DCT
2:19-cv-01401
Skywalker Holdings LLC v. Red Rock Sourcing LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Skywalker Holdings, LLC (Utah)
- Defendant: Red Rock Sourcing, LLC (Nevada)
- Plaintiff’s Counsel: Jones Waldo Holbrook & McDonough PC
- Case Identification: 2:19-cv-01401, D. Nev., 01/31/2020
- Venue Allegations: Plaintiff alleges venue is proper in the District of Nevada because Defendant has a place of business in the district and has committed the alleged acts of patent infringement there.
- Core Dispute: Plaintiff alleges that Defendant’s "Bounce Master" brand trampolines infringe a patent related to a method for attaching a safety enclosure directly to a trampoline's jumping mat.
- Technical Context: The technology addresses a safety issue in consumer trampolines by eliminating the gap between the safety net and the jumping surface, where users could otherwise fall or contact the springs.
- Key Procedural History: The asserted patent is a reissue patent. The complaint alleges that Plaintiff sent a letter to Defendant on July 24, 2019, requesting that it cease its infringing conduct, but Defendant did not respond.
Case Timeline
| Date | Event |
|---|---|
| 2005-05-24 | U.S. Patent No. RE45,182 Priority Date |
| 2014-10-07 | U.S. Patent No. RE45,182 Issues |
| 2019-07-24 | Plaintiff sends pre-suit notice letter to Defendant |
| 2020-01-31 | Amended Complaint for Patent Infringement Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Reissued Patent No. RE45,182 - Trampoline Enclosure Attachment to Trampoline Mat
Patent Identification: U.S. Reissued Patent No. RE45,182, Trampoline Enclosure Attachment to Trampoline Mat, issued October 7, 2014 (’182 Patent) (Compl. ¶9; ’182 Patent, cover).
The Invention Explained
- Problem Addressed: The patent's background describes prior art methods for attaching safety enclosures to trampolines, such as manually weaving a rope, as "tedious and time consuming." It further notes that these methods can leave gaps between the enclosure wall and the rebounding surface, creating a risk that a user's limbs could slide into the gaps or contact the metal springs (’182 Patent, col. 1:39-52).
- The Patented Solution: The invention discloses a safety enclosure with a "flexible wall" that has a plurality of "buttonholes" positioned along its bottom edge. These buttonholes are sized to allow the spring attachment features of the rebounding mat (e.g., V-rings) to pass through them. When the trampoline springs are subsequently connected to these attachment features, the springs hold the flexible wall securely against the mat, which is intended to minimize gaps and provide a quick and effective attachment method (’182 Patent, Abstract; col. 2:61-67). Figure 3 of the patent illustrates the buttonholes of the enclosure wall (120) fitted over the V-ring spring attachment features (112) of the mat (’182 Patent, Fig. 3).
- Technical Importance: This design sought to improve trampoline safety by creating a more integrated, gap-free connection between the jumping mat and the safety net, while also simplifying the assembly process for consumers (’182 Patent, col. 2:61-67).
Key Claims at a Glance
- The complaint asserts infringement of at least Claim 1 of the ’182 Patent (Compl. ¶18; Compl., Ex. C).
- Independent Claim 1 requires:
- A trampoline comprising a frame, a rebounding surface with spring attachment features, springs, and vertical support rods.
- A trampoline enclosure comprising a flexible wall that connects to the support rods and has a bottom edge that connects to the rebounding surface.
- A plurality of buttonholes that are sized and configured to fit over the spring attachment features.
- The buttonholes are positioned near the bottom edge of the flexible wall and are aligned with the spring attachment features to allow the features to pass through the buttonholes, "and thereby connect the rebounding surface to the bottom edge of the flexible wall."
- The complaint alleges infringement of "one of more claims" of the patent (Compl. ¶18).
III. The Accused Instrumentality
Product Identification
The accused products are "Bounce Master trampolines" sold and offered for sale by Defendant Red Rock (Compl. ¶¶ 16, 18).
Functionality and Market Context
- The complaint alleges that the Bounce Master trampolines feature a safety enclosure system with a flexible wall and "coordinated buttonholes in the bottom of the flexible wall" (Compl. ¶19).
- These buttonholes are allegedly "configured to slip over the spring attachment features on the bounce pad," which mirrors the structure claimed in the ’182 Patent (Compl. ¶19). The complaint includes photographs, sourced from a preliminary claim chart, that depict the enclosure netting of an accused product with openings along its bottom edge being placed over V-rings on the jumping mat before a spring is attached (Compl., Ex. C, p. 4). This image shows the net's openings being placed over the V-rings on the mat (Compl., Ex. C, p. 4).
- The complaint alleges Defendant sells these products via the internet, citing an Amazon.com product page (Compl. ¶16).
IV. Analysis of Infringement Allegations
RE45,182 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a rebounding surface comprising a plurality of spring attachment features that attach the rebounding surface to the frame via a plurality of springs; | The Bounce Master trampoline includes a jumping mat with V-rings sewn on, which are used to attach the mat to the frame with springs (Compl., Ex. C, p. 2). | ¶19; Ex. C, p. 2 | col. 5:5-9 |
| a flexible wall that connects to the plurality of vertical support rods, said flexible wall being sized to encircle a perimeter of the rebounding surface and having a bottom edge that connects to the rebounding surface; and | The accused product includes an enclosure netting that attaches to support poles and encircles the jumping mat, with a bottom edge that attaches to the mat (Compl., Ex. C, p. 3). | ¶19; Ex. C, p. 3 | col. 6:46-52 |
| a plurality of buttonholes that are sized and configured to fit over the spring attachment features and are positioned proximate the bottom edge of the flexible wall and aligned with the spring attachment features to allow the spring attachment features of the rebounding surface to pass through... | The Bounce Master enclosure netting has a series of openings along its bottom edge that are allegedly sized and positioned to align with and slip over the V-rings on the jumping mat (Compl., Ex. C, p. 4). | ¶19; Ex. C, p. 4 | col. 6:53-58 |
| ...and thereby connect the rebounding surface to the bottom edge of the flexible wall. | By passing the V-rings through the openings in the netting and then attaching springs, the netting is allegedly secured to the jumping mat, thereby performing the claimed connection (Compl., Ex. C, pp. 4-5). | ¶19; Ex. C, pp. 4-5 | col. 6:58-59 |
Identified Points of Contention
- Scope Questions: The case may turn on the interpretation of "buttonholes." The defendant could argue that the openings in its net are structurally distinct from the "buttonholes" disclosed in the patent, raising the question of whether the claim term requires a specific slit-like structure or broadly covers any opening that performs the recited function.
- Technical Questions: A key question will concern the claim limitation that the buttonholes "thereby connect" the mat to the net. The complaint's theory appears to be that this connection is achieved when the spring is attached through the V-ring that has been passed through the buttonhole. A potential defense could be that the buttonhole is a passive opening and the spring is the sole connecting element, raising the question of whether the accused system meets this functional limitation.
V. Key Claim Terms for Construction
The Term: "buttonholes"
Context and Importance
This term defines the core structural element of the invention. Whether the openings in the accused Bounce Master netting fall within the scope of this term is central to the infringement analysis.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The patent specification describes that "buttonholes" may be formed and reinforced in several ways, including with sewn edges, solid plastic edges created with a hot knife, or reinforced with metal or plastic eyelets, suggesting the term is not limited to a single structure ('182 Patent, col. 2:36-48).
- Evidence for a Narrower Interpretation: The term itself carries an ordinary meaning of a slit cut in fabric for a button to pass through. The patent also discloses specific embodiments, such as the sewn buttonhole in Figure 6, which could be used to argue that the term implies a specific structure beyond a simple loop or opening (’182 Patent, Fig. 6).
The Term: "thereby connect the rebounding surface to the bottom edge of the flexible wall"
Context and Importance
This functional language describes the role of the "buttonholes." Infringement depends on whether the accused product's structure performs this specific connecting function.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The specification states that once the spring attachment features are passed through the buttonholes, the springs can be attached, and the springs "prevent the buttonholes from detaching from the spring attachment features," implying this entire arrangement constitutes the "connection" (’182 Patent, col. 2:56-60).
- Evidence for a Narrower Interpretation: A defendant might argue that the spring connects the V-ring to the frame, and the net is merely captured in between. Language describing how the buttonholes "allow the spring attachment features...to pass through" could be interpreted to mean the buttonhole is a passive conduit, not an active connector (’182 Patent, col. 6:56-58).
VI. Other Allegations
Indirect Infringement
The complaint alleges inducement to infringe, asserting that Red Rock provides a user manual with its trampolines that instructs purchasers on how to assemble the product in an infringing manner by "slipping the openings in the bottom of the flexible wall over the spring attachment features" (Compl. ¶¶ 17, 20, 31-35).
Willful Infringement
The complaint alleges willful infringement based on both constructive and actual knowledge (Compl. ¶27). The claim of actual knowledge is supported by the allegation that Plaintiff sent a cease-and-desist letter to Red Rock on July 24, 2019, which identified the infringing conduct, but Red Rock did not respond and allegedly continued its infringement (Compl. ¶¶ 21, 28).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction: does the term "buttonholes," as used in the ’182 Patent, encompass the openings in the accused Bounce Master net, and do those openings perform the claimed function of "connecting" the net to the mat, or are they merely passive passthroughs?
- A key evidentiary question will be one of inducement: does the user manual for the Bounce Master trampoline explicitly instruct users to assemble the safety enclosure by passing the mat's V-rings through the net's openings before attaching the springs, thereby directing them to perform the steps of the patented method?