DCT

1:25-cv-23581

Sea Swivel Inc v. Rhodan Marine Systems Of Florida LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-23581, S.D. Fla., 08/08/2025
  • Venue Allegations: Venue is asserted based on the Florida residency of Defendants Rhodan and ShuttleSlide, and on Defendant T6’s alleged purposeful direction of infringing activities into Florida. Plaintiff alleges a substantial part of the events giving rise to the claims occurred in the district.
  • Core Dispute: Plaintiff alleges that Defendants’ swiveling trolling motor mounts infringe a patent related to a mounting system for attaching and maneuvering accessories, like trolling motors, on a boat.
  • Technical Context: The technology concerns mounting hardware designed to solve the problem of safely and easily deploying and stowing long-shaft trolling motors, particularly from the bow of a boat.
  • Key Procedural History: The complaint alleges that Plaintiff provided written notice of the patent-in-suit to Defendants Rhodan and ShuttleSlide on June 25, 2025, and to Defendant T6 on June 27, 2025, prior to filing the lawsuit. These notices may form the basis for the willfulness allegations.

Case Timeline

Date Event
2023-09-26 Priority Date for U.S. Patent No. 12,258,111
2025-03-25 U.S. Patent No. 12,258,111 Issued
2025-06-25 Plaintiff sends notice letter to Rhodan and ShuttleSlide
2025-06-27 Plaintiff sends notice letter to T6
2025-08-08 Complaint Filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 12,258,111 - "Swivel mounts for attaching and maneuvering accessories over the gunnel of a boat or any other mounting surface," issued March 25, 2025 (’111 Patent)

The Invention Explained

  • Problem Addressed: The patent describes challenges with conventional trolling motor mounts, particularly for large boats. Deploying and stowing motors with long shafts can be precarious, requiring boaters to climb onto the bow, which risks falling overboard or damaging the boat or motor (’111 Patent, col. 1:35-51). Mounting options are often limited, and the forces from large waves can put significant stress on the mounting hardware (’111 Patent, col. 1:57-66).
  • The Patented Solution: The invention is a swivel mount that allows an accessory, such as a trolling motor, to be attached to a mounting plate that can pivot or swivel relative to a support plate fixed to the boat’s gunnel (’111 Patent, Abstract). A key feature is that the pivot point is offset from the centerline of the mounting plate, allowing the motor to be cantilevered over the side of the boat for deployment and then swiveled back and stowed in alignment with the gunnel for safety and convenience (’111 Patent, col. 5:4-18; Fig. 1). This photograph from the complaint shows the Plaintiff's product, which it alleges embodies the patented invention, mounted on the gunnel of a boat (Compl. p. 5).
  • Technical Importance: The design provides a method for managing long-shaft trolling motors that purports to be safer and more adaptable than prior fixed mounts, particularly for offshore boats where wave action and high gunnels are common (’111 Patent, col. 6:21-29).

Key Claims at a Glance

  • The complaint alleges infringement of "one or more claims" but does not specify which claims are asserted (Compl. ¶28). Independent claim 1 is representative.
  • Independent Claim 1:
    • an elongated mounting plate comprising first and second opposing faces spaced apart by one or more peripheral sidewalls;
    • a support plate comprising first and second opposing faces spaced apart by one or more peripheral sidewalls, wherein the support plate has a length less than or equal to half a length of the elongated mounting plate; and
    • a swivel element, wherein the swivel mount is configured for the elongated mounting plate, the support plate, and swivel element to be coupled together such that:
      • the first faces of the support plate and the elongated mounting plate are parallel;
      • the swivel element, the support plate, and the elongated mounting plate at least partially overlap each other; and
      • the swivel element is arranged such that the elongated mounting plate is able to swivel about an axis that is perpendicular to and passing through the first face of the elongated mounting plate at a point spaced from a widthwise center line of the elongated mounting plate.
  • The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint identifies three groups of accused products:

  1. Rhodan Marine Systems of Florida, LLC’s “SRQ Brackets” (Compl. ¶23).
  2. T/6 Marine’s “BOSS 360” and “Mini BOSS 360” trolling motor mounts (Compl. ¶24).
  3. ShuttleSlide LLC’s “SS-7.5R Rotating Mount” and “SS-9.5R Rotating Mount” (Compl. ¶25).

Functionality and Market Context

  • The complaint alleges that all accused products are trolling motor mounts, brackets, or systems that "incorporate rotating or pivoting mechanisms that facilitate secure attachment and directional adjustment of bow-mounted trolling motors" (Compl. ¶23-25).
  • The functionality is described as "materially similar" and "substantially similar in purpose, configuration, and operation" to Sea Swivel’s patented design (Compl. ¶23-25, ¶28). The complaint further alleges that Defendants have represented to customers that the accused products provide "similar functionality, design benefits, or compatibility" with Plaintiff's system (Compl. ¶29).

IV. Analysis of Infringement Allegations

The complaint references preliminary claim charts (Exhibits B, E, and K) that were not included with the filed document (Compl. ¶32, ¶39, ¶46). In the absence of these charts, the infringement theory must be drawn from the complaint's narrative allegations.

The complaint alleges that the accused products infringe the ’111 Patent because they share "structural and functional characteristics" with the patented invention, specifically citing "mechanisms that allow for rotational movement or directional adjustment of trolling motors" (Compl. ¶28). The core of the infringement allegation appears to be that the accused products are "colorable imitations of the invention claimed in the ’111 Patent" (Compl. ¶31, ¶38, ¶45).

  • Identified Points of Contention:
    • Pleading Standard: A significant issue is the complaint's repeated use of language associated with design patent infringement, stating that the accused products are "substantially the same as that of the '111 Patent in the eye of an ordinary observer" (Compl. ¶32, ¶39, ¶46). This is the legal standard for design patent infringement, not for utility patents like the ’111 Patent. This raises the question of whether the complaint adequately pleads utility patent infringement, which requires showing the accused product meets every limitation of an asserted claim.
    • Technical Questions: The complaint lacks specific factual allegations mapping elements of the accused products to the limitations of any specific claim. For an infringement case to proceed, Plaintiff will need to provide evidence showing, for example, that the accused products possess a "support plate" with a "length less than or equal to half a length of the elongated mounting plate" and a "swivel element" that pivots at a "point spaced from a widthwise center line," as required by Claim 1. The general allegation of a "rotating or pivoting mechanism" may not be sufficient to establish that these specific claimed features are present.

V. Key Claim Terms for Construction

  • The Term: "swivel element"

  • Context and Importance: This term is central to the invention's functionality. Its construction will determine what types of mechanisms can satisfy the limitation. The infringement analysis will depend on whether the accused products' rotating mechanisms fall within the construed scope of this term.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The term itself is functional. The claims do not recite a specific structure for the "swivel element", suggesting it could encompass any component or assembly that enables the claimed swiveling motion.
    • Evidence for a Narrower Interpretation: The specification describes the "swivel element" as a "combination of bolt 15, bearing 7 and nut 8" (’111 Patent, col. 10:39-41). A defendant may argue that this specific embodiment limits the term to a configuration involving a central bolt and bearing, potentially excluding other types of rotating assemblies like the "annular bearing" disclosed in an alternative embodiment (’111 Patent, col. 14:17-19).

  • The Term: "a point spaced from a widthwise center line"

  • Context and Importance: This limitation defines the offset pivot, which is a critical feature for cantilevering the motor over the boat's side. Practitioners may focus on this term because the degree of "space" required is not explicitly quantified in the claim, creating ambiguity.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The claim language only requires that the pivot point be "spaced from" the centerline, without specifying a distance. This could support an interpretation where any non-centered pivot point meets the limitation.
    • Evidence for a Narrower Interpretation: The specification explains the purpose of the offset is to enable a trolling motor to be deployed "far enough away from the side of the boat" (’111 Patent, col. 5:22-24). A defendant might argue this functional language requires the "space" to be substantial enough to achieve this purpose, potentially excluding products with only a minimal offset.

VI. Other Allegations

  • Indirect Infringement: The complaint makes a passing reference to liability under 35 U.S.C. §§ 271(a)-(c) (Compl. ¶6), but it does not plead specific facts to support claims for induced or contributory infringement, such as knowledge of infringement combined with active encouragement of infringing acts.
  • Willful Infringement: The complaint alleges that infringement has been knowing and willful based on pre-suit written notice letters sent to each Defendant (Compl. ¶34, ¶41, ¶48). The complaint states that Rhodan and ShuttleSlide received notice on June 25, 2025, and T6 received notice on June 27, 2025, and that infringing activity continued after these dates (Compl. ¶34, ¶41, ¶48).

VII. Analyst’s Conclusion: Key Questions for the Case

  • A primary threshold issue will be one of pleading adequacy: does the complaint’s reliance on the "ordinary observer" test—a standard for design patents—and its lack of specific factual allegations mapping accused product features to claim limitations meet the requirements for pleading infringement of the asserted utility patent?
  • A central claim construction question will be the definitional scope of the "swivel element". Can the term be broadly construed to cover any rotating mechanism, or is it limited by the specification’s embodiments to a particular type of bolt-and-bearing assembly?
  • A key evidentiary question will be one of technical proof: assuming the complaint survives, Plaintiff must produce evidence demonstrating that the accused products meet every limitation of an asserted claim, particularly the geometric and relational requirements, such as the support plate being "less than or equal to half a length" of the mounting plate and the pivot point being "spaced from a widthwise center line."