allegations
| Claim Element (from Independent Claim 43) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| first and second clamp members on said object movable closer together for clamping a mounting rail... | The accused product has two clamp members, identified by white arrows in a provided photograph, that clamp onto a firearm's mounting rail. | ¶70, p. 24 | col. 3:25-40 |
| said object having a recess located on said object between said first and second clamp members; | The accused product's body includes a recess located between its clamp members, as identified by a white arrow in a provided photograph. | ¶70, p. 24 | col. 6:39-41 |
| a keying member removably disposed in the recess of said object, said keying member having a keying feature that engages the keying feature of the mounting rail... | The accused product is sold with five interchangeable keying members, shown in a photograph, which are placed in the recess to engage the keying feature (slot) of a firearm's rail. | ¶70, p. 25 | col. 6:39-44 |
Identified Points of Contention
- Scope Questions: The complaint's allegations and visual evidence appear to map directly onto the elements of claim 43. A potential question for the court may be whether the accused product's mechanism for securing the keying member falls within the scope of "removably disposed" as understood in the context of the patent.
- Technical Questions: The complaint provides a photograph of five distinct keying members allegedly included with the accused product (Compl. p. 25). A central factual question will be whether these components are, in fact, removable and interchangeable as alleged, and whether they function to engage the rail's keying feature as required by the claim.
V. Key Claim Terms for Construction
- The Term: "removably disposed"
- Context and Importance: The infringement allegation hinges on the accused product's keying member being removable, allowing it to be swapped to fit different rails. If the keying member is permanently affixed or integral to the product's body, this limitation would not be met. Practitioners may focus on this term because the concept of an interchangeable key is a core aspect of the claimed invention's adaptability.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the replacement process in simple terms: "Key member 62 is replaceable by removing key screw 68 and then removing key member 62 from key recess 42, and a replacement key member 62 is installed..." (’978 Patent, col. 6:62-66). This language may support a construction that simply requires the part to be capable of being removed and replaced, without limitation as to the specific method.
- Evidence for a Narrower Interpretation: A party seeking a narrower construction might argue that "removably" implies removal without tools. However, the specification's explicit reference to removing a "key screw 68" to replace the key member appears to contemplate the use of a tool, which may counter arguments for a more restrictive, tool-less definition (’978 Patent, col. 6:62).
VI. Other Allegations
- Indirect Infringement: The complaint's patent count focuses on direct infringement under 35 U.S.C. § 271(a) (Compl. ¶108).
- Willful Infringement: Willfulness is explicitly alleged (Compl. ¶111). The complaint asserts that Defendant had knowledge of the ’978 Patent through multiple channels: Plaintiff's product labeling, a patent-marking notice on Plaintiff's website, and "direct communication between Streamlight and HFT" (Compl. ¶¶71, 109).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of factual correspondence: Does the accused BRAUN product contain the specific combination of elements recited in claim 43—namely, clamping members, a recess between them, and a keying member that is, in fact, "removably disposed" within that recess for engaging a rail? The complaint's photographic evidence presents a direct visual alignment with this claim structure.
- A second key question will relate to willfulness and intent: The complaint alleges not only constructive notice via patent marking but also actual notice through "direct communication." The development of the factual record regarding what Defendant knew about the ’978 Patent, and when, will be critical to the willfulness claim and any potential for enhanced damages.