Patent Holder LLC v. Lone Wolf DIS

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Patent Holder, LLC. (Florida)
  • Defendant: Lone Wolf Distributors, Inc. and Lone Wolf R&D LLC. (Idaho)
  • Plaintiff’s Counsel: Albert Bordas, P.A.
• Case Identification: 2:17-cv-00452, S.D. Fla., 08/11/2017
• Venue Allegations: Plaintiff alleges venue is proper because Defendants regularly conduct business in the district, have committed acts of infringement there, and are subject to personal jurisdiction in the forum.
• Core Dispute: Plaintiff alleges that Defendants’ aftermarket firearm trigger connectors infringe a patent related to an enhanced trigger control mechanism designed to improve firearm performance.
• Technical Context: The technology concerns mechanical components for semi-automatic firearms, a market segment that includes law enforcement, sport shooters, and private owners seeking to customize and improve weapon accuracy and firing speed.
• Key Procedural History: The patent-in-suit is a division of a prior application, now U.S. Patent No. 9,062,925, which may be relevant to the prosecution history and interpretation of the asserted claims. The complaint alleges Defendants were notified of the infringing product but continued to sell it.

Case Timeline

Date	Event
2013-01-09	'700 Patent Priority Date
2016-08-02	'700 Patent Issued
2017-08-11	Complaint Filed

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

U.S. Patent No. 9,404,700 - "ENHANCED TRIGGER CONTROL CONNECTOR"

• Patent Identification: U.S. Patent No. 9,404,700, "ENHANCED TRIGGER CONTROL CONNECTOR", issued August 2, 2016.

The Invention Explained

• Problem Addressed: In certain semi-automatic firearms, the standard trigger mechanism exhibits undesirable characteristics. Specifically, the trigger bar travels rearward and downward during a trigger pull, creating "excess travel" and making contact with a "lip" that acts as an "obstruction." This requires the user to exert a "second force" to overcome it, which can reduce firing accuracy and precision (’700 Patent, col. 1:29-39).
• The Patented Solution: The invention is a redesigned connector component that replaces the standard part. It features a "guide lip" bent at a specific, less acute angle (angle B) that guides the firearm's trigger bar without the obstruction found in the prior art (’700 Patent, col. 4:53-60; Fig. 3). This new geometry is intended to eliminate the "second force" required from the user. The connector also includes a "control tab" that acts as a hard stop to prevent trigger "over-travel," thereby shortening the trigger's travel distance and reset, allowing for faster follow-up shots (’700 Patent, col. 4:61-65).
• Technical Importance: The claimed invention provides a mechanical solution to improve shooting performance by creating a smoother, shorter trigger pull, which is a desirable attribute for both precision and rapid-fire shooting applications (’700 Patent, col. 1:54-68).

Key Claims at a Glance

• The complaint asserts infringement of at least one claim without specifying which ones (Compl. ¶29). Independent claim 1 is the broadest claim and is central to the patent.
• Independent Claim 1 Essential Elements:
  • A torso comprising a guide lip positioned at a first predetermined angle approximately between 68 and 78 degrees with respect to the torso.
  • The guide lip containing a trigger bar of a firearm.
  • A first connector leg extending from the torso, having a disconnector tab at a third predetermined angle approximately between 81 and 91 degrees.
  • A control tab extending from the first connector leg along the same axis.
  • A second connector leg that removably fits within a trigger housing.
  • The trigger bar "nearly contacts or contacts" the guide lip when the firearm is in a rest position.
• The complaint does not explicitly reserve the right to assert dependent claims, but its general allegation could encompass them.

III. The Accused Instrumentality

Product Identification

• The complaint identifies the accused products as enhanced trigger control connectors sold under the model names "LWD-342-4243, LWD G42/43 3.5 Connector" (Compl. ¶18).

Functionality and Market Context

• The complaint alleges these products are aftermarket firearm parts and accessories (Compl. ¶18). It states that Defendants "chose to copy PATENT HOLDER's technology and innovative style" rather than develop their own (Compl. ¶20).
• The complaint alleges that Defendants manufacture, or have manufactured, and sell these connectors without a license (Compl. ¶19).
• The complaint does not provide sufficient detail for analysis of the specific technical operation of the accused connectors.

IV. Analysis of Infringement Allegations

The complaint alleges that the accused "LWD-342-4243, LWD G42/43 3.5 Connector" contains elements defined by the claims of the '700 Patent and refers to an "enclosed Exhibit 11" to support this allegation (Compl. ¶21). As this exhibit was not included with the public filing, a detailed element-by-element analysis based on the complaint is not possible. The narrative theory of infringement is that the accused products are direct copies of the plaintiff's patented technology (Compl. ¶20).

No probative visual evidence provided in complaint.

• Identified Points of Contention: Based on the specificity of the patent claims, the infringement analysis will likely focus on several key technical and legal questions:
  • Scope Questions: Do the specific geometric angles of the accused connectors fall within the claimed numerical ranges of "approximately between 68 and 78 degrees" for the guide lip and "approximately between 81 and 91 degrees" for the disconnector tab, as required by claim 1?
  • Technical Questions: What evidence will be presented to demonstrate that the accused connector's interaction with a trigger bar satisfies the "nearly contacts or contacts" limitation when a firearm is in its rest position? The precise distance between these components will be a critical factual issue.

V. Key Claim Terms for Construction

• The Term: "approximately between 68 degrees and 78 degrees"

• Context and Importance: This term defines the geometric orientation of the guide lip, which is the core feature for eliminating the "obstruction" of the prior art. The scope of "approximately" will determine whether a connector with an angle slightly outside the 68-78 degree range infringes.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The use of the word "approximately" itself suggests the patentee did not intend to be strictly limited to the recited numerical endpoints (’700 Patent, col. 4:55-57).
  • Evidence for a Narrower Interpretation: The specification discloses a "preferred embodiment" where the angle is "approximately 75 degrees" (’700 Patent, col. 3:20-22). A defendant may argue this disclosure limits the scope of "approximately" to a narrow band around 75 degrees. Dependent claim 15 recites that the angle is "approximately 75 degrees," which could be used to argue that the broader range in claim 1 must have a distinct and wider meaning.

• The Term: "nearly contacts"

• Context and Importance: This term is critical for infringement, as it describes the required proximity of the trigger bar to the guide lip in the firearm's resting state. This close positioning is what allows the connector to "eliminate undesired trigger pull obstruction" from the start of the pull (’700 Patent, col. 4:48-50). Practitioners may focus on this term because its definition could be case-dispositive.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The plain meaning of "nearly" suggests a close, but not touching, relationship, leaving some ambiguity.
  • Evidence for a Narrower Interpretation: The specification provides an explicit definition in a preferred embodiment, stating that ""nearly contacts" is defined as a distance up to approximately 3 mm" (’700 Patent, col. 4:51-52). Dependent claim 6 also recites this 3 mm distance. This provides strong intrinsic evidence to construe "nearly contacts" with this specific numerical limit.

VI. Other Allegations

• Indirect Infringement: The complaint makes conclusory allegations of induced and contributory infringement (Compl. ¶29). It alleges Defendants knew of the '700 Patent and intended for their customers to use the accused products in an infringing manner, but it does not plead specific facts such as references to user manuals or instructions that would actively encourage infringement.
• Willful Infringement: The complaint alleges that Defendants' infringement was and continues to be willful. This is based on allegations that Defendants have actual knowledge of the '700 patent and were "notified of their infringing product being sold on their website" but "knowingly continued to sell" it (Compl. ¶22-26).

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

1. A central question will be evidentiary and factual: given the complaint's lack of technical specifics, what proof will Plaintiff offer to demonstrate that the precise geometry and component interactions of the accused connectors—specifically their operational angles and resting-state proximity to the trigger bar—fall within the explicit numerical ranges and definitions required by claim 1 of the '700 Patent?

2. The case may also turn on a question of claim construction: how will the court interpret the scope of terms like "approximately" when applied to numerical ranges, and "nearly contacts"? The patent provides a specific definition for "nearly contacts" that may significantly narrow the scope of infringement, making the court's construction of that term a potentially dispositive issue.