DCT
1:25-cv-00087
Staccato 2011 LLC v. Oa Defense LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Staccato 2011, LLC (Delaware / Texas)
- Defendant: OA Defense LLC (Delaware / Nevada)
- Plaintiff’s Counsel: Jackson Walker LLP
- Case Identification: 1:25-cv-00087, W.D. Tex., 01/17/2025
- Venue Allegations: Venue is asserted based on Defendant OA Defense conducting business in the district, including through an online dealer locator, and on Plaintiff Staccato maintaining its principal place of business in the district.
- Core Dispute: Plaintiff Staccato seeks a declaratory judgment that its handguns featuring an ambidextrous slide stop do not infringe two of Defendant OA Defense's patents related to firearm mechanisms.
- Technical Context: The technology concerns mechanical improvements for semi-automatic handguns, particularly those based on the 1911-style platform, which represents a significant and enduring segment of the consumer and professional firearms market.
- Key Procedural History: The action was initiated by Staccato following receipt of a letter from OA Defense on January 7, 2025, which alleged infringement of the patents-in-suit and demanded that Staccato cease and desist marketing certain handgun models.
Case Timeline
| Date | Event |
|---|---|
| 2022-07-29 | Earliest Priority Date for ’199 Patent |
| 2022-08-25 | Priority Date for ’483 Patent |
| 2023-12-19 | ’483 Patent Issued |
| 2024-06-11 | ’199 Patent Issued |
| 2025-01-07 | OA Defense Sends Infringement Allegation Letter to Staccato |
| 2025-01-17 | Complaint for Declaratory Judgment Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,846,483 - “Firearm with an Ambidextrous Slide Stop,” issued Dec. 19, 2023
The Invention Explained
- Problem Addressed: The patent’s background section states that traditional 1911-style handguns are not optimized for all users because their slide stop controls are not ambidextrous, creating operational difficulties for left-handed shooters (ʼ483 Patent, col. 1:21-25).
- The Patented Solution: The invention is a two-piece slide stop that provides controls on both the left and right sides of the firearm frame. The two portions are designed to interlock through a specific male-female mating mechanism, which allows them to be securely coupled and move in unison, while also being removable from the frame for disassembly (ʼ483 Patent, Abstract; col. 4:47-53). Figure 5 illustrates the two portions mated together outside of the firearm (ʼ483 Patent, Fig. 5).
- Technical Importance: The design aims to provide truly ambidextrous slide manipulation on a widely popular firearm platform, which can streamline reloads and malfunction clearance for all users, regardless of hand dominance (ʼ483 Patent, col. 2:56-65).
Key Claims at a Glance
- The complaint identifies independent claims 1, 10, and 16 as being at issue (Compl. ¶23).
- Essential elements of representative independent claim 1 include:
- a slide stop attached to a handgun frame, comprising a first portion and a second portion both removably attached to the frame;
- the first portion comprising a first lever, a shaft, and a stopper;
- the second portion comprising a second lever;
- a mating mechanism between the two portions, which includes a male mating mechanism on the first portion and a female mating mechanism on the second portion;
- the male mating mechanism is a protrusion extending from the shaft, and the female mating mechanism is a protrusion extending perpendicularly from the second lever;
- the two portions, when mated, move operably together so that a user can engage the stopper with the slide stop notch using either hand.
U.S. Patent No. 12,007,199 - “Firearm with Various Improvements,” issued Jun. 11, 2024
The Invention Explained
- Problem Addressed: The patent identifies a general need to improve upon the classic 1911 handgun design, stating that certain features of the original are "not optimized" (ʼ199 Patent, col. 1:36-37).
- The Patented Solution: The patent describes a suite of discrete mechanical upgrades to the 1911 platform. These include, among other things, a novel trigger shoe assembly that uses a dovetail-style connection and a set screw for adjustment, a magazine catch retainer plate designed to prevent spring buckling and enable compatibility with different magazine types, an integral beavertail built into the frame, and a modular front sight block that can be attached directly to the frame instead of the slide (ʼ199 Patent, col. 1:42 - col. 2:51; col. 5:31 - 6:25).
- Technical Importance: The collection of claimed improvements seeks to modernize the 1911 platform by enhancing modularity, shooter ergonomics, reliability, and compatibility with a wider array of modern components and accessories (ʼ199 Patent, col. 1:38-41).
Key Claims at a Glance
- The complaint identifies independent claims 1, 10, and 20 as being at issue (Compl. ¶32).
- Essential elements of representative independent claim 10 include:
- a frame, a barrel, and a slide;
- a trigger shoe assembly with a rear channel, a corresponding front tab on a trigger bow, and a vertical set screw for biasing the components into engagement;
- a magazine catch assembly;
- a magazine catch retainer plate positioned between the trigger shoe and the magazine catch, configured to prevent the catch spring from buckling into a trigger cavity;
- a hammer, a mainspring assembly, and a hammer strut connecting them.
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are Plaintiff Staccato’s "handguns with an ambidextrous slide stop" (Compl. ¶2).
Functionality and Market Context
- The complaint does not provide specific technical details on the operation of the accused handguns. Instead, it makes broad assertions that the products do not practice the limitations of the asserted patent claims (Compl. ¶¶23, 32).
- The complaint alleges that OA Defense conducts business within the Western District of Texas through authorized dealers, referencing a screenshot of a "Dealer Locator" map from the Defendant's website as evidence (Compl. ¶10). The allegation that OA Defense's infringement assertions have "placed a cloud over Staccato and its products" suggests Staccato is a notable participant in the market for these types of firearms (Compl. ¶2).
IV. Analysis of Infringement Allegations
The complaint, being an action for declaratory judgment of non-infringement, does not affirmatively allege how the accused products work. It instead asserts that Staccato's products do not meet specific limitations of the patents-in-suit.
’483 Patent Infringement Allegations
The complaint alleges that Staccato’s products do not practice various “slide stop” limitations of independent claims 1, 10, and 16 (Compl. ¶23). The table below outlines the specific limitations from representative claim 1 that are in dispute.
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a slide stop attached to frame, wherein the slide stop is configured to move in and out of engagement with the slide for locking and releasing the slide | The complaint asserts this limitation is not practiced by Staccato’s products. | ¶23 | col. 10:43-46 |
| wherein the slide stop comprises a first portion and a second portion both removably attached to the frame, wherein the first portion is on the first side of the frame and the second portion is on the second side of the frame | The complaint asserts this limitation is not practiced by Staccato’s products. | ¶23 | col. 10:47-51 |
| wherein the first portion comprises a first lever with a proximal end and a distal end, a shaft extending perpendicularly from the distal end of the first lever, and a stopper extending from the proximal end of the first lever... | The complaint asserts this limitation is not practiced by Staccato’s products. | ¶23 | col. 10:52-59 |
| wherein the second portion comprises a second lever | The complaint asserts this limitation is not practiced by Staccato’s products. | ¶23 | col. 10:60 |
| wherein the slide stop further comprises a mating mechanism between the first portion and the second portion, wherein the mating mechanism further comprises a male mating mechanism on the first portion and a female mating mechanism on the second portion | The complaint asserts this limitation is not practiced by Staccato’s products. | ¶23 | col. 10:61-66 |
| wherein the male mating mechanism is a protrusion extending from the shaft, and the female mating mechanism is a protrusion extending perpendicularly from the second lever | The complaint asserts this limitation is not practiced by Staccato’s products. | ¶23 | col. 11:1-4 |
| wherein the first portion and the second portion, upon mating with each other via the mating mechanism move operably with one another such that engaging the stopper with the slide stop notch is achievable with either hand of a user | The complaint asserts this limitation is not practiced by Staccato’s products. | ¶23 | col. 11:5-9 |
- Identified Points of Contention:
- Scope Questions: A primary issue will be the interpretation of "removably attached to the frame" as applied to both portions of the slide stop. The dispute may turn on the specific method of attachment and removal in the accused products compared to the patent's teachings.
- Technical Questions: The infringement analysis will likely focus on the precise geometry of Staccato's slide stop connection. A key question is whether the accused products utilize a "mating mechanism" that meets the claim's specific definition of a "protrusion extending from the shaft" (male part) and a "protrusion extending perpendicularly from the second lever" (female part).
’199 Patent Infringement Allegations
The complaint does not provide sufficient detail for a claim-chart analysis. It states that Staccato’s products do not practice limitations of independent claims 1, 10, and 20 related to the "trigger shoe assembly," "magazine catch" / "magazine retainer plate," "mainspring assembly" / "retention clip," "slide stop," "relief" / "barrel lug," and/or "pin and pin connector" (Compl. ¶32). The lack of specificity suggests the dispute over the ’199 Patent will involve a component-by-component factual investigation across numerous distinct mechanical systems within the accused firearms.
V. Key Claim Terms for Construction
For the ’483 Patent:
The Term: "removably attached to the frame" (Claim 1)
Context and Importance: This term applies to both the first and second portions of the slide stop. The question of infringement may depend on whether the accused slide stop components are attached to the frame in a manner that qualifies as "removable" under the proper construction of the claim. Practitioners may focus on this term because the specific method of assembly and disassembly is a core aspect of the invention.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The plain meaning of "removably attached" suggests any attachment that can be undone without destroying the component. The claims do not specify that tools cannot be used.
- Evidence for a Narrower Interpretation: The specification describes an embodiment where the two portions are simply uncoupled from each other and the frame (ʼ483 Patent, col. 4:35-37). Figure 3B depicts the two portions separated from the frame, potentially implying a tool-less removal process that could be argued to limit the scope of the term.
The Term: "mating mechanism" (Claim 1)
Context and Importance: Claim 1 defines this term with a high degree of structural specificity, requiring a male protrusion from the shaft and a female protrusion from the second lever. A determination of infringement will depend on a direct structural comparison. Practitioners may focus on this term as it appears to be a primary point of novelty and a significant potential distinction between the patented invention and accused products.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that minor variations in the shape or angle of the protrusions still fall within the claim's scope, as long as they perform the same interlocking function.
- Evidence for a Narrower Interpretation: The claim language itself is highly limiting. The specification further states the male mating mechanism "can be a protrusion or projection... without any recess" (ʼ483 Patent, col. 4:50-52). This explicit description could be used to argue that any interlocking mechanism that does not meet this precise geometric definition does not infringe.
VI. Other Allegations
- Indirect Infringement: Staccato seeks a declaratory judgment that it has not contributed to or induced infringement of either patent (Compl. ¶¶21-22, 30-31). The complaint does not detail the specific factual allegations made by OA Defense that would support a claim of indirect infringement.
- Willful Infringement: Staccato seeks a declaration of non-willful infringement (Compl. p. 7, ¶A). The complaint acknowledges that OA Defense provided pre-suit notice of the patents via its letter of January 7, 2025, which would establish the knowledge element for a potential claim of post-suit willful infringement by the patentee (Compl. ¶13).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of structural correspondence: does the ambidextrous slide stop in Staccato's handguns meet the specific structural requirements of the '483 patent's claims, particularly the limitations defining how the two portions are "removably attached" to the frame and interlock via the precisely described male and female "mating mechanism"?
- A second central question will be one of component-level infringement: for the '199 patent, which covers a diverse set of firearm improvements, the case will depend on a broad factual inquiry into whether any of the multiple, distinct sub-assemblies in Staccato's products—from the trigger assembly to the magazine catch to the mainspring housing—practice the specific combinations of features recited in the asserted claims.