DCT
2:20-cv-00345
Really Right Stuff v. Field Optics Research
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Really Right Stuff, LLC (Utah)
- Defendant: Field Optics Research, Inc. (Utah)
- Plaintiff’s Counsel: Strong & Hanni; CHERNOFF VILHAUER LLP
- Case Identification: 2:20-cv-00345, D. Utah, 01/11/2021
- Venue Allegations: Venue is asserted based on the defendant being incorporated in Utah, having its principal place of business in Utah, and maintaining a regular and established place of business within the judicial district.
- Core Dispute: Plaintiff alleges that Defendant’s camera and optics mounting hardware, including quick-release clamps and ball heads, infringes three patents related to quick-release mechanisms, dual-standard clamping systems, and panoramic mounts.
- Technical Context: The technology concerns high-performance mounting systems for photography and sporting optics, where the ability to quickly, securely, and reliably attach equipment to supports like tripods is critical.
- Key Procedural History: The complaint notes that U.S. Patent No. 10,612,718 was the subject of a Certificate of Correction issued by the U.S. Patent and Trademark Office to correct a clerical error in the language of an asserted claim.
Case Timeline
| Date | Event |
|---|---|
| 2003-08-20 | ’172 Patent Priority Date |
| 2004-08-10 | ’172 Patent Issue Date |
| 2005-01-07 | ’337 Patent Priority Date |
| 2017-09-29 | ’718 Patent Priority Date |
| 2020-03-10 | ’337 Patent Issue Date |
| 2020-04-07 | ’718 Patent Issue Date |
| 2020-11-17 | ’718 Patent Certificate of Correction Issued |
| 2021-01-11 | First Amended Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 6,773,172 - "QUICK-RELEASE CLAMP FOR PHOTOGRAPHIC EQUIPMENT" (Issued Aug. 10, 2004)
The Invention Explained
- Problem Addressed: The patent describes conventional methods for mounting photographic equipment to supports like tripods as time-consuming and awkward, particularly screw-based systems. It further notes that existing quick-release clamps that use simple springs can loosen over time, compromising the security of expensive equipment. (’172 Patent, col. 1:11-50).
- The Patented Solution: The invention is a quick-release clamp that uses a cam lever to adjust the width of a channel that grips rails on a camera or lens plate. The key innovation is the use of a "substantially compressible member," such as a series of Belleville washers, interposed between the lever and the clamp's adjustable arm. This member creates a counter-force that, in conjunction with the lever's over-center cam design, provides a secure, detent-like lock that resists loosening from spring pressure or vibration. (’172 Patent, col. 3:21-40; Fig. 6).
- Technical Importance: This design sought to improve upon prior art quick-release clamps by providing a more robust and reliable locking mechanism that actively prevents loosening.
Key Claims at a Glance
- The complaint asserts independent claim 1. (Compl. ¶14).
- Essential elements of claim 1 include:
- A member defining a channel with a first side wall capable of lateral movement with respect to a second side wall.
- A lever capable of causing said lateral movement.
- A substantially compressible member operably interconnected between the lever and the first side wall.
- The complaint does not explicitly reserve the right to assert other claims, but this is standard practice.
U.S. Patent No. 10,612,718 - "DUAL CLAMPING DEVICE" (Issued Apr. 7, 2020)
The Invention Explained
- Problem Addressed: The patent identifies a need for a single clamping device that can accommodate different, incompatible mounting standards commonly used in the photography and firearms industries, namely the Arca-Swiss dovetail system and the Picatinny rail system. Without such a device, users require burdensome adapters or separate clamps for their equipment. (’718 Patent, col. 1:47-56).
- The Patented Solution: The invention is a single, compact clamp assembly featuring two distinct channels at different elevations. An "upper channel" is configured to engage Arca-Swiss style dovetail plates, while a "lower channel" is configured to engage a Picatinny rail. A single adjustment mechanism, such as a threaded stud and knob, simultaneously controls the clamping action of both channels via a shared movable arm. (’718 Patent, col. 3:1-20, col. 4:6-14).
- Technical Importance: The invention provides a unified, versatile mounting solution for users who operate across different equipment ecosystems, eliminating the need for multiple clamps or adapters.
Key Claims at a Glance
- The complaint asserts independent claim 1. (Compl. ¶22).
- Essential elements of claim 1 include:
- A body defining a portion of an upper channel and a lower channel.
- An arm defining a portion of the upper and lower channels, capable of lateral movement.
- The upper channel is at a higher elevation than the lower channel.
- The upper channel is suitable to engage dovetail slots of a plate.
- The lower channel is suitable to engage a rail of a Picatinny rail assembly.
- A stud extending between the body and the arm.
- The complaint notes that a Certificate of Correction was issued for this patent to amend language in claim 1. (Compl. ¶9).
U.S. Patent No. 10,585,337 - "PANORAMIC CAMERA MOUNT" (Issued March 10, 2020)
The Invention Explained
- Technology Synopsis: The patent addresses challenges in taking panoramic photographs by providing a mounting device with a base member and a rotatable clamp member. A first knob is used to selectively lock the panning rotation of the clamp relative to the base, while a second, distinct knob controls the jaws of the clamp itself to secure a camera. This separation of controls is intended to provide a stable platform for precise panoramic image capture. (’337 Patent, Abstract; col. 1:26-38).
Key Claims at a Glance
- Asserted Claims: The complaint asserts independent claim 1. (Compl. ¶30).
- Accused Features: The complaint alleges that the "pan axis" functionality of the Field Optics Research Arca-Type & Picatinny Lever Clamp with Pan Axis infringes the ’337 Patent. (Compl. ¶30).
III. The Accused Instrumentality
Product Identification
- The complaint identifies two accused product lines:
- Field Optics Research Arca-Type & Picatinny Lever Clamp with Pan Axis, Product Serial No. FBT-ASPL. (Compl. ¶¶14, 22, 30).
- Field Optics Research Tactical Ball Head, Product Serial No. FBH-44DT. (Compl. ¶¶14, 22).
Functionality and Market Context
- The complaint describes the accused products as "quick-release clamps," "panoramic camera mounts," and "brackets for photographic equipment." (Compl. ¶¶14, 22, 30). Based on the product names, the "FBT-ASPL" appears to be a dual-standard clamp compatible with both Arca-type plates and Picatinny rails that also includes a rotational "pan axis," features which correspond to the subject matter of the ’718 and ’337 patents. The "FBH-44DT" is identified as a "Tactical Ball Head," which typically incorporates a quick-release clamp for mounting cameras or optics, corresponding to the subject matter of the ’172 and ’718 patents. The complaint does not provide specific technical details about the internal operation or construction of the accused products.
- No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint alleges infringement but does not provide claim charts or specific factual mappings of the accused products to the claim elements. The following summary is based on the language of the asserted claims and the general identification of the accused products.
’172 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| (a) a member defining a channel having a first side wall capable of lateral movement with respect to a second side wall | The complaint alleges the accused clamps (FBT-ASPL, FBH-44DT) contain a channel with a movable jaw for clamping a camera plate. | ¶14 | col. 2:50-54 |
| (b) a lever capable of causing said lateral movement | The complaint alleges the accused clamps utilize a lever to actuate the movable jaw. | ¶14 | col. 3:1-15 |
| (c) a substantially compressible member operably interconnected between said lever and said first side wall | The complaint alleges the accused clamps' lever mechanisms incorporate a compressible element that provides force to secure the clamp. | ¶14 | col. 3:21-30 |
’718 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| (a) a body defining a portion of an upper channel having a first side wall | The complaint alleges the accused clamps (FBT-ASPL, FBH-44DT) have a main body that forms one side of a primary clamping channel. | ¶22 | col. 3:1-5 |
| (b) an arm defining a portion of said upper channel having a second side wall capable of lateral movement... suitable to detachably engage a pair of dovetail slots of said plate | The complaint alleges the clamps have a movable arm that forms the other side of the primary channel, which is configured to engage Arca-type dovetail plates. | ¶22 | col. 3:1-5 |
| (c) said body defining a portion of a lower channel having a third side wall | The complaint, by identifying the FBT-ASPL as an "Arca-Type & Picatinny Lever Clamp," suggests it has a body that also forms part of a second, lower channel for Picatinny rails. | ¶22 | col. 4:6-14 |
| (d) said arm defining a portion of said lower channel having a fourth side wall... suitable to detachably engage a rail of said Picatinny rail assembly | The complaint suggests the same movable arm also forms the other side of the lower channel to clamp a Picatinny rail. | ¶22 | col. 4:6-14 |
| (e) wherein said upper channel is at a higher elevation than said lower channel | The complaint suggests the two channels in the accused clamps are located at different vertical positions on the clamp body. | ¶22 | col. 4:1-5 |
| (g) said arm is slidably engaged with a stud extending between [a] base and said arm | The complaint alleges the movable arm in the accused clamps is operated by a central stud or similar mechanism. | ¶22 | col. 5:21-25 |
Identified Points of Contention
- Evidentiary Questions: A central issue will be evidentiary. The complaint lacks specific factual allegations demonstrating how the accused products work. Discovery will be required to determine if the internal mechanisms of the accused clamps, in fact, possess the specific structures and operational characteristics required by each claim element.
- Technical Questions (’172 Patent): What is the precise nature of the locking mechanism in the accused clamps? Does it employ a "substantially compressible member" that creates the over-center detent force profile described in the patent, or does it use a different mechanical principle to achieve a locked state?
- Scope Questions (’718 Patent): Does the FBH-44DT product, identified as a "Tactical Ball Head," contain both an upper and lower channel for two different mounting standards as required by claim 1? The complaint's allegations for this product may raise questions of technical mismatch.
V. Key Claim Terms for Construction
The Term: "substantially compressible member" ('172 Patent, Claim 1)
- Context and Importance: This term is central to the asserted novelty of the ’172 patent’s locking mechanism. Its definition will determine whether the claim is limited to the specific type of spring disclosed or can cover a wider range of resilient components.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim uses the general term "substantially compressible member" without restriction to a specific type, and later refers to it as a "force generating member." (’172 Patent, col. 3:30-32).
- Evidence for a Narrower Interpretation: The specification's preferred embodiment and detailed description focus heavily on a "series of Belleville washers that together operate as a compression spring" as the locking member. (’172 Patent, col. 3:26-30). A party could argue the claims should be interpreted in light of this specific disclosure.
The Term: "upper channel" and "lower channel" (’718 Patent, Claim 1)
- Context and Importance: The spatial and functional relationship between these two channels defines the core "dual-clamping" feature. The construction will determine what structural arrangements meet the claim requirements.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The terms themselves are general. One might argue any clamp with two distinct recessed clamping areas at different elevations could meet the limitation.
- Evidence for a Narrower Interpretation: The specification and background explicitly link the channels to two different standards: the "upper channel" for Arca-Swiss style dovetails and the "lower channel" for Picatinny rails. (’718 Patent, col. 1:10-15; col. 3:1-20). The patent also describes specific features like "angled upward and inward" walls and a "raised central portion" associated with these channels, which may be used to argue for a more limited scope. (’718 Patent, col. 4:24-30).
VI. Other Allegations
Indirect Infringement
- The complaint alleges that the accused products "are not a staple article or commodity of commerce suitable for substantial non-infringing use, and are especially made or especially adapted for use in an infringement," which are factual allegations that may support a claim for contributory infringement. (Compl. ¶¶14, 22, 30). The complaint does not, however, plead specific facts to support a claim for induced infringement, such as allegations related to user manuals or advertising that instruct on an infringing use.
Willful Infringement
- The complaint alleges that Defendant had knowledge of the patents-in-suit "no later than the date of the original filing of this Complaint" and continued to infringe despite this knowledge. (Compl. ¶¶16, 24, 32). This alleges ongoing, post-suit willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
An Evidentiary Question of Operation: The complaint presents a "bare bones" case, providing product names but no technical details or claim charts. A primary question for the court will be evidentiary: does discovery reveal that the internal mechanics and physical structures of the accused clamps actually function in the specific manner required by the asserted claims of the ’172, ’718, and ’337 patents?
A Definitional Question of Scope: The case may turn on claim construction. For the ’172 patent, a core issue will be whether the term "substantially compressible member" is limited to the disclosed Belleville washers or can be construed more broadly to cover other types of springs or resilient components. For the ’718 patent, a key question will be whether the "upper" and "lower" channels must be configured specifically for the Arca-Swiss and Picatinny standards, respectively, or if the terms can read on other dual-channel configurations.