DCT

8:25-cv-02790

CRBN Pickleball LLC v. Vatic Pro LLC

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 8:25-cv-02790, C.D. Cal., 12/17/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant resides in the district, has a regular and established place of business there, and has committed acts of alleged infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s pickleball paddles infringe a patent related to dual-density foam core technology.
  • Technical Context: The lawsuit arises within the rapidly growing and competitive market for high-performance pickleball paddles, where manufacturers engineer advanced materials and core constructions to enhance player performance.
  • Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of its pending patent application on June 30, 2025, and again notified Defendant after the patent issued on November 28, 2025. These notices may be central to the allegations of willful infringement.

Case Timeline

Date Event
2023-08-18 ’827 Patent Priority Date
2025-06-30 Plaintiff allegedly notified Defendant of its pending patent application
2025-11-11 U.S. Patent No. 12,465,827 issues
2025-11-28 Plaintiff allegedly notified Defendant of the issued ’827 Patent
2025-12-17 Complaint filed

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

U.S. Patent No. 12,465,827 - "Paddle Technology"

  • Patent Identification: U.S. Patent No. 12,465,827, "Paddle Technology," issued November 11, 2025 (the "’827 Patent").

The Invention Explained

  • Problem Addressed: The patent’s background section describes the challenge in paddle design of balancing weight, rigidity, and durability. It notes that paddles made of lightweight polymer foams can "excessively deflect, compress, and are not durable," while paddles made of denser polymers are rigid but too heavy to meet tournament requirements (’827 Patent, col. 3:3-10). The conventional solution of a lightweight honeycomb core provides skeletal support but has its own performance trade-offs (’827 Patent, col. 2:50-59).
  • The Patented Solution: The invention proposes a "dual density core" that combines a structural "skeleton" or "frame" made of a higher-density foam with a "filling" made of a lower-density foam or other material that occupies the cells or regions within the frame (’827 Patent, col. 3:20-45; Fig. 2). This composite structure is designed to provide the necessary rigidity and strength from the higher-density frame while keeping the overall weight low by using a lighter filler material, thereby creating a paddle that is both durable and lightweight (’827 Patent, col. 3:15-24).
  • Technical Importance: This dual-density approach allows for precise engineering of a paddle's performance characteristics, including weight distribution and the location of the "sweet spot" (’827 Patent, col. 7:15-28), which are key differentiators in the competitive paddle market (Compl. ¶13).

Key Claims at a Glance

  • The complaint asserts independent claim 1 and dependent claims 4, 8, 9, 10, 11, 12, and 13 (Compl. ¶19).
  • Independent Claim 1 requires:
    • A paddle comprising a core,
    • The core comprises a continuous layer of a first material, which is a high density composite foam comprising expanded polypropylene (EPP) with a density of about 3.5 to 20 pounds per cubic foot,
    • The core has a total weight between 2 and 4 ounces,
    • The core has one or more regions embedded within the continuous layer that lack the first material,
    • These regions are at least partially filled with a second material.
  • The complaint reserves the right to assert additional claims (Compl. p. 6:5-9).

III. The Accused Instrumentality

Product Identification

  • The V-SOL POWER paddle (Compl. ¶12).

Functionality and Market Context

  • The complaint alleges that the V-SOL POWER paddle "implemented the same patented paddle technology claimed in the ’827 Patent" (Compl. ¶14). It further alleges that Defendant promotes the performance benefits derived from these patented features as key selling points to consumers through advertising, product descriptions, and technical specifications (Compl. ¶14). The products are allegedly sold through Defendant's website, third-party online marketplaces, and direct-to-consumer sales channels (Compl. ¶12). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references an infringement chart (Exhibit 2) that was not provided with the filed document (Compl. p. 6:1-2). The complaint’s narrative infringement theory alleges that the V-SOL POWER paddle directly infringes at least claim 1 of the ’827 Patent because it embodies the patented technology (Compl. ¶¶18-19). The complaint asserts that Vatic "has implemented the same patented paddle technology claimed in the ’827 Patent," but does not provide specific, element-by-element details in the body of the complaint mapping the features of the V-SOL POWER paddle to the limitations of the asserted claims (Compl. ¶14).

Identified Points of Contention

  • Scope Questions: A central dispute may concern the proper construction of "continuous layer." The question for the court will be whether this term requires a single, monolithic piece of high-density foam from which regions are removed, or if it can be read more broadly to cover an assembled frame of interconnected high-density foam pieces.
  • Technical Questions: A primary factual question will be establishing the internal construction of the V-SOL POWER paddle. The complaint does not provide evidence (such as from a product teardown) showing that the accused paddle actually contains a dual-density EPP foam core that meets the specific density and weight limitations recited in claim 1.

V. Key Claim Terms for Construction

The Term: "continuous layer"

  • Context and Importance: This term is foundational to the structure of the claimed invention. Whether the accused product's internal frame constitutes a "continuous layer" will be a critical infringement question. Practitioners may focus on this term because Defendant could argue its paddle core is constructed from discrete, non-continuous elements, thereby designing around the claim.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the structure as a "skeleton frame design" (’827 Patent, col. 3:29-30) and depicts it in figures (e.g., Fig. 2) as an interconnected structure that spans the paddle head, which could support an interpretation covering any functionally connected framework.
    • Evidence for a Narrower Interpretation: The claim language "one or more regions embedded within the continuous layer that are lacking the first material" (’827 Patent, col. 9:22-24) could suggest that the "layer" exists first as a solid sheet, and then "regions" are formed within it. This might support a narrower reading that excludes frames assembled from separate pieces.

The Term: "regions embedded within"

  • Context and Importance: This phrase defines the physical relationship between the high-density structural material and the lower-density filler material. The infringement analysis depends on whether the accused paddle's construction meets this "embedded" configuration.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes filling the "cells of frame 50" with the second material, suggesting that any space defined by the frame could be considered an "embedded" region (’827 Patent, col. 3:49-50).
    • Evidence for a Narrower Interpretation: A defendant might argue that "embedded" requires the region to be fully enclosed on all sides by the "continuous layer," which may not be the case if the cells in its frame are open on the faces before the paddle's outer surfaces are applied.

VI. Other Allegations

Indirect Infringement

  • The complaint alleges that Defendant induces infringement by encouraging customers to use the V-SOL POWER paddle for its intended purpose (Compl. ¶28). The complaint also alleges that Defendant knew or should have known that its customers' use of the paddle would result in infringement (Compl. ¶30).

Willful Infringement

  • The willfulness allegation is based on alleged pre-suit and post-suit knowledge of the ’827 Patent. The complaint cites a notice letter sent on June 30, 2025 regarding the then-pending application, and a second notice letter sent on November 28, 2025, after the patent had issued (Compl. ¶16). The complaint further supports its willfulness claim by quoting public statements from Defendant’s founder that allegedly show a dismissive attitude toward patent rights in the pickleball industry (Compl. ¶¶1, 5).

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

  • A central issue will be one of evidentiary proof: What is the actual internal composition and construction of the accused V-SOL POWER paddle? The outcome of the case will depend heavily on whether discovery reveals a dual-density foam core structure that maps onto the specific material, density, and weight limitations of the asserted claims.
  • The case will also turn on a question of claim scope: How will the court construe the term "continuous layer"? A broad construction covering any interconnected skeleton could favor the plaintiff, while a narrow construction requiring a single, monolithic piece of material could favor the defendant.
  • A third key question will address willfulness: Did Defendant’s alleged receipt of pre-issuance and post-issuance notice, combined with its founder’s public statements regarding patents, constitute the type of egregious conduct necessary to support a finding of willful infringement and potential enhanced damages?