DCT

1:25-cv-23910

RT RECOVER Innovations Ltd v. Meta Platforms Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-23910, S.D. Fla., 08/29/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Southern District of Florida because Defendants reside in the district, avail themselves of Florida laws, and purposefully direct business activities toward consumers within the state and district.
  • Core Dispute: Plaintiff alleges that a network of individuals and corporate entities (the "Navia Defendants") manufacture and sell firearm holster assemblies that infringe a utility patent, and that Meta Platforms actively participates in and profits from this infringement by providing a targeted advertising platform.
  • Technical Context: The technology relates to firearm accessories, specifically holster assemblies that allow a handgun to be securely carried and quickly accessed.
  • Key Procedural History: The complaint alleges that Plaintiff sent takedown notices to Meta regarding trademark and copyright infringement by the Navia Defendants prior to filing suit. It also alleges that while Meta has a reporting process for trademark and copyright, it lacks a similar mechanism for patent infringement, which Plaintiff characterizes as a form of willful blindness.

Case Timeline

Date Event
2019-12-17 U.S. Patent No. 12,066,271 Priority Date
2021-01-01 Approximate start of alleged infringing activity by Navia Defendants
2024-08-20 U.S. Patent No. 12,066,271 Issues
2025-08-05 Plaintiff sends most recent take-down notice to Meta
2025-08-29 Complaint Filed

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

U.S. Patent No. 12,066,271 - "Holster Assembly"

  • Patent Identification: U.S. Patent No. 12,066,271, "Holster Assembly," issued August 20, 2024 (the ’271 Patent).

The Invention Explained

  • Problem Addressed: The patent addresses the general need for holsters for handguns. While not explicitly stated as a problem, the background implies a need for reliable and adaptable holster systems for firearms. (’271 Patent, col. 1:13-15).
  • The Patented Solution: The invention is a holster system comprising two main parts: an "adaptor flange" that secures to the firearm (specifically, underneath the barrel and forward of the trigger guard) and a separate "holster clip" that attaches to a user's clothing or belt via a "garment mounting provision" like a paddle. (’271 Patent, col. 4:4-15). The holster clip has "resilient arms" with inner faces that are designed to "click over a border" of an opening in the adaptor flange when the firearm is inserted, thereby securely holding the firearm in place. (’271 Patent, col. 4:10-15; Fig. 4C).
  • Technical Importance: This two-part design separates the firearm-specific interface (the flange) from the user-worn component (the clip), potentially allowing for a modular system.

Key Claims at a Glance

  • The complaint asserts the ’271 Patent generally, with Count I for Direct Infringement appearing to implicate all claims. (Compl. ¶¶102-108). Independent claim 1 is representative.
  • Independent Claim 1 Elements:
    • An adaptor flange securable to a firearm and formed with an opening.
    • A garment mounting provision.
    • A holster clip comprising resilient arms that include inner faces.
    • One of the resilient arms comprises a mounting feature that couples to the garment mounting provision.
    • Wherein when the firearm is slid and fully holstered into the holster clip, the inner faces of the resilient arms click over a border of the opening and the firearm is securely held.
    • Wherein the resilient arms extend over a trigger guard of the firearm when secured.
  • The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

  • The accused products are "holster assembly" products sold by the "Navia Defendants" through various websites such as armamentpro.com and usslegendary.com. (Compl. ¶¶36-37). Specific product names like the "TRX Holster" are featured in advertisements. (Compl. ¶51).

Functionality and Market Context

  • The complaint alleges the accused products are "knock-offs" designed to "mimic" and "replicate the patented utility" of Plaintiff's G7® holster assembly. (Compl. ¶36, ¶37, ¶103). Advertisements for the accused products, delivered via Meta's platforms, describe them as ambidextrous holsters compatible with various firearm models and having "adjustable retention." (Compl. p. 13). A screenshot of an advertisement run on Meta's platform shows a holster product with a call to action to "Shop Now." (Compl. p. 14). The complaint alleges these products are sold in direct competition with Plaintiff's genuine goods, causing significant lost sales and reputational harm. (Compl. ¶78, ¶99).

IV. Analysis of Infringement Allegations

The complaint does not contain a claim chart. The following table summarizes the infringement theory based on the complaint's narrative allegations.

’271 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A holster assembly comprising: an adaptor flange securable to a firearm and formed with an opening; The accused holsters are alleged to be direct copies that "replicate the patented utility," which would necessarily include a flange-like component that attaches to the firearm. ¶37, ¶104 col. 4:56-59
a garment mounting provision; and The accused holsters are advertised and sold for carrying on a person's body, implying the presence of a feature to attach to a belt or waistband. ¶37, ¶51 col. 4:62-65
a holster clip comprising resilient arms that include inner faces... The complaint alleges the accused products are imitations of Plaintiff's G7® holster, which embodies the patented technology, suggesting the presence of a clip with resilient arms. ¶37, ¶103 col. 4:10-12
wherein when the firearm is slid and fully holstered into said holster clip, said inner faces of said resilient arms click over a border of said opening and the firearm is securely held in the holster assembly... The complaint's allegation that the accused products "replicate the patented utility" implies they perform this specific retention function. Advertisements mention "Adjustable Retention." ¶37, ¶51, ¶104 col. 4:11-15
  • Identified Points of Contention:
    • Technical Questions: The complaint lacks specific factual allegations detailing how the accused "TRX Holster" meets each claim limitation. A central question will be whether discovery shows the accused products actually contain an "adaptor flange" with an "opening" and a separate "holster clip" with "resilient arms" that "click over a border" of that opening, as opposed to a different retention mechanism.
    • Scope Questions: The infringement analysis may turn on whether the accused products, which are advertised as fitting multiple firearm brands like "Glock, S&W, Sig and more," achieve this versatility using the claimed "adaptor flange" structure or some other means that falls outside the claim scope. (Compl. p. 13).

V. Key Claim Terms for Construction

  • The Term: "adaptor flange"

    • Context and Importance: This term appears to define the component that attaches to the firearm and interfaces with the holster clip. Its construction is critical because if the accused products achieve firearm attachment through a different structure, there may be no infringement. Practitioners may focus on whether this term requires a separate component distinct from the firearm's frame or if it can read on an integrated feature.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: Claim 1 describes the flange functionally as being "securable to a firearm and formed with an opening." The specification notes that the flange could be a separate component like "flange 60, used as an adaptor for using the holster 50." (’271 Patent, col. 4:8-9). This could support an interpretation where any component added to the firearm to create the necessary interface is an "adaptor flange."
      • Evidence for a Narrower Interpretation: The primary embodiment describes the flange as being part of the "brace assembly 10" and constructed of "left and right halves" that are fastened together around the firearm's receiver and trigger guard. (’271 Patent, col. 2:45-50). A defendant might argue that "adaptor flange" is limited to this more complex, two-part structure illustrated in the figures.

  • The Term: "click over a border"

    • Context and Importance: This phrase describes the locking mechanism. The dispute will likely center on the specific structural and functional requirements of this "click." The complaint's visuals show ads for the accused product that mention "Adjustable Retention," which may or may not be achieved by the claimed "clicking" mechanism. (Compl. p. 13).
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The claims do not specify the material or geometry that produces the "click," potentially covering any mechanism where a resilient part deforms and snaps back into place over an edge to create secure retention with an audible or tactile confirmation.
      • Evidence for a Narrower Interpretation: The specification links this action to "resilient arms 55" interacting with "opening 61." (’271 Patent, col. 4:11-15). A defendant could argue this term requires the specific geometry of the arms and opening shown in Figures 4A-4C and is not met by other common retention systems (e.g., a friction-based system or a detent).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges contributory infringement and inducement against Meta. (Compl. ¶¶109-127). The allegations state Meta had knowledge of the Navia Defendants' infringing activity, provided the platform that is a material part of the infringement, and used its algorithms to amplify advertisements for the infringing products to Plaintiff's customers. (Compl. ¶114, ¶123). Knowledge is partly based on Plaintiff's prior takedown notices for trademark infringement, with Plaintiff arguing Meta's failure to create a patent reporting tool constitutes willful blindness. (Compl. ¶70, ¶83).
  • Willful Infringement: Willfulness is not pleaded as a separate count but is implied in the allegations against all defendants. The complaint alleges the Navia Defendants "purposely designed" their products to mimic Plaintiff's (Compl. ¶36) and that Meta acted with "deliberate and willful avoidance" of information about infringement on its platform (Compl. ¶58).

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

  • A core issue will be one of evidentiary sufficiency: Can Plaintiff produce technical evidence demonstrating that the accused holster assemblies, marketed as versatile solutions, literally incorporate every element of the asserted claims, particularly the specific "adaptor flange" and "click over a border" retention mechanism described in the ’271 Patent?
  • A second central issue will be the scope of intermediary liability: Can knowledge of trademark infringement be used to establish the knowledge and intent required for patent inducement or contributory infringement against a platform like Meta, especially when the platform allegedly provides no direct mechanism for patent holders to report infringement?
  • Finally, the case presents a question of functional operation: Does the accused products' "Adjustable Retention" feature, as advertised in screenshots provided in the complaint, operate by the same means as the claimed "click over a border" function, or does it represent a technologically distinct, non-infringing alternative?