DCT

8:25-cv-00197

MCP IP LLC v. Barnett Outdoors LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 8:25-cv-00197, M.D. Fla., 01/24/2025
  • Venue Allegations: Venue is asserted on the basis that Defendant is formed in the Middle District of Florida and has a regular and established place of business within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s crossbows, specifically the Hyper Raptor model, infringe a patent related to pass-through cabling systems for compound bows.
  • Technical Context: The technology concerns the design of cams and cable routing in modern compound bows and crossbows, a field where small design changes can affect arrow speed, accuracy, and reliability.
  • Key Procedural History: Plaintiff alleges sending a notice letter to Defendant on January 9, 2025, approximately two weeks prior to filing the complaint, putting Defendant on notice of the alleged infringement.

Case Timeline

Date Event
2017-02-09 U.S. Patent No. 10,386,151 Priority Date
2019-08-20 U.S. Patent No. 10,386,151 Issued
2025-01-09 Plaintiff sends notice letter to Defendant
2025-01-24 Complaint Filed

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

U.S. Patent No. 10,386,151 - "Archery Bow with Pass Through Cabling"

The Invention Explained

  • Problem Addressed: The patent’s background section identifies a general need for higher-performing compound bows that are more accurate, lightweight, and reliable than prior designs ('151 Patent, col. 1:16-20).
  • The Patented Solution: The invention describes a compound bow system featuring a rotatable member (cam) with a "pass-through aperture" that allows a power cable to route from one side of the cam to the other ('151 Patent, Abstract; col. 3:15-20). This design dictates a specific path for the power cable, comprising a first segment on one side of the cam, a pass-through segment within the aperture, and another segment on the opposite side of the cam, which can influence the bow's performance characteristics ('151 Patent, col. 4:55-65).
  • Technical Importance: This cabling arrangement provides a novel method for managing the forces and paths of power cables in a compound bow, which can be engineered to affect shot accuracy and mechanical efficiency ('151 Patent, col. 1:16-20).

Key Claims at a Glance

  • The complaint asserts independent Claim 1 and notes infringement of "one or more claims" (Compl. ¶14, 17).
  • The essential elements of independent Claim 1 are:
    • A crossbow comprising: a frame;
    • a first limb arranged to support a first rotatable member, said first rotatable member comprising a first side, a second side, a bowstring track, a first cable track and a pass-through aperture;
    • a second limb arranged to support a second rotatable member;
    • a bowstring extending between the first rotatable member and the second rotatable member; and
    • a first power cable comprising a first segment, a pass-through segment and a second segment, the first segment oriented to the first side of the first rotatable member, the pass-through segment oriented in the pass-through aperture, the third segment oriented to the second side of the first rotatable member.

III. The Accused Instrumentality

Product Identification

Barnett's "Hyper Raptor crossbow and substantially similar products and components thereof" (the "Accused Products") (Compl. ¶14).

Functionality and Market Context

The complaint alleges that the Accused Products are crossbows that have the claimed features of the ’151 Patent (Compl. ¶14). The complaint does not provide specific details regarding the technical operation of the Hyper Raptor crossbow's cabling or cam system, other than the general allegation that it infringes Claim 1 (Compl. ¶14, 18). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that the Accused Products infringe at least Claim 1 of the ’151 Patent (Compl. ¶18). However, it does not provide a narrative explanation or element-by-element breakdown of its infringement theory in the body of the complaint. Instead, it refers to an external "Exhibit B" for an illustrative infringement chart, which was not provided with the complaint document (Compl. ¶18). Therefore, the complaint does not provide sufficient detail for a claim-chart-based analysis of the infringement allegations.

V. Key Claim Terms for Construction

  • The Term: "pass-through aperture"

  • Context and Importance: This term is central to the claimed invention, as it defines the physical feature enabling the novel cable path. The scope of this term—whether it is limited to specific shapes or configurations—will be critical to determining infringement.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification describes the aperture’s function as providing "communication between the first side 16 and second side 18," which could suggest any opening fulfilling this role would suffice ('151 Patent, col. 3:17-18).
    • Evidence for a Narrower Interpretation: The patent describes and depicts specific embodiments where the aperture has "a flared end portion 42" to guide the cable and extends through a "raised flange 36" ('151 Patent, col. 3:21-34; Fig. 2). A defendant may argue that these features are required limitations.

  • The Term: "the third segment oriented to the second side of the first rotatable member"

  • Context and Importance: This limitation, along with the other "segment" limitations, defines the specific three-part geometry of the power cable's path relative to the cam. Practitioners may focus on this term because Claim 1 introduces "a first segment, a pass-through segment and a second segment" but then refers to a "third segment," a potential antecedent basis issue that could be a subject of dispute. The infringement analysis will depend on whether the accused product's cable path matches this claimed geometric arrangement.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The term "oriented to" could be construed broadly as a general directionality, not requiring a specific angle, separation, or that the segment be entirely contained on the second side.
    • Evidence for a Narrower Interpretation: The patent's figures, such as Figure 6, depict the cable segments as having distinct and separate paths on opposite sides of the rotatable member (20), connected only through the aperture (40) ('151 Patent, Fig. 6). A party could argue that "oriented to the second side" requires a configuration consistent with these specific visual depictions.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Barnett induces infringement by taking "active steps to promote and encourage the sale of the Accused Products" and knows or should know that this encouragement induces direct infringement (Compl. ¶15).
  • Willful Infringement: Willfulness is alleged based on two grounds: (1) alleged pre-suit knowledge of the ’151 Patent "on information and belief" (Compl. ¶20), and (2) continued infringement after receiving a notice letter from MCP on January 9, 2025 (Compl. ¶19, 21).

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

  • A core issue will be one of claim construction: how will the court define the scope of the term "pass-through aperture"? Will it be construed broadly to cover any opening through the cam, or will it be limited to the more specific "flared" and "flanged" embodiments shown in the patent's figures? The outcome of this question may be dispositive.
  • A second central issue will relate to claim language and evidence: does the language of Claim 1, which appears to contain a typographical error by introducing a "second segment" but later referring to a "third segment," create ambiguity? Further, a key evidentiary question will be whether the plaintiff can prove that the accused Hyper Raptor crossbow's cable system follows the precise three-part spatial orientation required by the claim.