DCT
4:25-cv-00497
Dead Air Armament LLC v. Jarvis Arms LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Dead Air Armament, LLC d/b/a Dead Air Silencers (a North Carolina LLC with a principal place of business in Utah)
- Defendant: Jarvis Arms LLC d/b/a Mission Silencers (Idaho)
- Plaintiff’s Counsel: Hawley Troxell Ennis & Hawley LLP; Alston & Bird LLP
- Case Identification: 1:25-cv-00497, D. Idaho, 08/29/2025
- Venue Allegations: Venue is alleged to be proper in the District of Idaho because the sole Defendant is an Idaho limited liability company that resides in the district.
- Core Dispute: Plaintiff seeks a declaratory judgment that its RXD22Ti firearm suppressor does not infringe Defendant's patent related to a firearm suppression system.
- Technical Context: The technology concerns firearm suppressors, devices designed to reduce the sound, muzzle flash, and gas blowback associated with discharging a firearm.
- Key Procedural History: The action was precipitated by a cease-and-desist letter sent by Defendant's counsel to Plaintiff on June 9, 2025. The letter accused Plaintiff's RXD22Ti suppressor of infringing at least Claim 1 of the patent-in-suit and threatened legal action if Plaintiff did not cease sales or take a license.
Case Timeline
| Date | Event |
|---|---|
| 2022-10-27 | '906 Patent Priority Date |
| 2024-06-25 | '906 Patent Issue Date |
| 2025-06-09 | Defendant sends cease-and-desist letter to Plaintiff |
| 2025-08-29 | Complaint for Declaratory Judgment filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,018,906 - "Firearm Suppression System"
- Patent Identification: U.S. Patent No. 12,018,906, "Firearm Suppression System", issued June 25, 2024 (’906 Patent).
The Invention Explained
- Problem Addressed: The patent's background section states that many firearm suppressors on the market fail to adequately reduce muzzle flash, noise, and back gassing simultaneously, often improving one metric at the expense of others ('906 Patent, col. 1:36-44).
- The Patented Solution: The invention is a suppression system featuring a main housing and a removable internal "core" ('906 Patent, col. 2:6-8). The design creates a "channel" between the outer surface of the core and the inner surface of the housing. This channel is described as enabling a "pressure equalizing technology (PET)" where high-pressure gases can immediately fill the entire volume of the suppressor, converting high pressure to low pressure rapidly and reducing gas blowback towards the user ('906 Patent, col. 5:3-11; col. 6:61-65). The core itself contains a plurality of apertures and internal baffles to manage gas flow and reduce sound ('906 Patent, Abstract).
- Technical Importance: The described approach seeks to overcome the inverse relationship between sound reduction and back gassing, particularly in gas-operated firearms, by providing a novel method for managing gas pressure dynamics within the suppressor ('906 Patent, col. 5:12-23).
Key Claims at a Glance
- The complaint asserts non-infringement of all claims, with a focus on independent claims 1, 13, and 17 (Compl. ¶¶25, 27).
- Independent Claim 1:
- a housing comprising a first end and a second end;
- an inner compartment;
- an end cap with a projectile aperture; and
- a core removably attachable to the housing, wherein the core has apertures that allow gas to pass to a channel between the housing and core, which circumscribes the core and equalizes pressure from the first end to the second end of the housing.
- Independent Claim 13:
- a housing and inner compartment;
- an end cap actuated by pressure, the end cap comprising a projectile aperture, a parallel pressure channel, and a perpendicular closure channel; and
- a core with apertures and baffles.
- Independent Claim 17:
- a housing and inner compartment;
- a muzzle adapter;
- an end cap with a projectile aperture;
- a core with apertures, baffles, and one or more pressure reduction tubes; and
- a disc interposed between the end cap and the core.
III. The Accused Instrumentality
Product Identification
- The Dead Air RXD22Ti suppressor (Compl. ¶9).
Functionality and Market Context
- The complaint describes the RXD22Ti as a "high-performance" suppressor for rifles and pistols (Compl. ¶9). The core of the non-infringement argument is based on the specific structure of the product. The complaint alleges that the RXD22Ti does not have "an end cap with a projectile aperture" as a single component; rather, it has an end cap and a separate projectile aperture that is part of the suppressor's core (Compl. ¶¶25-26). It further alleges the product lacks the claimed "channel" for equalizing pressure (Compl. ¶28). The complaint describes a visual from the Defendant's demand letter that allegedly identifies the "end cap (red circle)" as distinct from the "projectile aperture (light blue arrow)" (Compl. ¶25).
IV. Analysis of Infringement Allegations
'906 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an end cap with a projectile aperture | The complaint alleges the RXD22Ti suppressor does not meet this limitation because its projectile aperture is part of the core, not the end cap. | ¶¶25, 26 | col. 12:35 |
| a core removably attachable to the housing and positioned therein... to pass to a channel between the inner surface of the housing and an outer surface of the core, the channel circumscribes the outer surface of the core and equalizes pressure that begins at the first end of the housing and terminates at the second end of the housing | The complaint alleges the RXD22Ti suppressor does not have a "channel" that performs the claimed circumscribing and pressure-equalizing function. | ¶28 | col. 12:39-47 |
Identified Points of Contention
- Scope Questions: A primary dispute may concern the construction of "an end cap with a projectile aperture." The question for the court will be whether this language requires the projectile aperture to be an integral feature of the end cap component, or if it can be read on a device that has a separate end cap and an adjacent projectile aperture located on a different component (the core).
- Technical Questions: A key factual question will be whether the RXD22Ti suppressor contains a physical structure that meets the definition of the claimed "channel" and, if so, whether that structure performs the claimed function of equalizing pressure along the length of the housing. The complaint notes that the claim chart in Defendant's demand letter acknowledged that "the channel is not shown" in the provided image of the accused product (Compl. ¶28).
V. Key Claim Terms for Construction
The Term: "an end cap with a projectile aperture" (Claim 1)
Context and Importance: This term is central to Plaintiff's primary non-infringement theory. The interpretation of the word "with" will be critical to determining whether Plaintiff's product, which allegedly has a separate end cap and a projectile aperture on its core, can infringe.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that "with" should be interpreted as "associated with" or "accompanied by," not necessarily "integrally formed with." The claims do not explicitly state that the end cap and aperture must be a single, unitary piece.
- Evidence for a Narrower Interpretation: The patent specification states, "The end cap 110 may also comprise a projectile/bullet aperture 128" ('906 Patent, col. 6:20-23). The use of "comprise" suggests the aperture is a constituent part of the end cap, supporting an interpretation that they are a single component.
The Term: "channel... that equalizes pressure" (Claim 1)
Context and Importance: This term is the basis for Plaintiff's second non-infringement argument. The dispute will likely focus on both the structural definition of "channel" and the functional requirement of "equalizes pressure."
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term "channel" itself is not explicitly defined, which may support a construction covering any space between the core and housing that allows for gas flow. The function "equalizes pressure" could be argued to encompass any process that allows pressure to distribute throughout the suppressor.
- Evidence for a Narrower Interpretation: The specification provides a detailed functional description, stating the channel "allows the incoming high pressure... immediately [to] flow to the outside of the core... and proceed down the entire length of the firearm suppression system... so that high pressure is converted to low pressure" ('906 Patent, col. 7:1-7). This specific description of the gas dynamics could be used to argue that the term requires not just any channel, but one that performs this specific pressure-equalizing function.
VI. Other Allegations
- Indirect Infringement: The complaint denies liability for induced or contributory infringement, basing this denial on the assertion that there is no underlying direct infringement of the '906 Patent by the RXD22Ti suppressor (Compl. ¶¶30, 31).
- Willful Infringement: The complaint seeks a declaration of non-willful infringement (Compl. p. 7, ¶2). Any potential claim of willfulness by the Defendant would likely be based on Plaintiff's alleged knowledge of the '906 Patent as of the receipt of the June 9, 2025 cease-and-desist letter (Compl. ¶17).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: does the claim term "an end cap with a projectile aperture" require a single, integrated component, or can it be construed to cover an assembly where the end cap and the projectile aperture exist on two separate but adjacent parts (the end cap and the core)? This is a fundamental claim construction question that may significantly impact the outcome.
- A key evidentiary question will be one of technical and factual presence: does the accused RXD22Ti suppressor, in its actual construction, contain a "channel" between its core and housing that performs the specific function of "equalizing pressure" as described and claimed in the '906 Patent? This will likely require expert analysis of the device's internal gas dynamics.