DCT
1:17-cv-00483
Steyr Arms Inc v. Sig Sauer Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Steyr Arms, Inc. (Alabama)
- Defendant: Sig Sauer, Inc. (Delaware)
- Plaintiff’s Counsel: Starnes Davis Florie LLP; Hoffmann & Baron, LLP
- Case Identification: 1:17-cv-00483, N.D. Ala., 05/03/2017
- Venue Allegations: Venue is alleged based on Defendant conducting business in the judicial district and a substantial part of the claims arising there.
- Core Dispute: Plaintiff alleges that Defendant’s P250 and P320 model pistols, which feature a removable chassis system, infringe a patent related to a modular, multifunction metal insert for polymer-framed pistols.
- Technical Context: The case concerns the design of modern semi-automatic pistols, specifically the use of a polymer frame combined with a serialized metal sub-assembly that houses key operational components.
- Key Procedural History: No prior litigation, licensing history, or other procedural events are mentioned in the complaint.
Case Timeline
| Date | Event |
|---|---|
| 1998-08-13 | U.S. Patent No. 6,260,301 Priority Date |
| 2001-07-17 | U.S. Patent No. 6,260,301 Issued |
| 2017-05-03 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. 6,260,301, “Pistol, Whose Housing Is Composed Of Plastic,” issued July 17, 2001.
The Invention Explained
- Problem Addressed: The patent describes the manufacturing challenges of polymer-framed pistols, where critical metal components like barrel slide guides and trigger mechanism mounts must be precisely positioned within the plastic housing. Prior methods, such as embedding individual metal parts into the plastic during molding, were described as expensive, complicated, and leading to dimensional inaccuracies that could hinder performance and make repairs difficult (’301 Patent, col. 1:18-39).
- The Patented Solution: The invention proposes a single, removable, metallic “multifunction part” that is manufactured separately with high precision. This single unit contains the slide guides and serves as the mounting point for the trigger mechanism components. The entire pre-assembled metal unit is then inserted into the plastic housing, simplifying manufacturing and repair while improving operational accuracy (’301 Patent, Abstract; col. 1:44-54). The patent’s Figure 4 shows a side view of this standalone multifunction part, illustrating its integrated nature before insertion into the pistol housing.
- Technical Importance: This approach allows for the benefits of a lightweight polymer frame while maintaining the precise, durable metal-on-metal contact required for reliable slide operation and consistent trigger function (’301 Patent, col. 1:55-61).
Key Claims at a Glance
- The complaint asserts independent Claim 1, which is the only claim in the patent (Compl. ¶10).
- Essential elements of Claim 1 include:
- A pistol comprising a housing, a barrel slide, and a trigger mechanism.
- An improvement comprising a “multifunction metal part removably insertable within said housing.”
- The multifunction metal part is provided with “guides for the barrel slide” and “means for supporting the trigger mechanism.”
- The multifunction metal part and housing each have a “transverse hole” for a connecting shaft.
- The housing has a “rear wall” with a “recess for receiving a projection on the multifunction metal part.”
- The multifunction metal part includes “control means for locking said barrel in the barrel slide.”
III. The Accused Instrumentality
Product Identification
The SIG SAUER P250 and P320 pistols (Compl. ¶11).
Functionality and Market Context
- The complaint describes the accused pistols as having a plastic housing, identified as the “grip module,” and a removable multifunction metal part, identified as the “frame” (for the P250) or “fire control assembly” (for the P320) (Compl. ¶¶12-13). This internal frame/assembly is the serialized component of the firearm, containing the trigger mechanism and slide guides.
- This modular design allows the user to swap the serialized fire control assembly between different sized grip modules and slide/barrel combinations, a key feature of the P250 and P320 product lines (Compl. ¶¶12-13).
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint.
Claim Chart Summary
The complaint’s allegations for the P250 and P320 are substantively identical. The following chart summarizes the allegations for the P250 model against Claim 1.
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a multifunction metal part removably insertable within said housing | The P250 pistol includes a multifunction metal part identified as the frame, which is removably insertable into the plastic housing identified as the grip module. | ¶12 | col. 1:44-49 |
| said multifunction metal part being provided with guides for the barrel slide | The frame includes guides for the barrel slide. | ¶12 | col. 3:3-6 |
| and means for supporting the trigger mechanism | The trigger mechanism is supported on the frame. | ¶12 | col. 2:50-61 |
| said multifunction metal part and housing are each provided with a transverse hole which receives a shaft for connecting the housing and the multifunction metal part together | The frame and grip module each include a transverse hole which receives a takedown lever for connection. | ¶12 | col. 2:44-49 |
| the housing has a rear wall which is provided with a recess for receiving a projection on the multifunction metal part | The frame includes a locking tab (projection) that is received in a mating slot (recess) inside the rear of the grip module. | ¶12 | col. 2:39-44 |
| the multifunction metal part includes control means for locking said barrel in the barrel slide | The frame includes a slide catch lever pin which functions as a control means for locking the barrel in the barrel slide. | ¶12 | col. 3:1-3 |
Identified Points of Contention
- Technical Questions: A primary technical question is whether the accused pistols’ "slide catch lever pin" (Compl. ¶12) performs the function of "locking said barrel in the barrel slide" as claimed. The dispute may focus on whether this component's primary or intended function matches the specific locking function described in the patent.
- Scope Questions: The claim limitation "control means for locking said barrel in the barrel slide" is drafted in means-plus-function format. Its scope is therefore limited to the corresponding structure described in the specification and its equivalents. The patent discloses a "second bridge 33" as the structure performing this function (’301 Patent, col. 3:1-3). A central question for the court will be whether the accused "slide catch lever pin" is structurally equivalent to the patent's disclosed "second bridge."
V. Key Claim Terms for Construction
- The Term: "control means for locking said barrel in the barrel slide"
- Context and Importance: This term is a means-plus-function limitation under 35 U.S.C. § 112(f). Its construction will be critical because infringement requires showing that the accused products contain a structure that is identical or equivalent to the specific structure disclosed in the patent for performing the recited function. The complaint’s allegation that a "slide catch lever pin" meets this limitation (Compl. ¶12) directly sets up a potential dispute over structural equivalence.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The parties may dispute the scope of the function itself. Plaintiff may argue that "locking" should be interpreted broadly to encompass any interaction that secures the barrel relative to the slide during any phase of operation.
- Evidence for a Narrower Interpretation: The structure disclosed in the patent specification that performs this function is the "second bridge 33" (’301 Patent, col. 3:1-3; Fig. 4-6). Defendant will likely argue that the accused "slide catch lever pin" is structurally distinct from the disclosed "bridge" and is therefore not an equivalent, limiting the scope of the claim to exclude the accused products.
VI. Other Allegations
- Indirect Infringement: The prayer for relief requests an injunction against contributory and induced infringement (Compl. ¶B, p. 5), but the complaint body contains no factual allegations to support the knowledge or specific intent required for these claims. The allegations focus exclusively on direct infringement.
- Willful Infringement: The complaint alleges that Defendant’s infringement has been "willful and deliberate, with full knowledge of STEYR's patent rights" (Compl. ¶16). However, the complaint does not plead specific facts to support this assertion, such as evidence of pre-suit notification or copying.
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of structural equivalence under § 112(f): Is the accused pistols’ "slide catch lever pin," a component traditionally associated with holding the slide open, the structural equivalent of the patent’s disclosed "second bridge (33)" for performing the claimed function of "locking said barrel in the barrel slide"? The outcome of this highly technical, fact-intensive inquiry may determine infringement.
- A second key question will be one of functional mapping: Does the accused "slide catch lever pin" actually perform the function of locking the barrel within the slide, as required by the claim, or does it perform a different function? The evidence will need to show a direct correspondence between the operation of the accused component and the specific function recited in the claim.