DCT
1:22-cv-01956
Lasermarx Inc v. Hamskea Archery Solutions LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Lasermarx, Inc. d/b/a Quality Archery Designs, Inc. (Virginia) and QTM, LLC (Virginia)
- Defendant: Hamskea Archery Solutions LLC (Colorado)
- Plaintiff’s Counsel: Talus Law Group LLC; Barclay Damon LLP
- Case Identification: 1:22-cv-01956, D. Colo., 10/28/2022
- Venue Allegations: Venue is alleged to be proper in the District of Colorado because Defendant is organized in Colorado and has its principal place of business within the district.
- Core Dispute: Plaintiff alleges that Defendant’s archery accessory mounting systems, including its C.O.R. Mount and Epsilon Arrow Rest, infringe patents related to a dovetail-style mounting interface for connecting accessories to a bow riser.
- Technical Context: The technology concerns mounting systems for archery accessories, such as arrow rests and sights, which aim to provide a more stable, secure, and easily adjustable connection than traditional bolt-on methods.
- Key Procedural History: The complaint alleges that the parties initiated licensing discussions in the summer of 2021. Plaintiff subsequently provided Defendant with notice of the ’974 Patent on February 7, 2022, and the ’884 Patent on June 16, 2022, following its issuance. These allegations of pre-suit knowledge form the basis for the willfulness claims.
Case Timeline
| Date | Event |
|---|---|
| 2015-08-25 | ’974 Patent Priority Date |
| 2018-11-13 | ’884 Patent Priority Date |
| 2021-06-01 | Licensing discussions initiated (approximated from "Summer 2021") |
| 2021-08-24 | ’974 Patent Issue Date |
| 2022-01-07 | Accused Products launched at trade show |
| 2022-02-07 | Notice letter sent to Defendant regarding ’974 Patent |
| 2022-06-14 | ’884 Patent Issue Date |
| 2022-06-16 | Notice letter sent to Defendant regarding ’884 Patent |
| 2022-08-05 | Defendant served with original complaint |
| 2022-10-28 | First Amended Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,098,974 - "Archery Device and Method," issued August 24, 2021
The Invention Explained
- Problem Addressed: The patent’s background section describes shortcomings with conventional methods for attaching accessories to bows, citing issues such as difficulty of adjustment, unexpected detachment, misalignment, and instability that can impair shooting accuracy (Compl. ¶15; ’974 Patent, col. 1:25–2:3).
- The Patented Solution: The invention describes an archery device, typically integrated into the bow’s riser, featuring a rearward-facing protrusion with a specific dovetail geometry. This dovetail shape is configured to mate with a corresponding feature on a bow accessory, creating a secure and vertically adjustable mounting platform that avoids the instability of older side-mount systems (’974 Patent, Abstract; col. 3:20-35). Figure 5a of the patent illustrates an accessory mount (502) designed to engage with a dovetail-shaped rail (120) on the bow riser (’974 Patent, Fig. 5a).
- Technical Importance: This integrated dovetail approach provides a more stable, repeatable, and easily adjustable interface for critical accessories compared to traditional single-bolt attachments, which were prone to rotation and difficult to fine-tune (’974 Patent, col. 1:52–2:3).
Key Claims at a Glance
- The complaint asserts independent claim 11 and dependent claim 13 (Compl. ¶42).
- Independent Claim 11 recites an archery device comprising:
- a first portion configured to at least partially face in a forward direction toward an archery target;
- a second portion configured to at least partially face in a rearward direction away from the archery target;
- wherein the second portion at least partially comprises a dovetail shape;
- and comprises a protrusion configured to at least partially fit into a space defined by the bow accessory;
- wherein the second portion comprises a first right edge, a first left edge, a second right edge, and a second left edge;
- that define a right slot and a left slot;
- wherein the first right and left edges are separated by a first distance, and the second right and left edges are separated by a second distance that differs from the first distance.
U.S. Patent No. 11,359,884 - "Archery Coupling Assembly and Method," issued June 14, 2022
The Invention Explained
- Problem Addressed: The patent addresses problems with attaching accessories like arrow rests, including the cumbersome nature of screw-based attachments, challenges in fine-tuning their position, and the tendency of some designs to cause wear on arrow shafts or lose their settings over time (Compl. ¶18; ’884 Patent, col. 1:17–51).
- The Patented Solution: The invention is a coupling assembly that includes a mounting portion (e.g., a dovetail rail on a bow) and a separate device (e.g., an arrow rest) that moveably couples to it. The device itself features "engagers" that are arranged to compress the mounting portion to secure it in place. The assembly often includes a vertical adjuster, such as a knob, which allows for precise, repeatable movement of the device along a vertical axis relative to the mounting portion (’884 Patent, Abstract; col. 10:2–11).
- Technical Importance: This assembly facilitates secure, micro-adjustable positioning of an archery accessory on the bow, providing a more robust and user-friendly system than prior art methods that relied on simple friction from a single screw (’884 Patent, col. 1:29–35).
Key Claims at a Glance
- The complaint asserts independent claim 12 and dependent claims 16 and 17 (Compl. ¶51).
- Independent Claim 12 recites an archery coupling assembly comprising:
- a mounting portion configured to be coupled to a body of an archery bow, which extends at least partially along a vertical axis when oriented;
- a device moveably coupled to the mounting portion, comprising a first engager and a second engager;
- wherein the engagers are arranged to at least partially compress the mounting portion;
- wherein the device is configured to be moved along the vertical axis relative to the mounting portion when coupled.
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are Defendant's "C.O.R. Mount Riser Interface," "C.O.R. Universal Adaptor Bracket kit," and "Epsilon Arrow Rest" (Compl. ¶2).
Functionality and Market Context
- The complaint alleges that Defendant’s products combine to form an archery accessory mounting system (Compl. ¶24). The C.O.R. Mount Riser Interface is an adapter that provides a dovetail-shaped rail, which can be attached to a bow riser. The Epsilon Arrow Rest is an accessory designed to attach to this dovetail interface (Compl. ¶¶23-24). The complaint alleges that Defendant designed these products to compete directly with and copy the functionality of Plaintiff's patented "Integrate Mounting System™" standard (Compl. ¶¶10, 33). A product catalog image shows the accused C.O.R. dovetail mount and bracket system (Compl. ¶24, p. 6).
IV. Analysis of Infringement Allegations
’974 Patent Infringement Allegations
| Claim Element (from Independent Claim 11) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first portion configured to at least partially face in a forward direction toward an archery target; and | The accused Product includes a first portion (the front of the bow riser it is attached to) that faces forward toward a target. A supporting photograph shows this orientation. | ¶42, p. 10 | col. 3:36-39 |
| a second portion configured to at least partially face in a rearward direction away from the archery target, | The Product includes a second portion (the C.O.R. mount itself) that faces rearward, away from the target. An annotated image labels this rearward-facing component. | ¶42, p. 10 | col. 3:40-42 |
| wherein: the second portion at least partially comprises a dovetail shape; and | The Product's second portion is alleged to have a dovetail shape, as shown in an annotated close-up photograph highlighting the angled geometry. | ¶42, p. 11 | col. 6:25-26 |
| the second portion comprises a protrusion configured to at least partially fit into a space defined by the bow accessory; | The Product’s second portion is alleged to be a protrusion that fits into a space on the corresponding bow accessory (e.g., the Epsilon Arrow Rest). | ¶42, p. 12 | col. 4:5-8 |
| the second portion comprises a first right edge, a first left edge, a second right edge, and a second left edge; | The complaint identifies four distinct edges on the protrusion of the accused Product, labeling them in a photograph as "First Left Edge," "Second Left Edge," "First Right Edge," and "Second Right Edge." | ¶42, p. 13 | col. 8:39-41 |
| the first right edge and the second right edge define a right slot; | The identified first and second right edges of the Product are alleged to define a "Right Slot," which is outlined in a supporting photograph. | ¶42, p. 14 | col. 8:42-43 |
| the first left edge and the second left edge define a left slot; | The identified first and second left edges of the Product are alleged to define a left slot. | ¶42, p. 14 | col. 8:44-45 |
| the first right edge and the first left edge are separated by a first distance; and | The complaint alleges the first right and left edges are separated by a "First Distance," as indicated in a photograph. | ¶42, p. 15 | col. 8:46-48 |
| the second right edge and the second left edge are separated by a second distance that differs from the first distance. | The complaint alleges the second right and left edges are separated by a second, different distance, consistent with a tapered dovetail shape, and provides a supporting annotated photograph. | ¶42, p. 15 | col. 8:49-52 |
- Identified Points of Contention:
- Scope Questions: Dependent claim 13 requires the infringing "protrusion" to be an "integral part of a rearward facing portion of a bow riser" (Compl. ¶42, p. 16). The accused C.O.R. Mount Riser Interface is a separate adapter component that is bolted onto the riser. The core question for this claim will be whether a component bolted to a riser can satisfy the "integral part" limitation, or if the term requires a single, monolithic construction.
- Technical Questions: The complaint's evidence for claim 13 shows the C.O.R. Mount as an add-on part (Compl. ¶42, p. 18). The factual dispute will center on evidence of how securely and permanently this adapter is affixed, which may influence the "integral part" analysis.
’884 Patent Infringement Allegations
| Claim Element (from Independent Claim 12) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a mounting portion configured to be coupled to a body of an archery bow, wherein the mounting portion, when vertically oriented, extends at least partially along a vertical axis; and | The Product includes a mounting portion (the C.O.R. mount) coupled to the bow body, which extends along a vertical axis as shown in a provided image. | ¶51, p. 21 | col. 5:7-15 |
| a device moveably coupled to the mounting portion, | The Product includes a device (the Epsilon Arrow Rest) that is moveably coupled to the mounting portion. | ¶51, p. 22 | col. 8:14-17 |
| wherein the device comprises: a first engager configured to engage a first part of the mounting portion; and a second engager configured to engage a second part of the mounting portion, | The device is alleged to have a first and second engager that engage different parts of the mounting portion, as depicted in an annotated photograph. | ¶51, p. 22 | col. 8:30-33 |
| wherein the first and second engagers are arranged to at least partially compress the mounting portion, | The complaint alleges that an Allen wrench is used to bring the first and second engagers together, causing them to "compress the mounting portion." A supporting image illustrates this action. | ¶51, p. 23 | col. 9:19-22 |
| wherein the device is configured to be moved, along the vertical axis, relative to the mounting portion when the device is coupled to the mounting portion. | The complaint alleges that when a knob on the device is rotated, the device moves along the vertical axis relative to the mounting portion, providing video frames as evidence. | ¶51, p. 24 | col. 11:7-11 |
- Identified Points of Contention:
- Scope Questions: The interpretation of "compress the mounting portion" will be critical. The question is whether this requires a specific mechanical action where the mounting portion itself is squeezed and flexes, or if it can be met by any clamping force that creates a secure friction fit.
- Technical Questions: The infringement theory relies on the combination of the Epsilon Arrow Rest ("the device") and the C.O.R. Mount ("the mounting portion"). The key factual inquiry will be the precise mechanical interaction between the rest's "engagers" and the C.O.R. Mount's dovetail rail to determine if the interaction constitutes "compression" as contemplated by the patent.
V. Key Claim Terms for Construction
Term 1: "integral part of a ... bow riser" (’974 Patent, Claim 13)
- Context and Importance: This term is potentially dispositive for infringement of dependent claim 13. The accused product is an adapter bolted to the riser, not a feature machined into the riser itself. Practitioners may focus on this term because its construction will determine whether add-on components can meet the limitation.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that "integral" should be interpreted functionally, meaning a component so securely affixed that it functions as if it were one piece with the riser, thereby achieving the patent's stated goal of stability (’974 Patent, col. 4:36-39).
- Evidence for a Narrower Interpretation: The specification consistently depicts the coupling structure as a feature of the riser itself. For example, language states "the bow accessory coupler 108 is configured to attach to the rear edge or rear side 107 of the riser 104" and figures like Fig. 9 show the accessory coupler (108) attached directly to the riser (104) (’974 Patent, col. 6:31-34, Fig. 9). This may support a definition requiring a single, monolithic piece.
Term 2: "compress the mounting portion" (’884 Patent, Claim 12)
- Context and Importance: This term defines the securing mechanism of the claimed coupling assembly. The infringement analysis depends on whether the accused device performs this specific action.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue "compress" should be given its ordinary meaning of pressing together, which could encompass the force a set screw exerts to hold a part in place via friction.
- Evidence for a Narrower Interpretation: The patent describes a specific "positioning clamp assembly" where a fastener draws two clamp portions together to exert a "compression force" on the riser (’884 Patent, col. 9:11-22). This suggests a mechanism that actively squeezes the mounting portion between two opposing engagers, rather than merely pushing against it. The complaint's evidence, showing an Allen wrench bringing engagers together, supports this narrower, active clamping interpretation (Compl. ¶51, p. 23).
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Defendant induces infringement by providing customers with installation instructions that allegedly direct them to perform the claimed steps (Compl. ¶29). It also alleges contributory infringement, asserting that the accused products are especially made for infringing use and lack substantial non-infringing uses (Compl. ¶¶31, 47).
- Willful Infringement: Willfulness is alleged based on Defendant’s purported pre-suit knowledge of the patents. The complaint cites licensing discussions beginning in summer 2021, a notice letter for the ’974 Patent dated February 7, 2022, and a notice letter for the ’884 Patent dated June 16, 2022 (Compl. ¶¶25-27, 45, 53). The complaint further alleges that Defendant purposefully copied Plaintiff's design and failed to obtain an opinion of counsel (Compl. ¶¶39-40).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "integral part of a ... bow riser" from the ’974 Patent, which the specification depicts as a feature of the riser itself, be construed to cover a separate adapter component that is bolted onto the riser, as is the case with the accused C.O.R. Mount?
- A key evidentiary question will be one of functional mechanism: does the accused Epsilon Arrow Rest, when coupled with the C.O.R. Mount, secure itself by "compressing" the mount in the specific manner described in the ’884 Patent, or does it operate through a technically distinct method of attachment that falls outside the claim's scope?