DCT
1:24-cv-00472
AOB Products Co v. Nanyang Jianling Trading Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: AOB Products Company (Missouri)
- Defendant: Nanyang Jianling Trading Co., Ltd. (China)
- Plaintiff’s Counsel: K&L GATES LLP
- Case Identification: 1:24-cv-00472, N.D. Ill., 01/18/2024
- Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Illinois because Defendant has committed acts of infringement within the district, including making, selling, importing, or offering infringing products for sale.
- Core Dispute: Plaintiff alleges that Defendant’s Death Grip Tripod infringes a patent related to firearm shooting rests.
- Technical Context: The technology involves mechanical rests designed to support a firearm, providing stability and adjustability to improve a user's shooting accuracy.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of infringement via a letter on September 13, 2023, which demanded that Defendant cease infringing activities. The complaint also notes that Plaintiff maintains a virtual patent marking website in compliance with 35 U.S.C. § 287.
Case Timeline
| Date | Event |
|---|---|
| 2018-01-17 | U.S. Patent No. 10,514,225 Application (Priority) Date |
| 2019-12-24 | U.S. Patent No. 10,514,225 Issued |
| 2023-09-13 | Plaintiff Sent Pre-Suit Notice of Infringement to Defendant |
| 2024-01-18 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,514,225 - "Firearm shooting rest,"
- Patent Identification: U.S. Patent No. 10,514,225, "Firearm shooting rest," issued December 24, 2019.
The Invention Explained
- Problem Addressed: The patent background notes that firearm rests are used to support the weight of a firearm, which helps a user aim more steadily and improve shooting accuracy (’225 Patent, col. 1:10-14). The implicit problem is the need for a single device that can both securely hold a firearm and allow for precise, fine-tuned aiming adjustments.
- The Patented Solution: The invention is a shooting rest featuring a forward support cradle designed to clamp a firearm. A key aspect of the solution is a clamp actuator with a single knob that moves two opposing jaws toward each other simultaneously and at the same rate, ensuring the firearm remains centered as it is clamped (’225 Patent, col. 6:1-9, 6:25-40). The forward support is mounted on a frame, often a tripod, and can pivot to allow for both horizontal (yaw) and vertical (pitch) aiming adjustments while the firearm is secured (’225 Patent, col. 3:35-4:15).
- Technical Importance: The design provides a stable, "turret rest" platform where the firearm's aim can be finely adjusted without unclamping it, which is valuable in dynamic shooting situations or for achieving high precision (’225 Patent, col. 8:26-35).
Key Claims at a Glance
- The complaint asserts independent claim 1 of the ’225 Patent (Compl. ¶20).
- The essential elements of independent claim 1 include:
- A cradle for supporting the forward portion of a firearm, comprising first and second jaws, a bed between the jaws, and an actuator.
- The first jaw has a threaded opening, and the actuator has a threaded section that engages the opening.
- The jaws are movable to clamp the firearm, and the actuator is configured to move the first jaw by rotation of its threaded section.
- The cradle includes first and second wings spaced laterally outboard from the bed, with the jaws located between the bed and the wings.
- The jaws have retracted and clamping positions.
- The cradle includes first and second guides extending between the bed and the wings.
- The first and second jaws each include at least one follower movable along the respective guides.
III. The Accused Instrumentality
Product Identification
- The complaint identifies the "Death Grip Tripod" as the accused instrumentality (Compl. ¶19).
Functionality and Market Context
- The complaint alleges the Death Grip Tripod is a shooting rest sold by Defendant through an Amazon.com storefront named "Precision hunting" (Compl. ¶14, 15). Based on allegations and visual evidence in the complaint, the product is a tripod equipped with a clamping head. This head features two padded jaws that are moved by a rotating knob (actuator) to grip the forward portion of a firearm (Compl. ¶24, 27). The complaint includes an image from the product's Amazon listing, which describes it as a "Lightweight-Adjustable-Hands-Free-Operation" tripod (Compl. ¶15).
IV. Analysis of Infringement Allegations
’225 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a cradle for supporting the forward portion of the firearm, the cradle including first and second jaws, a bed between the jaws, and an actuator... | The complaint alleges the accused product includes a cradle with two jaws, a bed, and an actuator, as shown in an annotated image. (Compl. ¶24) | ¶24 | col. 5:48-54 |
| ...the first jaw including a first threaded opening, the actuator including a shaft having a first threaded section, the first threaded section being threaded in the first threaded opening... | The complaint alleges the accused product's actuator has a threaded section that engages a threaded opening in the first jaw, supported by a labeled diagram. (Compl. ¶25) | ¶25 | col. 6:25-31 |
| ...the first and second jaws being movable with respect to the bed to clamp the forward portion of the firearm between the jaws... | A visual in the complaint depicts the jaws of the accused product moving from an open to a closed position relative to the bed. (Compl. ¶26) | ¶26 | col. 5:65-6:3 |
| ...the actuator being operable to move the first and second jaws toward each other...the actuator configured to move the first jaw by rotation of the first threaded section in the first threaded opening... | The complaint provides images alleging that rotating the actuator on the accused product moves the jaws and that this movement is driven by the rotation of the threaded section. (Compl. ¶27, 28) | ¶27, ¶28 | col. 6:22-25 |
| ...wherein the cradle includes first and second wings spaced laterally outboard from the bed... | The complaint identifies components on the accused product as "first wing" and "second wing" located outboard of the "bed." (Compl. ¶29) | ¶29 | col. 6:4-7 |
| ...the first jaw including at least one follower movable along the first guide... and the second jaw including at least one follower movable along the second guide... | The complaint alleges the accused product includes guides and a "follower" on each jaw that moves along the guides, illustrated with a labeled image. (Compl. ¶31, 32) | ¶32 | col. 6:58-64 |
Identified Points of Contention
- Scope Questions: The complaint alleges the actuator moves "the first and second jaws toward each other" (Compl. ¶27), but the patent specification describes a specific mechanism with opposing left-hand and right-hand threads that ensures the jaws move "at the same time and at the same rate of movement" (’225 Patent, col. 6:1-3, 6:25-31). A point of contention may arise over whether the accused product’s actuator performs this simultaneous and same-rate movement, and whether the claim scope requires it.
- Technical Questions: Claim 1 requires each jaw to have a "follower movable along the... guide." The complaint identifies a component as a "follower" (Compl. ¶32). A technical question for the court will be whether the structure and operation of this accused component meet the functional requirements of a "follower" as understood in the context of the patent, which describes the follower as an opening in the jaw through which a guide rod passes (’225 Patent, col. 6:61-64).
V. Key Claim Terms for Construction
The Term: "actuator"
- Context and Importance: The "actuator" is the core mechanism for clamping the firearm. The patent’s only disclosed embodiment is a single shaft with opposing left-hand and right-hand threads to move both jaws simultaneously toward the center. Practitioners may focus on this term because its construction will determine whether the claim is limited to this specific dual-action mechanism or if it can read on other structures that move the jaws, even if not at the exact same rate.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The language of claim 1 itself requires an "actuator... operable to move the first and second jaws toward each other," without specifying the mechanism or requiring simultaneous or same-rate movement (’225 Patent, col. 8:65-col. 9:1).
- Evidence for a Narrower Interpretation: The specification repeatedly emphasizes that the actuator moves the jaws "at the same time and at the same rate of movement" and only discloses the dual-threaded shaft (80A, 80B) to achieve this result (’225 Patent, col. 6:1-3, 6:25-31). A party could argue this feature is central to the invention and should be read into the term "actuator."
The Term: "follower"
- Context and Importance: The "follower" and "guide" system is critical for the controlled movement of the jaws. Infringement of this limitation depends entirely on whether the accused product's sliding mechanism constitutes a "follower" as claimed.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not provide a special definition for "follower," which could support using its plain and ordinary meaning in mechanics—a component that is guided by or follows the path of another.
- Evidence for a Narrower Interpretation: The patent describes the followers in a specific structural context as "followers 76D (FIG. 8) that are slidable along the slides" and are "provided in the form of circular openings in the jaws 76 through which the slides 86A, 86B pass" (’225 Patent, col. 6:58-64). This could support an interpretation that limits the term to a component with an opening that slides on a rod-like guide.
VI. Other Allegations
Willful Infringement
- The complaint alleges that Defendant's infringement is, and has been, willful (Compl. ¶39). This allegation is based on the claim that Defendant had pre-suit knowledge of the ’225 Patent since at least September 13, 2023, the date Plaintiff allegedly sent a notice letter, and that Defendant continued its infringing activities thereafter (Compl. ¶13, 38).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of claim construction: can the term "actuator", which the patent’s specification describes as a mechanism that moves both jaws "at the same time and at the same rate," be construed to cover the accused product's mechanism, or will its scope be limited by the sole embodiment disclosed?
- A key evidentiary question will be one of technical operation: does the accused product's clamping mechanism, particularly the interaction between its alleged "follower" and "guide" components, function in the specific manner required by the claim language, and does the evidence show that its actuator moves both jaws toward each other as claimed?