DCT
1:25-cv-00323
Riddell Inc v. Certor Sports LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Riddell, Inc. (Illinois) and Bell Sports, Inc. (California)
- Defendant: Certor Sports, LLC (Delaware)
- Plaintiff’s Counsel: Richards, Layton & Finger, P.A.
- Case Identification: 1:25-cv-00323, D. Del., 06/13/2025
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant Certor is a Delaware corporation and therefore resides in the district.
- Core Dispute: Plaintiff alleges that Defendant’s Schutt- and VICIS-brand football helmets infringe four U.S. patents related to helmet shell design, face guard mounting, and multi-layer liner construction.
- Technical Context: The technology domain is protective athletic helmets, a market where innovation is driven by efforts to enhance player safety through improved impact absorption, fit, and integrated design.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of infringement for all four patents-in-suit via letters with preliminary claim charts on April 20, 2023, and July 7, 2023, establishing a basis for alleged willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2002-05-01 | Priority Date for U.S. Patent No. 10,932,514 |
| 2013-02-12 | Priority Date for U.S. Patent No. 10,506,841 |
| 2013-12-06 | Priority Date for U.S. Patent Nos. 11,291,263 and 10,362,829 |
| 2019-07-30 | U.S. Patent No. 10,362,829 Issued |
| 2019-12-17 | U.S. Patent No. 10,506,841 Issued |
| 2021-03-02 | U.S. Patent No. 10,932,514 Issued |
| 2022-04-05 | U.S. Patent No. 11,291,263 Issued |
| 2023-04-20 | First pre-suit notice of infringement alleged |
| 2023-07-07 | Second pre-suit notice of infringement alleged |
| 2025-06-13 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,506,841 - “Football Helmet with Recessed Face Guard Mounting Areas”, issued December 17, 2019
The Invention Explained
- Problem Addressed: The patent’s background section describes conventional football helmets where the face guard is secured to the external surface of the shell, which increases the helmet’s frontal profile and can be “visually dominant and unappealing” (’841 Patent, col. 1:47-53).
- The Patented Solution: The invention provides a helmet shell with recessed mounting areas into which the face guard connectors are fastened, creating a “low-profile mounting configuration” and a “streamlined frontal appearance” (’841 Patent, col. 2:8-12). This design allows the width of the attached face guard to more closely correspond to the width of the helmet shell itself, as illustrated by comparing the inventive helmet (FIG. 11A) to the prior art (FIG. 12A).
- Technical Importance: This integrated design approach reduces the helmet’s overall profile, which may alter its aesthetic and performance characteristics during use and upon impact (’841 Patent, col. 3:5-10).
Key Claims at a Glance
- The complaint asserts independent claim 22 (as corrected by a Certificate of Correction) (Compl. ¶31).
- The essential elements of claim 22 are:
- A football helmet comprising a one-piece shell that defines a frontal opening.
- A "recessed face guard attachment region" that resides inward of the adjacent outer shell surface and is defined by an arrangement of "three linear wall segments" that form a "U-shaped area".
- A face guard with an upper peripheral mounting portion.
- A connector bracket that secures the face guard’s mounting portion to the recessed region.
- A specific secured position wherein: (i) the face guard’s exterior surface is external to the adjacent shell surface, (ii) part of the connector bracket’s inner surface is inward of the adjacent shell surface, and (iii) another part of the connector bracket’s inner surface is offset from the recessed region’s outer surface.
U.S. Patent No. 10,932,514 - “Protective Sports Helmet”, issued March 2, 2021
The Invention Explained
- Problem Addressed: The patent background discusses challenges with conventional helmets, including the irritation caused by repeated frictional contact with a player's ears when putting on or removing the helmet, and the general desire to reduce helmet weight (’514 Patent, col. 2:1-9).
- The Patented Solution: The patent describes a helmet shell with a unique side-region geometry comprising two distinct, non-circular openings: a first opening for the ear and a second opening positioned rearward of the first (’514 Patent, Abstract). A defining characteristic of the invention is that “at least a substantial extent of the top edge of the first non-circular opening is aligned with the top edge of the second non-circular opening” (’514 Patent, claim 20). FIG. 2A illustrates this alignment between the main ear opening (112) and the rearward opening (112’).
- Technical Importance: This specific configuration of openings and the structural strip between them defines a novel aesthetic and structural approach to the helmet shell’s side wall, potentially affecting ventilation, weight, and structural integrity (’514 Patent, col. 10:19-27).
Key Claims at a Glance
- The complaint asserts independent claim 20 (as corrected by a Certificate of Correction) (Compl. ¶42).
- The essential elements of claim 20 are:
- A protective sports helmet comprising a one-piece plastic shell with front, crown, rear, and two side regions.
- Each side region has an arrangement of openings comprising:
- A "first non-circular opening" configured to overlie an ear, defined by edge segments including a "top edge" and a "rear edge".
- A "second non-circular opening" positioned rearward of the first, defined by edge segments including a "top edge" and a "front edge".
- The key limitation that "at least a substantial extent of the top edge of the first non-circular opening is aligned with the top edge of the second non-circular opening".
U.S. Patent No. 11,291,263 - “Multi-layer Helmet and Method for Making the Same”
- Patent Identification: “Multi-layer Helmet and Method for Making the Same,” issued April 5, 2022 (Compl. ¶47).
- Technology Synopsis: The patent addresses the limitations of conventional single-layer helmet liners by proposing a multi-layer liner assembly (an inner-layer and an outer-layer) designed to permit relative rotational movement between the layers upon impact (’263 Patent, col. 1:24-42, claim 1). The invention specifies distinct densities for the layers and varying thickness of the outer-layer in different regions of the helmet.
- Asserted Claims: Independent claim 1 (Compl. ¶54).
- Accused Features: The complaint accuses the multi-layer liner systems in the VICIS Zero2 Helmets and Schutt F7 2.0 Helmets (Compl. ¶53).
U.S. Patent No. 10,362,829 - “Multi-Layer Helmet and Method for Making the Same”
- Patent Identification: “Multi-Layer Helmet and Method for Making the Same,” issued July 30, 2019 (Compl. ¶59).
- Technology Synopsis: This patent, related to the ’263 patent, also describes a multi-layer liner assembly (inner, middle, and outer layers) within a flexible outer shell that permits relative rotational movement between the layers to manage impact forces (’829 Patent, Abstract). The invention specifies density and thickness relationships, requiring the middle-layer to have a greater density than the inner and outer layers.
- Asserted Claims: Independent claim 16 (Compl. ¶66).
- Accused Features: The complaint accuses the VICIS Zero2 Helmets, alleging infringement via their flexible outer shell and multi-layer liner assembly (Compl. ¶65).
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are numerous models of football helmets sold under Defendant’s “Schutt” and “VICIS” brands, including the VICIS Zero2 line, the Schutt F7 2.0 line, the Schutt F7 line, and the Schutt Vengeance line (Compl. ¶¶19, 21-23).
Functionality and Market Context
- The complaint alleges that Defendant’s helmets incorporate technologies that Plaintiffs innovated and patented (Compl. ¶17). The VICIS Zero2 helmet is described as featuring a “Deformable Outer Shell” and a “VICIS RFLX 2.0” impact absorption system composed of buckling column structures (Compl. p. 8). The complaint includes a marketing image from Defendant describing the VICIS RFLX 2.0 system as leveraging "buckling structures" with interconnected columns (Compl. p. 8). Similarly, the Schutt F7 2.0 helmet is alleged to use a “RFLX-S impact layer,” which is described as a “proprietary buckling layer” (Compl. p. 11).
- The complaint positions these products as direct competitors that have copied Plaintiff’s successful innovations to compete in the market for protective athletic equipment (Compl. ¶17). An image provided in the complaint highlights the position-specific protection offered by the VICIS ZERO2 QB helmet, which may relate to claims concerning variable layer thicknesses (Compl. p. 10).
IV. Analysis of Infringement Allegations
The complaint incorporates by reference preliminary claim charts that were not attached as exhibits (Compl. ¶¶32, 43, 55, 67). The following infringement summary for the lead patents is based on the complaint’s narrative allegations, product descriptions, and visual evidence.
’841 Patent Infringement Allegations
| Claim Element (from Independent Claim 22) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a recessed face guard attachment region that resides inward of an adjacent first portion of an outer shell surface... defined by an arrangement of three linear wall segments that are formed in the shell and define a U-shaped area | The accused Schutt F7 2.0 helmets feature a region where the face guard connects that is recessed from the primary contour of the helmet shell, as depicted in product imagery. | ¶¶30, 32 | col. 4:25-34 |
| a connector bracket configured to receive an extent of the upper peripheral mounting portion of the face guard and releasably secure... the face guard to the recessed face guard attachment region | The accused helmets use a bracket to attach the face guard to the shell in the recessed area. | ¶¶30, 32 | col. 6:50-58 |
| wherein in the secured position: (i) an exterior surface of said upper peripheral mounting portion of the face guard resides external to the adjacent first portion of the outer shell surface... | The face guard bars on the accused helmets are positioned external to the main plane of the helmet shell. | ¶¶30, 32 | col. 5:25-30 |
| ...(ii) at least a first extent of an inner surface of the connector bracket reside inward of the adjacent first portion of the outer shell surface... | The connector bracket on the accused helmets sits within the recessed region, inward of the primary outer surface of the shell. A cutaway image of the Schutt F7 2.0 shows the faceguard attachment point set into the shell (Compl. p. 11). | ¶¶30, 32 | col. 5:25-30 |
| ...(iii) a second extent of the inner surface of the connector bracket is offset a distance from an outer surface of the recessed face guard attachment region. | The connector bracket is allegedly configured such that an inner surface is spaced apart from the recessed region to accommodate the mounting hardware. | ¶¶30, 32 | col. 7:12-15 |
Identified Points of Contention
- Scope Questions: A central dispute may arise over whether the recess in the accused Schutt helmets constitutes a “U-shaped area” that is defined by “three linear wall segments” as strictly required by the claim. The geometric accuracy of this description as applied to the accused products will be a key factual question.
- Technical Questions: The analysis may question whether the spatial relationships between the shell, bracket, and face guard in the accused products meet all three sub-elements (i, ii, and iii) of the “secured position” limitation.
’514 Patent Infringement Allegations
| Claim Element (from Independent Claim 20) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first non-circular opening formed in the shell and configured to overlie an ear of the player... said first non-circular opening is defined by an arrangement of edge segments that includes a top edge oriented towards the crown region and a rear edge... | The accused Schutt helmets include a main, non-circular opening in the side region of the shell designed to be positioned over the player’s ear. | ¶¶41, 43 | col. 10:19-27 |
| a second non-circular opening formed in the shell and positioned rearward of the first non-circular opening, said second non-circular opening is defined by an arrangement of edge segments that includes a top edge... and a front edge... | The accused Schutt helmets allegedly feature a second, smaller non-circular opening (such as a vent) located behind the primary ear opening. | ¶¶41, 43 | col. 10:19-27 |
| wherein at least a substantial extent of the top edge of the first non-circular opening is aligned with the top edge of the second non-circular opening. | The top edge of the primary ear opening and the top edge of the rearward opening in the accused helmets are alleged to be horizontally aligned with each other. | ¶¶41, 43 | col. 10:24-27 |
Identified Points of Contention
- Scope Questions: A primary issue for claim construction will be the term “aligned.” The parties may dispute the degree of co-linearity or parallelism required for the top edges to be considered aligned over a “substantial extent.”
- Technical Questions: It raises the question of whether a vent opening in the accused helmets serves the same structural and functional role as the “second non-circular opening” described in the patent, or if there is a fundamental difference in purpose and design that may distinguish it from the claimed invention.
V. Key Claim Terms for Construction
For the ’841 Patent
- The Term: "U-shaped area"
- Context and Importance: This term, further limited as being defined by "three linear wall segments," is central to the definition of the recessed region. Infringement depends on whether the accused product's geometry matches this specific structural description. Practitioners may focus on this term because visual evidence in the complaint is not detailed enough to confirm a perfect match with this precise geometric language.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification refers to FIG. 7, stating that segments of the transition wall "form a U-shaped area 59" (’841 Patent, col. 4:57-59). The term itself, absent the "three linear wall segments" limitation, could be argued to have a more general meaning.
- Evidence for a Narrower Interpretation: The claim language itself provides a narrow definition by explicitly requiring the area to be defined by "an arrangement of three linear wall segments." A defendant may argue that any curvature or deviation from a three-segment linear construction falls outside the claim scope.
For the ’514 Patent
- The Term: "aligned"
- Context and Importance: The infringement allegation for the '514 patent hinges on this geometric relationship between the two side openings. The definition of "aligned" will determine whether the accused helmet's design, which may have slight variations, falls within the claim scope.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim requires alignment over "at least a substantial extent," which suggests that perfect or complete alignment is not necessary and allows for some tolerance.
- Evidence for a Narrower Interpretation: The specification provides a highly specific geometric description, stating that "the upper edges 112a, 112’a collectively contain at least three points that are collinear" (’514 Patent, col. 10:13-15). A party could argue this language implies that "aligned" requires a strict, co-linear relationship.
VI. Other Allegations
- Indirect Infringement: The complaint does not provide sufficient detail for analysis of indirect infringement. It contains general allegations of infringement by "making, using, selling, offering to sell..." but does not plead specific facts related to inducement or contributory infringement, such as instructing users or providing components for an infringing purpose (Compl. ¶30, 41, 53, 65).
- Willful Infringement: The complaint alleges willful infringement for all four asserted patents. The basis for this allegation is pre-suit knowledge, stemming from infringement notice letters allegedly sent to Defendant on April 20, 2023, and July 7, 2023, which included preliminary claim charts for the asserted patents (Compl. ¶¶33, 44, 56, 68).
VII. Analyst’s Conclusion: Key Questions for the Case
This case presents a multifaceted dispute over football helmet technology, blending issues of structural geometry and internal liner construction. The outcome will likely depend on the court's interpretation of several key claim limitations as applied to the accused products. The central open questions appear to be:
- A core issue will be one of definitional scope: Can the precise geometric limitations in the ’841 patent, such as a "U-shaped area" defined by "three linear wall segments," be construed to read on the recessed face guard mounting areas of the accused Schutt helmets, or will minor structural deviations place them outside the claim’s scope?
- A second core issue will be one of geometric interpretation: For the ’514 patent, how will the term "aligned" be construed? The case may turn on whether the spatial relationship between the two side openings on the accused helmets meets the standard of alignment over a "substantial extent," particularly in light of the patent's specific "collinear" language in the specification.
- A key evidentiary question will be one of functional equivalence: For the multi-layer liner patents (’263 and ’829), does the accused products' use of "buckling structures" and "Tektonic plates" meet the claim requirements for layers that permit "relative rotational movement," and do their material densities and thicknesses map directly onto the patents' specific limitations?