DCT
2:20-cv-05710
Streamlight Inc v. Tractor Supply Co
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Streamlight, Inc. (Delaware)
- Defendant: Tractor Supply Company (Delaware)
- Plaintiff’s Counsel: Quarles & Brady LLP
- Case Identification: 2:20-cv-05710, E.D. Pa., 11/16/2020
- Venue Allegations: Plaintiff alleges venue is proper because Defendant operates numerous regular and established brick-and-mortar store locations within the Eastern District of Pennsylvania and has committed acts of patent infringement in the district, including the sale of the accused products.
- Core Dispute: Plaintiff alleges that Defendant’s Treeline-branded shotgun forend lights infringe a patent related to an improved switch assembly for firearm-mountable lights.
- Technical Context: The technology concerns integrated lighting and forend systems for shotguns, where an ambidextrous, extended switch allows for easier activation in high-stress or low-visibility environments.
- Key Procedural History: The complaint alleges that Plaintiff provides virtual marking for its own products pursuant to 35 U.S.C. § 287, which may serve as a basis for constructive knowledge of the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2018-12-21 | Priority Date for U.S. Patent No. 10,670,251 |
| 2020-06-02 | Issue Date for U.S. Patent No. 10,670,251 |
| 2020-10-22 | Purchase of Accused TSC Treeline Lights |
| 2020-11-16 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,670,251 - "Switch for Firearm-Mountable Light"
- Patent Identification: U.S. Patent No. 10,670,251, "Switch for Firearm-Mountable Light," issued June 2, 2020.
The Invention Explained
- Problem Addressed: The patent's background section notes that on-off switches for existing firearm-mountable lights can be "small and difficult to locate for users, especially in high-stress and/or low-visibility scenarios" (’251 Patent, col. 1:15-18).
- The Patented Solution: The invention is an improved switch assembly for a firearm light that replaces the standard shotgun forend. It features an elongated, depressible bar positioned over multiple, spaced-apart tactile switches (’251 Patent, col. 4:30-41; FIG. 5). This design allows a user to activate the light by pressing anywhere along the extended length of the bar, providing redundant and easy-to-locate activation without needing to shift grip or look at the switch (’251 Patent, col. 4:35-41).
- Technical Importance: The design aims to improve upon prior art switches by providing a more intuitive and reliable activation mechanism for long-gun lights, a critical feature for military, law enforcement, and civilian defensive use (’251 Patent, col. 3:42-44).
Key Claims at a Glance
- The complaint asserts independent Claim 1 (Compl. ¶23).
- The essential elements of Claim 1 include:
- A light assembly with a light source.
- A power source.
- A switch assembly comprising:
- A first tactile switch and a second tactile switch, each having a "trip force rating."
- A "bar" with a top and bottom surface.
- A first "actuating button" between the bar's bottom surface and the first tactile switch.
- A second "actuating button" between the bar's bottom surface and the second tactile switch.
- A configuration wherein depressing the top surface of the bar "anywhere along the length thereof" causes one of the actuating buttons to apply force to its corresponding tactile switch, adjusting a state of the light assembly.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
The accused products are the "TSC Treeline Lights," specifically the "Treeline 900 lumen forend light" in versions for Remington and Mossberg shotguns (Compl. ¶¶2, 11).
Functionality and Market Context
The accused products are shotgun forends with integrated lights designed to replace the original factory forends (Compl. ¶2). The complaint provides images of the products marketed by Defendant and installed on a firearm (Compl. pp. 5-6). The complaint alleges that these products are sold at Defendant's retail stores and through its website (Compl. ¶11; pp. 5-6). The disassembly of a purchased unit, shown in an annotated photograph, reveals an internal switch mechanism with multiple electronic components on a circuit board, activated by a long external button (Compl. p. 8). This photo shows the accused product's internal circuit board with two distinct tactile switches identified (Compl. p. 8).
IV. Analysis of Infringement Allegations
'251 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a light assembly including at least one light source; | The accused TSC Treeline Lights are firearm-mountable lights that include a light source. | ¶¶11, 25 | col. 4:57-65 |
| a power source in electrical connection with the light assembly to supply power to the light assembly; | The accused products are powered by batteries. | ¶25 | col. 4:65 - col. 5:4 |
| a switch assembly, the switch assembly comprising a first tactile switch...a second tactile switch being spaced apart from the first tactile switch... | The complaint provides a photograph of the accused product's disassembled switch assembly, identifying a "first tactile switch" and a "second tactile switch" on a circuit board. | ¶25; p. 8 | col. 9:1-9 |
| a bar, the bar having a length, a top surface, and a bottom surface, | The disassembled product contains a component identified as a "bar" with a "Top surface" and a "Bottom surface." | ¶25; p. 8 | col. 9:10-11 |
| a first actuating button located at least partially between the bottom surface of the bar and the first tactile switch, and a second actuating button... | The disassembled product is shown to have components labeled "A first actuating button" and "A second actuating button" positioned under the "bar." | ¶25; p. 8 | col. 9:12-18 |
| wherein the application of a depressing force to the top surface of the bar anywhere along the length thereof causes the first actuating button to apply the first applied force...and/or the second actuating button to apply the second applied force... | The complaint alleges that the product's structure causes a depressing force on the bar to be transferred through the actuating buttons to the tactile switches. | ¶25 | col. 9:19-26 |
| wherein if at least one of the first tactile switch or the second tactile switch is placed into its respective second state, at least one state of the light assembly is adjusted. | The complaint alleges that pressing the switch assembly activates the light. | ¶25 | col. 9:26-29 |
- Identified Points of Contention:
- Scope Questions: The dispute may turn on whether the internal components of the accused product, as labeled in the complaint's photographs, meet the specific definitions of "bar" and "actuating button" as used in the patent. A defendant might argue that its components, while functionally similar, are structurally different from the specific embodiments disclosed in the patent (e.g., ’251 Patent, FIG. 5).
- Technical Questions: A key factual question will be whether a "depressing force...anywhere along the length" of the accused product's external actuator reliably causes the internal mechanism to function as claimed. Evidence regarding the force transfer mechanics and the "trip force rating" of the accused switches will be central to the infringement analysis.
V. Key Claim Terms for Construction
The Term: "tactile switch"
Context and Importance: Claim 1 requires two distinct "tactile switch" elements, each with a "trip force rating." The definition of this term is critical for determining if the electronic components on the accused product's circuit board (Compl. p. 8) qualify. Practitioners may focus on this term because the patent specification explicitly identifies a commercial example, "TC series tactile dome switches made by Snaptron Inc.," which could be used to argue for a narrow construction (’251 Patent, col. 7:42-44).
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims describe the switch by its function: having a first state below a trip force rating and a second state at or in excess of that rating (e.g., ’251 Patent, col. 9:1-6). This functional language could support a construction covering any switch that provides tactile feedback and meets the force-based criteria.
- Evidence for a Narrower Interpretation: The specification’s reference to a specific commercial product ("Snaptron" dome switches) and the depiction of dome-shaped switches with protruding dimples in the patent figures (e.g., ’251 Patent, FIG. 5, elements 86a-c, 90a-c) could support a narrower construction limited to that type of switch.
The Term: "bar"
Context and Importance: This term is the central element that enables the "press anywhere" functionality of the invention. The infringement allegation hinges on mapping this claim term to the component identified as the "bar" in the accused product (Compl. p. 8).
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent also refers to the structure more generally as a "pressing mechanism" (’251 Patent, col. 8:2-3), suggesting the term "bar" may not be limited to a specific shape or material but could encompass any elongated structure that spans multiple switches to transfer force.
- Evidence for a Narrower Interpretation: The patent figures depict the "bar" (element 70) as a distinct, fairly rigid component press-fit into a rubber boot and containing holes for the actuating buttons (’251 Patent, FIG. 5; col. 6:40-46). A defendant may argue that the term should be limited to a structure with these specific characteristics.
VI. Other Allegations
- Willful Infringement: The complaint alleges willful infringement. The stated bases are: (1) constructive knowledge of the ’251 Patent via Plaintiff's virtual patent marking practices (Compl. ¶¶20, 26); and (2) alleged actual knowledge based on the "striking similarities" in appearance and functionality between Plaintiff's TL-Racker® products and the accused TSC Treeline lights (Compl. ¶26).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction and mapping: Can the terms "bar" and "actuating button", as defined by the patent's specification and figures, be construed to read on the specific internal components of the accused Treeline light? The complaint's annotated photographs present a strong prima facie case, but the precise structural and functional characteristics of these components will be a central point of dispute.
- A key evidentiary question will be one of functional operation: Does the accused product's switch mechanism actually perform the claimed function of activating the light when a "depressing force" is applied "anywhere along the length" of the bar? The analysis will likely require expert testimony and testing to verify the force transfer mechanics and determine if there are any "dead spots" that would contradict the claim language.