Medal Sports Corp v. EastPoint Sports Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Medal Sports Corporation (Taiwan)
  • Defendant: EastPoint Sports, Ltd. (Delaware); Target Corporation (Minnesota)
  • Plaintiff’s Counsel: Stamoulis & Weinblatt LLC; Connor Kudlac Lee PLLC
• Case Identification: 1:20-cv-00899, D. Del., 07/01/2020
• Venue Allegations: Venue is alleged against EastPoint based on its incorporation in Delaware and sales into the district. Venue is alleged against Target based on its operation of three retail stores within Delaware, residency, and sales into the district.
• Core Dispute: Plaintiff alleges that Defendants’ electronic punching bag product infringes a patent related to the internal mounting and placement of force sensors.
• Technical Context: The technology concerns electronic sporting goods, specifically improving the accuracy and durability of sensor-equipped punching bags by altering how the sensors are secured within the apparatus.
• Key Procedural History: Plaintiff alleges it notified Defendant EastPoint of its infringement of the patent-in-suit on or about October 10, 2019, and also sent a copy of the notification letter to Defendant Target. The complaint alleges willful infringement by EastPoint and Target commencing shortly after these notification dates.

Case Timeline

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

U.S. Patent No. 9,027,415 - “Force Sensing Kickboxing Apparatus and Method of Manufacture”

The Invention Explained

• Problem Addressed: The patent describes prior art electronic punching bags as having sensors mounted on a separate inner shell that hangs behind the outer, strikeable shell. With use, this inner shell can stretch, tear, or become misaligned, causing the sensors to no longer line up with the target graphics on the outer shell and reducing detection accuracy (’415 Patent, col. 1:36-50).
• The Patented Solution: The invention eliminates the separate inner shell. Instead, it attaches a "sensor housing" directly to the internally facing side of the main body. This housing creates a small "pocket" that secures the sensor, ensuring it remains properly positioned directly behind the external target area and improving the reliability of strike detection (’415 Patent, Abstract; col. 2:11-17; Fig. 4). This design aims to improve durability and reduce manufacturing costs by using fewer parts (’415 Patent, col. 2:1-5).
• Technical Importance: This design provides a method for integrating sensors into a striking bag in a way that is intended to be more robust and accurate than prior designs that relied on a separate, and potentially misalignable, internal structure (Compl. ¶21).

Key Claims at a Glance

• The complaint asserts independent Claim 1.
• The essential elements of Claim 1 are:
  • A force sensing apparatus comprising: a body including an externally facing first side and an internally facing second side;
  • an electronic device connected to the body and configured to provide information associated with the body;
  • a sensor housing; and a sensor;
  • wherein the sensor housing is attached to a portion of the second side of the body forming a pocket between the sensor housing and the portion of the internally facing second side;
  • wherein the sensor is positioned within the pocket and communicatively coupled to the electronic device, the sensor configured to detect an object contacting a portion of the first side of the body in proximity to the sensor;
  • wherein the sensor housing is configured to cause the sensor to contact the internally facing second side; and
  • wherein the electronic device is configured to count a number of strikes of the body based on data received from the sensor.

III. The Accused Instrumentality

Product Identification

• The "Go Pro Inflatable Electronic Kick Boxing Set," also identified as the "Rec-Tek Pop-Up Power Punch" (Compl. ¶1, ¶31).

Functionality and Market Context

• The Accused Product is an inflatable electronic punching bag marketed as a toy or sporting good (Compl. ¶17, ¶29). A visual of the Accused Product shows an inflatable stand-up bag with light-up targets and a "Power Punch Meter" (Compl. p. 6). The complaint alleges the product contains force sensors that detect and register strikes, and that its internal construction infringes the ’415 Patent (Compl. ¶40, ¶49).
• The product is alleged to be sold through major retailers such as Target and Walmart, as well as directly through Defendant EastPoint’s website (Compl. ¶33, ¶35).

IV. Analysis of Infringement Allegations

The complaint alleges that the Accused Product infringes at least Claim 1 of the ’415 Patent by having a structure that meets every limitation of the claim (Compl. ¶40, ¶49). Although the complaint references claim chart exhibits that were not included in the filing, it provides a narrative mapping of the claim to the product.

’415 Patent Infringement Allegations

• Identified Points of Contention:
  • Technical Questions: A primary question will be whether the internal construction of the Accused Product factually corresponds to the claimed architecture. The complaint does not provide visual evidence of the product's internal components, so infringement will depend on facts established during discovery.
  • Scope Questions: The case may raise the question of whether the Accused Product's internal mounting components meet the definition of a "sensor housing" that forms a "pocket." Further, a dispute may arise over the meaning of "configured to cause the sensor to contact the internally facing second side," particularly if the accused sensor is merely held "adjacent" to the surface rather than in constant contact.

V. Key Claim Terms for Construction

• The Term: "sensor housing"

  • Context and Importance: This term is central to the claimed invention, as the specific method of "housing" the sensor directly on the body's internal surface is the key distinction over the prior art's separate inner shell. The outcome of the case may depend on whether the defendant's internal mounting structure is found to be a "sensor housing."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the housing as a "sheet section that encloses the sensor" (’415 Patent, col. 4:45-46), which could be argued to encompass a wide variety of materials and shapes that perform a covering or enclosing function.
    • Evidence for a Narrower Interpretation: Defendants may argue the term is limited by embodiments showing a discrete piece of plastic sheeting attached at its edges to form a "pocket 402" where the sensor can "float" (’415 Patent, col. 5:38-40, col. 5:60-61; Fig. 4). This could be used to argue that structures that do not form a similar "pocket" are outside the claim's scope.

• The Term: "configured to cause the sensor to contact the internally facing second side"

  • Context and Importance: Practitioners may focus on this term because it presents a potential factual distinction between the claim and the accused device. The difference between "contact" and mere proximity ("adjacent") could be a critical infringement battleground.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation (supporting "contact"): The claim explicitly uses the word "contact." A plaintiff would argue this should be given its plain and ordinary meaning, and that "configured to cause" implies a design that ensures this contact, even if it is not constant.
    • Evidence for a Narrower Interpretation (against "contact"): The specification states the configuration "causes the sensor 206 to be adjacent with the internally facing side 212" (’415 Patent, col. 4:47-48) and that the sensor may "float in a fixed position of the pocket" (’415 Patent, col. 5:60-61). A defendant could argue this language teaches away from required, constant "contact," suggesting the claim requires a specific interaction that may not be present in the accused device.

VI. Other Allegations

• Willful Infringement: The complaint alleges that Defendants' infringement was willful. This allegation is based on alleged pre-suit knowledge of the ’415 Patent, stemming from a notice letter Plaintiff sent to EastPoint and Target (Compl. ¶28). The complaint alleges that Defendants knew of or were willfully blind to their infringement since at least October 23, 2019 (for EastPoint) and November 18, 2019 (for Target), and continued their infringing activities thereafter (Compl. ¶43-45, ¶52-53).

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

1. A central issue will be one of structural correspondence: Does discovery on the internal construction of the "Rec-Tek Pop-Up Power Punch" reveal a "sensor housing" attached to the internal surface of the body to form a "pocket," or does it employ a fundamentally different mounting mechanism that falls outside the claim scope?

2. The case will likely involve a key question of definitional interpretation: Can the claim limitation "configured to cause the sensor to contact the internally facing second side" be met by a design where the sensor is merely held "adjacent" to the surface, as described in the specification, or does it require a more specific and persistent state of physical contact?

3. A key evidentiary question will be what facts support Plaintiff’s willfulness allegations. The court will need to examine the content of the alleged pre-suit notice letters and Defendants' subsequent conduct to determine if their actions rose to the level of "egregious" conduct required for enhanced damages under the Halo standard.