Centre Firearms Co Inc v. Otter Creek Labs LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Centre Firearms Co., Inc. (New York)
  • Defendant: Otter Creek Labs, LLC (Kentucky)
  • Plaintiff’s Counsel: Taylor, Keller & Oswald, PLLC
• Case Identification: 6:25-cv-00210, E.D. Ky., 11/20/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Kentucky because Defendant is a resident of London, Kentucky, and maintains a corporate office and manufacturing facility within the district.
• Core Dispute: Plaintiff alleges that Defendant’s "Infinity" model firearm suppressors infringe three patents related to monolithic, or single-piece, noise suppression devices.
• Technical Context: The technology concerns firearm suppressors manufactured as a single, seamless unit to improve structural reliability and performance compared to traditional multi-component, welded designs.
• Key Procedural History: The complaint alleges Plaintiff notified Defendant of the asserted patents on March 5, 2025. It further alleges that Defendant refused to engage in business discussions and instead responded via social media posts, which Plaintiff cites as evidence of willful infringement.

Case Timeline

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

U.S. Patent No. 9,470,466 - Monolithic Noise Suppression Device for Firearm

Issued October 18, 2016 (’466 Patent, (45); Compl. ¶21).

The Invention Explained

• Problem Addressed: The patent’s background describes conventional firearm suppressors as being constructed from multiple separate components that are welded together (’466 Patent, col. 2:38-46). These welded joints or seams are identified as inherent reliability issues, creating points of potential structural failure under the high pressure of propellant gas (’466 Patent, col. 2:42-46).
• The Patented Solution: The invention is a "truly monolithic" noise suppressor where the internal core (containing baffles) and the external body are fabricated as a single, seamless piece (’466 Patent, col. 3:28-36). This construction, illustrated in Figure 3, eliminates the welded seams found in prior art devices (shown in Figure 1), thereby enhancing structural integrity (’466 Patent, col. 6:38-46). The specification proposes manufacturing the device using a "layered printing process," such as 3D printing (’466 Patent, col. 6:61-63).
• Technical Importance: This monolithic approach was intended to improve suppressor reliability by removing structural weak points and to reduce manufacturing costs, which could in turn facilitate customization (’466 Patent, col. 3:16-21).

Key Claims at a Glance

• The complaint asserts at least independent Claim 1 (Compl. ¶40).
• Claim 1 of the ’466 Patent requires:
  • A body having an outermost external surface and an internal surface;
  • A plurality of internal chambers;
  • A core comprising one or more baffles having space between the baffles forming the plurality of internal chambers, seamlessly connected to the internal surface of the body;
  • Wherein the noise suppression device includes no joints, seams, or any formerly separate pieces within any of the body, the core, and the one or more baffles.

U.S. Patent No. 9,777,979 - Monolithic Noise Suppression Device for Firearm

Issued October 3, 2017 (’979 Patent, (45); Compl. ¶22).

The Invention Explained

• Problem Addressed: As a continuation of the application leading to the ’466 Patent, the ’979 Patent addresses the same problem of potential structural failure in conventional suppressors caused by welded joints between components (’979 Patent, col. 2:50-54).
• The Patented Solution: This patent claims a similar monolithic baffle housing module but adds a distinct element: a "blast insert" that is attached to the monolithic module (’979 Patent, Abstract). The core of the invention remains the seamless, single-piece housing, but this two-part assembly allows the blast insert—the component that endures the initial, most intense pressure—to be a separate piece, potentially made from a different, more durable material than the main body (’979 Patent, col. 10:35-42).
• Technical Importance: This design combines the reliability of a monolithic main body with the potential for enhanced durability or material specialization in the high-wear blast insert area.

Key Claims at a Glance

• The complaint asserts at least independent Claim 1 (Compl. ¶48).
• Claim 1 of the ’979 Patent requires:
  • A monolithic integral baffle housing module including a body, internal chambers, and a seamlessly connected core with a baffle;
  • A blast insert attached to the monolithic integral baffle housing module;
  • Wherein the monolithic integral baffle housing module includes no joints, no seams, or any formerly separate pieces within the body or the core.

U.S. Patent No. 9,982,959 - Monolithic Noise Suppression Device for Firearm

Issued May 29, 2018 (’959 Patent, (45); Compl. ¶23).

Technology Synopsis

As part of the same patent family, the ’959 Patent covers a monolithic noise suppressor that is structurally similar to that of the ’466 Patent. The key distinction in its independent claim is an explicit material limitation, requiring that "the monolithic noise suppression device is made of one of a metal and a metal alloy" (’959 Patent, col. 14:20-22). This claim applies the monolithic manufacturing concept to metal construction, which aligns with modern additive manufacturing techniques for metals.

Asserted Claims

The complaint asserts at least independent Claim 1 (Compl. ¶56).

Accused Features

The complaint alleges the accused "Infinity" suppressor is made via "DMLS [direct metal laser sintering] 3D printed & heat treated 718 inconel," which is a metal alloy (Compl. ¶25). This allegation directly targets the metal material limitation of the ’959 Patent.

III. The Accused Instrumentality

Product Identification

The accused products are Otter Creek’s "Infinity" model suppressors (the "Accused Products") (Compl. ¶¶25-26).

Functionality and Market Context

• The complaint identifies the Accused Products as noise suppression devices for firearms (Compl. ¶24).
• A central technical allegation is that the Accused Products are "made from DMLS [direct metal laser sintering] 3D printed & heat treated 718 inconel" (Compl. ¶25). Direct metal laser sintering is an additive manufacturing process that builds a metal object layer-by-layer from a powder, which can create a single, integral component without traditional joints or welds.
• The complaint alleges Defendant manufactures these devices at a facility in London, Kentucky (Compl. ¶27).

IV. Analysis of Infringement Allegations

The complaint references claim charts in Exhibits 11, 12, and 13, but these exhibits were not filed with the complaint itself. The infringement theory is therefore summarized from the complaint's narrative allegations.

’466 Patent Infringement Allegations

The complaint alleges that the Accused Products directly infringe at least Claim 1 of the ’466 Patent (Compl. ¶40). The core of this allegation appears to be that the DMLS 3D-printing process used to make the "Infinity" suppressor results in a single-piece device that meets the "monolithic" and "no joints, seams, or any formerly separate pieces" limitations of the claim (Compl. ¶¶18, 25).

’979 Patent Infringement Allegations

The complaint alleges infringement of at least Claim 1 of the ’979 Patent, which requires both a monolithic module and an attached "blast insert" (Compl. ¶48). The complaint does not provide sufficient detail for analysis of how the Accused Products allegedly meet the "blast insert" limitation. It makes a conclusory allegation that the "Infinity" suppressor infringes this claim without identifying a specific corresponding component (Compl. ¶¶19, 49).

No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: A central question for the court will be one of claim construction: does a device manufactured via a DMLS 3D-printing process qualify as "monolithic" and containing "no joints, seams, or any formerly separate pieces" as those terms are used in the patents? The defense may argue that the layer-by-layer fusion inherent in additive manufacturing creates structural interfaces that could be construed as a type of seam or joint.
• Technical Questions: For the ’979 Patent, a key factual dispute will likely be whether the "Infinity" suppressor has a distinct, attached component that functions as a "blast insert." The complaint provides no evidence on this point, raising the question of whether the accused device is a fully integrated, single component that may lack this claimed element entirely.

V. Key Claim Terms for Construction

• The Term: "monolithic"

• Context and Importance: This term is the foundation of all asserted patents. Its construction will determine whether the accused 3D-printed metal suppressors fall within the scope of the claims. Practitioners may focus on this term because the accused manufacturing method (DMLS) did not exist in its current commercial form when the patent was filed, creating a potential dispute over whether it was contemplated by the inventors.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification repeatedly contrasts the invention with prior art devices constructed by welding separate segments together (’466 Patent, col. 2:38-46). It defines a monolithic device as one that "at least exhibits no welded joints or seams" between its core and body, suggesting the primary meaning is the absence of such welds (’466 Patent, col. 3:32-36).
  • Evidence for a Narrower Interpretation: The specification also states that in prior art, it was known to manufacture a "monolithic core" as a "single, integral unit," which was then inserted into an outer structure (’466 Patent, col. 2:47-53). A defendant could argue this establishes a narrower meaning of "monolithic" that does not encompass the entire device (body and core) as a single unit formed by layered printing.

• The Term: "no joints, seams, or any formerly separate pieces"

• Context and Importance: This phrase, which appears in the independent claims of all asserted patents, quantifies the "monolithic" concept. The infringement analysis will depend on whether the internal structure of a DMLS-printed object is considered to be free of "joints" or "seams."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent provides context by referencing the prior art "weld joints or seams that appear between each of the segments in FIG. 1" (’466 Patent, col. 2:42-46). This suggests the terms refer to macroscopic connections between prefabricated parts, which are absent in a device printed as a single, continuous object.
  • Evidence for a Narrower Interpretation: The defense may argue that microscopic boundaries between the fused layers of metal powder in a DMLS part constitute a form of "seam" or "joint" from a metallurgical perspective, even if they are not traditional welds. The patent does not define the terms at this microscopic level, leaving it open to interpretation.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement based on Defendant selling the Accused Products to customers and providing "marketing material and/or product packaging intended to promote subsequent use and re-sale" (Compl. ¶¶42, 50, 58).
• Willful Infringement: The complaint alleges Defendant had knowledge of the patents as of at least March 5, 2025, the date of Plaintiff's first notice letter (Compl. ¶¶29, 44). The willfulness claim is further based on allegations that Defendant refused to engage in discussions and subsequently posted statements on social media, such as "Not only am I not ceasing Nor am I desisting I'm releasing more printed fucking cans," which Plaintiff asserts demonstrates "a complete disregard and even contempt for Centre Firearms' patent rights" (Compl. ¶¶1, 37).

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

• A core issue will be one of definitional scope: can the terms "monolithic" and "no joints, seams," which are rooted in distinguishing from traditional multi-part welded suppressors, be construed to read on a device created by modern additive manufacturing (DMLS 3D printing)? This question will require the court to apply the patent’s language to a newer technology.
• A key evidentiary question will be one of component structure: for the ’979 patent, does the accused "Infinity" suppressor contain a distinct, identifiable "blast insert" that is "attached to" the main body, as required by the claim? The current complaint provides no factual basis for this element, suggesting it will be a significant point of factual dispute.
• The case will also present a critical question of litigation conduct and intent: do the defendant's alleged social media responses to pre-suit notice letters constitute the kind of egregious conduct sufficient to support a finding of willful infringement and justify an award of enhanced damages under 35 U.S.C. § 284?