Fatboy Tripods LLC v. Guangdong Laitu Imaging Technology Co Ltd dba

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: FatBoy Tripods, LLC (Nebraska)
  • Defendant: Guangdong Laitu Imaging Technology Co., Ltd d/b/a Leofoto (China) and Super Photo Gear, LLC d/b/a Leofoto USA and Leofoto Outdoors (Louisiana)
  • Plaintiff’s Counsel: McDonnell Boehnen Hulbert & Berghoff LLP; MT2 Law Group
• Case Identification: 2:26-cv-00039, E.D. Tex., 01/21/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas based on Defendants' transaction of business in the district, including sales through interactive websites accessible to customers in the district and sales through major online retailers like Amazon and Walmart that ship to the district.
• Core Dispute: Plaintiff alleges that Defendants’ adjustable clamping tripod heads infringe a patent related to a ball head leveling base with a quick-release mounting device.
• Technical Context: The technology at issue involves tripod mounting systems designed to securely and adjustably hold equipment, such as high-end cameras or firearms equipped with accessory rails.
• Key Procedural History: The complaint notes that the patent-in-suit was assigned from the inventors to an Iowa entity (FBT) in 2023 and subsequently assigned to the Nebraska-based Plaintiff entity in December 2025. Plaintiff also alleges sending a notice letter to Defendants regarding the alleged infringement approximately one month before filing the lawsuit.

Case Timeline

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

U.S. Patent No. 12,297,953 - "Adjustable Clamping Device and Leveling Base with Multidirectional Adjustment"

Issued May 13, 2025 (’953 Patent).

The Invention Explained

• Problem Addressed: The patent’s background section identifies a need for an improved tripod clamping device that is straightforward to use while reducing the risk of equipment, such as a firearm mounted on a Picatinny rail, sliding within the clamp or losing "lockup during articulation" (’953 Patent, col. 2:5-10). It also notes that traditional leveling bases can be "cumbersome" to operate (’953 Patent, col. 1:50-51).
• The Patented Solution: The invention is a tripod head that combines a ball joint for multidirectional movement with a specific adjustable clamping mechanism for securing equipment (’953 Patent, Abstract). The clamp uses a fixed wall and a moveable wall to create a channel for an accessory rail. A key feature is a lever-operated cam system that allows a user to quickly lock or unlock the clamp, combined with a separate rotatable knob that allows for fine adjustment of the clamping width (’953 Patent, col. 7:1-27; Fig. 10). This dual-control system is designed to provide both rapid release and precise, secure gripping.
• Technical Importance: The described solution aims to provide a mounting system that is both intuitive for rapid adjustments and robust enough to securely hold valuable or sensitive equipment during repositioning (’953 Patent, col. 1:51-56).

Key Claims at a Glance

• The complaint asserts independent claim 1 and dependent claims 2-3 and 9-14 (’953 Patent, col. 8:46 - col. 9:30; Compl. ¶31).
• Independent Claim 1 recites an adjustable clamping device with the following essential elements:
  • a base;
  • a ball coupled to and extending vertically from the base;
  • a housing with a cavity to receive the ball, allowing rotation;
  • a locking member to selectively inhibit the housing's rotation; and
  • a mounting structure on the housing, which itself comprises:
    • a first wall;
    • a second wall moveable with respect to the first;
    • a channel between the walls;
    • an elongated rod with a first and second end; and
    • a lever coupled to the rod's second end, including a "cam portion that rotates about a pivot axis to contact the second wall" to move between locked and unlocked positions.
• The complaint reserves the right to assert additional claims (’953 Patent, Compl. ¶31).

III. The Accused Instrumentality

Product Identification

The complaint identifies the "Leofoto MG-40X" and "MA-40X" model lines as the Accused Products (Compl. ¶31).

Functionality and Market Context

The complaint alleges these products are adjustable clamping devices used with tripods for photographic equipment and firearms (Compl. ¶23). The infringement allegations focus on the products' mechanical structure, which includes a ball head for positioning and a top-mounted clamp for securing equipment (Compl. ¶32). A product image included in the complaint shows the Leofoto MG-40X, which features a large primary knob for locking the ball joint and a smaller, lever-actuated clamp on its top surface (Compl. p. 8). The complaint alleges Defendants are direct competitors who market and sell these devices to improve a user's experience in photography and shooting sports (Compl. ¶23, ¶24).

IV. Analysis of Infringement Allegations

The complaint provides a detailed, image-based claim chart mapping elements of the Leofoto MG-40X to the limitations of claim 1 of the ’953 Patent (Compl. ¶32).

’953 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: The complaint's allegations appear to map the accused product's structure directly onto the claim elements. A potential point of contention could arise over whether the accused device contains every sub-element of the claimed "mounting structure" as recited.
• Technical Questions: A central question may be whether the internal mechanism of the accused product's lever operates as a "cam portion that rotates about a pivot axis to contact the second wall" in the manner required by the claim. The complaint’s visual evidence shows the external lever and alleges the internal function, but the precise mechanical interaction will be a key factual question requiring inspection of the accused device.

V. Key Claim Terms for Construction

• The Term: "a cam portion that rotates about a pivot axis to contact the second wall"
• Context and Importance: This term is critical as it defines the specific mechanical action of the quick-release lever, a core feature of the claimed invention. The infringement analysis will depend on whether the accused product's lever mechanism functions in this precise way. Practitioners may focus on this term because small differences in mechanical linkages or force application could distinguish the accused product from the claimed structure.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself does not specify the shape or material of the "cam portion," only its function: rotating on an axis to contact the movable wall and thereby transition between locked and unlocked states. Plaintiff may argue any structure that achieves this function falls within the claim's scope.
  • Evidence for a Narrower Interpretation: The specification describes an embodiment where the cam portion has an "asymmetrical shape about the pivot axis" to achieve its locking function (’953 Patent, col. 7:17-18). Defendant may argue that the term should be limited to the specific asymmetrical cam structures depicted in the patent's figures (e.g., Fig. 11, element 230), rather than covering any and all lever-based locking mechanisms.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement to infringe based on Defendants' promotion, advertising, instruction manuals, and product packaging, which allegedly instruct customers on how to use the products in an infringing manner (Compl. ¶33). It also pleads contributory infringement, alleging the Accused Products are "especially made for use in a manner that infringes" and have "no substantial non-infringing uses" (Compl. ¶34).
• Willful Infringement: Willfulness is alleged based on Defendants' continued infringement after receiving a notice letter from Plaintiff's counsel dated December 12, 2025, which allegedly provided "full knowledge of the '953 Patent and Plaintiff's patent rights" (Compl. ¶35).

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

The resolution of this dispute may turn on two central questions for the court:

1. A question of mechanical operation: Does the internal mechanism of the accused Leofoto products operate with a "cam portion that rotates about a pivot axis," as claimed, or does it employ a different mechanical linkage to translate the lever's motion into clamping force? The case may depend on a detailed engineering analysis of how the accused lever contacts and moves the second wall.
2. An evidentiary question of structure: While the complaint's annotated photographs suggest a structural correspondence, will a physical teardown and expert inspection of the accused products confirm the presence and arrangement of every claimed element, including the "elongated rod" and its specific connections to both the lever and an adjustment member, as required by the full patent claim set?