DCT

1:24-cv-00076

Tethrd LLC v. Cruzr Saddles LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: Tethrd, LLC v. Cruzr Saddles LLC, 1:24-cv-00076, M.D. Tenn., 12/03/2024
  • Venue Allegations: Venue is alleged to be proper as the Defendant has a regular and established place of business in the judicial district and has committed the alleged acts of infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendant's saddle-hunting rope bridges and associated saddles infringe a patent related to a specialized bridge rope assembly for safety harnesses.
  • Technical Context: The technology concerns safety equipment for "saddle hunting," where a hunter uses a fabric saddle and rope system to hunt from an elevated position in a tree, requiring lightweight, strong, and reliable components.
  • Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of infringement of the patent-in-suit and related intellectual property via letters in July 2020, September 2023, and June 2024. The complaint also notes that the patent, as originally issued, contained a typographical error ("min body" instead of "main body") that was subsequently corrected by the USPTO through a Certificate of Correction.

Case Timeline

Date Event
2020-01-07 '175 Patent Priority Date
2020-07-23 Plaintiff sent notice letter to Defendant regarding related patent application
2023-09-05 Plaintiff sent notice letter to Defendant regarding related '556 Patent
2024-04-23 U.S. Patent No. 11,964,175 issues
2024-06-03 Plaintiff sent notice letter to Defendant regarding '175 Patent
2024-10-11 Plaintiff submitted Request for Certificate of Correction for '175 Patent
2024-10-12 Original Complaint filed
2024-11-12 USPTO issued Certificate of Correction for '175 Patent
2024-12-03 First Amended and Supplemental Complaint filed

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

U.S. Patent No. 11,964,175 - "Bridge Rope Assembly"

  • Issued: April 23, 2024

The Invention Explained

  • Problem Addressed: The patent's background describes a challenge in using modern, high-strength rope materials like ultra-high-molecular-weight polyethylene (UHMWPE) for safety harnesses '175 Patent, col. 4:5-9 While these materials are strong and light, they have a very low coefficient of friction, which makes it difficult to form secure, non-slipping loops and knots that are critical for safety '175 Patent, col. 1:41-48
  • The Patented Solution: The invention claims a specific method of constructing a rope assembly to overcome this problem. It involves creating a main rope body where one end portion of the rope is passed through the hollow core of the other portion, creating a double-layered section '175 Patent, col. 3:13-21 This "buried" construction significantly increases the rope's thickness and internal friction, allowing the low-friction UHMWPE material to be used safely in a harness bridge rope '175 Patent, col. 3:15-19 This assembly includes a spliced eye loop at one end and an adjustable friction hitch to connect to a harness '175 Patent, abstract
  • Technical Importance: This design allows for the creation of hunting saddle bridges that are both ultralight and exceptionally strong, improving safety and performance over equipment made from conventional materials '175 Patent, col. 1:53-57

Key Claims at a Glance

  • The complaint asserts independent claim 1 '175 Patent, col. 6:7-21 Compl. ¶31
  • The essential elements of Claim 1 are:
    • A bridge rope assembly for coupling a tree rope to a harness.
    • A main body made of a rope with a first and second end.
    • A splice in the main body forming an eye loop for engaging a first bridge loop on the harness.
    • The main body has a first portion (with the first end) and a second portion (with the second end).
    • The first portion extends through the second portion, positioning the first end inside the second portion and adjacent to the second end.
    • A friction hitch positioned on the main body.
    • The friction hitch is configured to engage a second bridge loop on the harness.
    • The friction hitch comprises a closed loop.

III. The Accused Instrumentality

Product Identification

  • The "Cruzr Products," which include the Cruzr XC saddle, Archon saddle, and the "Adjustable Amsteel-Blue Bridge" Compl. ¶26

Functionality and Market Context

  • The accused products are components for a saddle-hunting system sold as direct competitors to the Plaintiff's products Compl. ¶10 The core accused component is the "Adjustable Amsteel-Blue Bridge," which is a rope assembly used to connect the two sides of the hunting saddle harness Compl. ¶33 Compl. ¶34 An image in the complaint's exhibits shows a hunter using the accused Cruzr XC saddle system, illustrating how the bridge supports the user's weight Compl. Ex. F, p. 3 The complaint alleges this bridge "features a spliced eye on one end," attaches to saddle loops using a "Prusik knot," and is made of "Amsteel," a brand of UHMWPE rope Compl. ¶33 Compl. ¶34

IV. Analysis of Infringement Allegations

Claim Chart Summary

  • The complaint alleges that the Cruzr Products, which incorporate the "Adjustable Amsteel-Blue Bridge," meet every element of at least Claim 1 of the '175 Patent Compl. ¶¶30-31 The infringement theory is detailed in preliminary claim charts attached as an exhibit Compl. Ex. F

'175 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A bridge rope assembly configured to couple together a tree rope to a first bridge loop and a second bridge loop on a harness... The accused "Adjustable Amsteel-Blue Bridge" is a tree saddle bridge that attaches to the bridge loops on a saddle harness. ¶34 col. 2:50-54
a main body comprising a rope having a first end and a second end... The accused bridge is comprised of a rope with two ends. ¶33 col. 2:57-58
the main body having a splice therein to form an eye loop in the main body, the eye loop being configured to engage the first bridge loop... The accused bridge "features a spliced eye on one end" which is shown in product photos engaging one of the saddle's bridge loops. ¶33 col. 2:59-62
the main body comprising a first portion including the first end and a second portion including the second end, the first portion extending through the second portion of the main body such that the first end is positioned within the second portion adjacent to the second end... The complaint incorporates by reference a claim chart showing an image of the accused product's rope construction, which allegedly has one portion of the rope buried inside the other portion. ¶31 col. 3:11-21
a friction hitch being positioned on the main body... the friction hitch being configured to engage the second bridge loop... the friction hitch comprising a closed loop. The accused bridge uses a "Prusik knot" formed from a "continuous loop of 5/32 Amsteel" to attach to the other bridge loop, which functions as the claimed friction hitch. A product photo shows this knot on the main rope. ¶34 col. 4:41-47

Identified Points of Contention

  • Scope Questions: A central dispute may arise over the construction of the phrase "the first portion extending through the second portion of the main body such that the first end is positioned ... adjacent to the second end." The case may turn on whether the internal construction of the accused "Adjustable Amsteel-Blue Bridge" satisfies this specific structural and positional requirement, particularly the meaning of "adjacent."
  • Technical Questions: While the complaint alleges the accused bridge uses a "Prusik knot" as a friction hitch Compl. ¶34, a technical question for the court will be whether the specific knotting and rope configuration in the accused device performs the function in the same way as described by the claim. An evidentiary question will be whether the accused product's internal rope structure, specifically the "buried" portion, is factually consistent with the patent's claims, as this is not visible from the exterior. The complaint provides a YouTube video still allegedly depicting this internal structure Compl. Ex. F, p. 6

V. Key Claim Terms for Construction

  • The Term: "the first portion extending through the second portion of the main body such that the first end is positioned within the second portion adjacent to the second end"
  • Context and Importance: This term describes the core inventive concept of burying one part of the rope inside another to increase friction. Practitioners may focus on this term because the infringement analysis will likely depend on how far the "first portion" extends and the required proximity of the two ends under the definition of "adjacent."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The plaintiff may argue that "adjacent" does not require the ends to be touching, pointing to specification language that gives a dimensional range, such as "less than 2.0 inches from the second end" '175 Patent, col. 3:23-25, suggesting it is not a rigid point but a general area.
    • Evidence for a Narrower Interpretation: The defendant may argue for a more restrictive definition, pointing to language in the abstract stating, "A distance between the first and second ends is less than 2.0 inches" '175 Patent, abstract and an embodiment where the ends are made "flush with each other" '175 Patent, col. 3:48-49, suggesting a very close or touching relationship is required.

VI. Other Allegations

Indirect Infringement

  • The complaint focuses on direct infringement and does not provide sufficient detail for analysis of indirect infringement. It alleges Defendant makes, uses, and sells the infringing products but does not detail facts supporting active inducement of third parties Compl. ¶29

Willful Infringement

  • The complaint strongly alleges willful infringement. It claims Defendant had pre-suit knowledge of its infringement based on a series of notice letters sent in 2020, 2023, and 2024 concerning the patent-in-suit and related applications (Compl. ¶24; Compl. ¶25; Compl. ¶26). The complaint alleges that Defendant's continued sales after receiving these notices were "willful and deliberate" and constitute "egregious infringement behavior" warranting enhanced damages Compl. ¶36 Compl. ¶39

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

  • A core issue will be one of structural infringement: Does the internal construction of the accused "Adjustable Amsteel-Blue Bridge" meet the specific claim requirement of a "first portion extending through the second portion" with its end "positioned... adjacent to the second end"? The resolution will depend on the court's construction of "adjacent" and factual evidence regarding the accused product's composition.
  • A second key issue, particularly relevant to damages, will be willfulness: Does the alleged history of notice letters, dating back years before the complaint was filed, establish that the Defendant acted with the deliberate or egregious disregard for the Plaintiff's patent rights necessary to support an award of enhanced damages?
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