DCT
1:25-cv-01224
Bowtech LLC v. Truth Archery LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Bowtech, LLC (Delaware)
- Defendant: Truth Archery LLC (Delaware)
- Plaintiff’s Counsel: Swartz Campbell LLC; Husch Blackwell LLP
- Case Identification: 1:25-cv-01224, D. Del., 10/02/2025
- Venue Allegations: Venue is alleged to be proper based on Defendant’s organization and residency in Delaware, as well as alleged acts of infringement, including sales and offers for sale, within the district.
- Core Dispute: Plaintiff alleges that Defendant’s compound archery bows, which feature an adjustable cam system, infringe a patent related to technology for adjusting the transverse position of a bow’s pulley assembly.
- Technical Context: The technology concerns high-performance compound archery bows, where precise alignment of cables and pulleys is critical for accuracy and consistent arrow flight.
- Key Procedural History: The complaint does not reference any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2016-06-22 | U.S. Patent No. 9,683,806 Priority Date |
| 2017-06-20 | U.S. Patent No. 9,683,806 Issue Date |
| 2025-10-02 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,683,806 - "Compound Archery Bow With Adjustable Transverse Position of the Pulley Assembly," Issued June 20, 2017
The Invention Explained
- Problem Addressed: The patent's background section describes an issue in compound bows where "power cables" must be deflected laterally to avoid interfering with the arrow's path. This misalignment can produce "undesirable lateral deflection or twisting of the pulley members or the limbs," which in turn can lead to "shooting inaccuracy, poor arrow flight, accelerated wear or damage, or other problems" (’806 Patent, col. 2:29-45).
- The Patented Solution: The invention provides a pulley assembly that can be "fixed at any one of multiple transverse positions along its rotation axis relative to the bow limb" (’806 Patent, Abstract). This adjustability allows an archer to fine-tune the lateral position of the pulley (or "cam"), compensating for force misalignments and optimizing the bow’s performance for greater accuracy (’806 Patent, col. 2:46-50; Compl. ¶10). The patent discloses achieving this either by retaining the transverse axle at different positions on the bow limb or by retaining the pulley at different positions along the axle itself (’806 Patent, Abstract).
- Technical Importance: This technology provides a user-adjustable mechanism for tuning a bow, a critical feature for high-performance archers seeking to optimize equipment for consistency and precision (Compl. ¶10).
Key Claims at a Glance
- The complaint asserts independent Claim 1 (Compl. ¶15).
- The essential elements of Claim 1 include:
- A compound archery bow with a riser, first and second resilient bow limbs.
- A first transverse axle and a rotatable first pulley member mounted on the first bow limb.
- A second transverse axle and a rotatable second pulley member mounted on the second bow limb.
- A draw cable and a power cable engaged with the pulley members to store and release energy.
- A novel feature wherein the "first pulley member is fixed at any one of multiple transverse positions along the first rotation axis relative to the first bow limb." This can be achieved by either (i) retaining the axle at multiple positions on the limb, or (ii) retaining the pulley at multiple positions on the axle.
- The complaint alleges infringement of "one or more claims," reserving the right to assert additional claims (Compl. ¶14).
III. The Accused Instrumentality
Product Identification
- The accused products are compound archery bows, specifically the Truth 31 MG, 33 MG, 35 MG, and 33AL models, and other substantially similar products (collectively, the "Truth Archery Bows") (Compl. ¶11).
Functionality and Market Context
- The Truth Archery Bows are alleged to incorporate a feature called the "KSET Cam Adjustment System" (Compl. ¶12). According to the complaint, this system allows a user to "optimize bow performance and accuracy by laterally adjusting the bow's pulleys left or right depending on tuning needs" (Compl. ¶12). An image provided in the complaint shows the pulley assembly adjusted to its leftmost and rightmost positions, illustrating the system's range of lateral movement (Compl. p. 5). The complaint asserts this functionality is central to the product's performance (Compl. ¶12).
IV. Analysis of Infringement Allegations
9,683,806 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| (a) a substantially rigid riser; | The accused bows comprise a substantially rigid riser. | ¶16 | col. 4:35-36 |
| (b) a first resilient bow limb extending from a first end portion of the riser; | The accused bows comprise resilient bow limbs. | ¶16 | col. 4:35-37 |
| (c) a second resilient bow limb extending from a second end portion of the riser; | The accused bows comprise resilient bow limbs. | ¶16 | col. 4:35-37 |
| (d) a first transverse axle and a first pulley member...rotatable relative to the first bow limb... | The accused bows have transverse axles and rotatable pulley members. | ¶16 | col. 5:31-36 |
| (e) a second transverse axle and a second pulley member... | The accused bows have a second transverse axle and pulley member. | ¶16 | col. 5:31-36 |
| (f) a draw cable engaged with the first and second draw cable grooves... | The accused bows have a draw cable engaged with the pulley members. | ¶16 | col. 4:55-58 |
| (g) a power cable...engaged to be taken up by the power cable take-up mechanism... | The accused bows have a power cable engaged with a take-up mechanism. | ¶16 | col. 4:58-62 |
| (h) wherein the first pulley member is fixed at any one of multiple transverse positions...by...(i) the first transverse axle being retained on the first bow limb at any one of multiple axle positions... | The KSET Cam Adjustment System allegedly retains a first transverse axle on a first bow limb at any one of multiple axle positions along a first rotation axis. | ¶17 | col. 5:15-20 |
- Identified Points of Contention:
- Scope Questions: A central question may be whether the accused KSET Cam Adjustment System's mechanism for lateral movement meets the specific structural requirements of claim 1(h)(i), which requires "the first transverse axle being retained on the first bow limb at any one of multiple axle positions...by engagement of the first transverse axle with the first bow limb." The complaint does not detail the specific mechanics of the accused system, leaving open questions as to how the axle is "retained."
- Technical Questions: The complaint alleges the accused bows meet the limitation of claim 1(h), but provides no technical detail on how the KSET system achieves this function. Discovery will likely focus on whether the accused system uses, for example, a threaded axle, a clamp, set screws, or discrete, indexed slots to retain the axle, and whether any of these mechanisms constitute "engagement of the first transverse axle with the first bow limb" as claimed.
V. Key Claim Terms for Construction
The Term: "fixed"
- Context and Importance: This term from claim 1(h) is critical for defining the state of the pulley member after adjustment. Practitioners may focus on whether "fixed" requires a rigid, locked state or if it can also describe a position that is merely held in place by tension or friction until a subsequent adjustment is made.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent’s general description suggests the goal is to establish a chosen position to optimize performance, which could support a broader meaning of being secured or set in place (’806 Patent, Abstract).
- Evidence for a Narrower Interpretation: The specification discloses specific locking mechanisms like set screws and clamps that secure the axle, which could support a narrower construction requiring a more permanent or mechanically locked state (’806 Patent, col. 7:11-24).
The Term: "multiple...positions"
- Context and Importance: Used in claim 1(h), the construction of this term will determine whether the invention is limited to systems with discrete, predefined adjustment points or if it also covers continuously adjustable systems.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification explicitly states that "The multiple transverse positions can be a set of discrete transverse positions, or a continuously variable range of transverse positions" (’806 Patent, col. 6:4-6). This provides strong intrinsic evidence for a broad construction covering both types of adjustability.
- Evidence for a Narrower Interpretation: A defendant could argue that the claim language "any one of multiple...positions" inherently suggests a finite, countable number of positions, and that the specification’s broader disclosure of a "continuously variable range" is not captured by the scope of this particular claim.
VI. Other Allegations
- Willful Infringement: The complaint alleges willful infringement based on the assertion that Defendant had "knowledge of the ‘806 Patent well-before developing the KSET Cam Adjustment System" (Compl. ¶19). This allegation of pre-suit knowledge, if substantiated, could form the basis for enhanced damages. The complaint also alleges infringement "continues to be willful," covering post-suit conduct (Compl. ¶19).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of technical implementation: What is the precise mechanical structure and method of operation of the accused KSET Cam Adjustment System? The infringement analysis will depend entirely on whether that undisclosed mechanism meets the specific limitations of how the pulley or axle is "retained" and "fixed" as recited in Claim 1.
- A key legal question will be one of claim scope: How will the court construe the term "fixed at any one of multiple...positions"? The resolution of this question, particularly whether it covers continuously adjustable systems, will be pivotal, as the patent specification itself contemplates both discrete and continuous adjustability.
- A key evidentiary question will concern willfulness: What evidence, if any, can Plaintiff produce to support its allegation that Defendant had pre-suit knowledge of the ’806 patent before developing its accused products?