DCT

5:23-cv-00598

Ravin Crossbows LLC v. Hunter's Mfg Co Inc

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:21-cv-02213, D. Nev., 12/17/2021
  • Venue Allegations: Venue is alleged to be proper in the District of Nevada because Defendant is incorporated under the laws of Nevada and has committed acts of infringement within the District.
  • Core Dispute: Plaintiff alleges that Defendant’s high-performance crossbows, which feature "Vector Quad Cable Technology," infringe six of Plaintiff's patents related to crossbow cam and cabling systems, marketed by Plaintiff as HeliCoil® technology.
  • Technical Context: The dispute centers on the mechanical systems in modern compound crossbows that are designed to increase arrow velocity and accuracy by enabling greater rotation of the device's cams.
  • Key Procedural History: The complaint notes that Certificates of Correction have been issued for three of the patents-in-suit. It also alleges that Plaintiff’s representative sent an email to Defendant’s representative in July 2017 listing patents protecting its crossbows, and that Defendant’s representative contacted Plaintiff in November 2017 seeking a potential license to the patented technology, which may be relevant to the allegations of willful infringement.

Case Timeline

Date Event
2013-12-16 Priority Date for ’015 Patent
2015-10-22 Priority Date for ’379, ’936, ’073, ’118, and ’728 Patents
2016-05-31 U.S. Patent No. 9,354,015 Issues
2016-11-15 U.S. Patent No. 9,494,379 Issues
2017-07-15 Ravin representative allegedly sends email to TenPoint listing patents
2017-11-27 TenPoint representative allegedly contacts Ravin seeking a potential license
2018-01-30 U.S. Patent No. 9,879,936 Issues
2019-04-09 U.S. Patent No. 10,254,073 Issues
2020-07-14 U.S. Patent No. 10,712,118 Issues
2021-08-10 U.S. Patent No. 11,085,728 Issues
2021-12-17 Complaint Filed

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

U.S. Patent No. 9,354,015 - "String Guide System for a Bow"

The Invention Explained

  • Problem Addressed: In conventional compound bows with a "reverse draw" configuration, the power cables that flex the bow's limbs can interfere with the rotating components (cams or string guides) to which the bowstring is attached. This interference can limit cam rotation to approximately 270 degrees, which in turn reduces the potential length of the power stroke and limits the energy stored and transferred to the arrow (Compl. ¶14).
  • The Patented Solution: The invention uses a "helical" take-up journal for the power cables. As the bowstring is drawn, the power cables wrap around this helical journal, which displaces the cables vertically away from the main body of the cam. This creates clearance that allows other parts of the cam system to rotate past the power cables, enabling cam rotation greater than 270 degrees. This increased rotation allows for a longer power stroke, greater energy storage, and consequently higher arrow speeds (’015 Patent, col. 6:11-21; Compl. ¶15). The complaint includes an annotated version of Figure 7 from the related ’379 Patent to illustrate this helical journal concept (Compl. ¶15, p. 7).
  • Technical Importance: This design allows for the creation of more compact crossbows that can achieve higher arrow speeds and, by reducing issues like "cam lean," can also improve long-range accuracy (Compl. ¶15).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶42).
  • Essential elements of Claim 1 include:
    • A first string guide and a second string guide mounted to respective bow limbs.
    • A draw string received in a draw string journal on each guide.
    • A first power cable received in a first power cable take-up journal on the first string guide, and a second power cable received in a second power cable take-up journal on the second string guide.
    • Wherein each power cable take-up journal "translates" its respective power cable "away from" the string guide as the bow is drawn.
  • The complaint reserves the right to assert additional claims (Compl. ¶43).

U.S. Patent No. 9,494,379 - "Crossbow"

The Invention Explained

  • Problem Addressed: The patent addresses the same technical problem of limited cam rotation in reverse-draw crossbows due to interference between power cables and cam attachment points (’379 Patent, col. 1:45-56; Compl. ¶14).
  • The Patented Solution: The ’379 Patent discloses a crossbow with cams that have upper and lower helical power cable take-up journals. As the draw string unwinds, the power cables wrap onto these journals, displacing them vertically away from the plane of the draw string journal. This clearance allows for greater cam rotation, a longer power stroke, and higher arrow speeds (’379 Patent, col. 2:10-24; Compl. ¶15). The complaint uses Figure 7 from the ’379 Patent, which depicts a helical journal displacing a power cable, to explain the core technology (Compl. ¶15, p. 7).
  • Technical Importance: This system enables crossbow designs with greater energy storage and higher performance while also featuring power cables that do not cross over the center rail, which can improve accuracy (Compl. ¶15; ’379 Patent, col. 2:62-65).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶51).
  • Essential elements of Claim 1 include:
    • A riser, a center rail, and first and second flexible limbs.
    • First and second cams mounted to the limbs, each cam having a string guide journal, an upper power cable take-up journal, and a lower power cable take-up journal.
    • A draw string in a reverse draw configuration.
    • Upper and lower power cables with ends secured to the cams and to the center rail "without crossover."
    • Wherein the power cables are received in the take-up journals and "displaced away from the respective draw string journals" as the bow is drawn.
  • The complaint reserves the right to assert additional claims (Compl. ¶52).

U.S. Patent No. 9,879,936 - "String Guide for a Bow"

  • Patent Identification: U.S. Patent No. 9,879,936, titled “String Guide for a Bow,” issued January 30, 2018.
  • Technology Synopsis: This patent is directed to a string guide system for a bow that uses helical power cable journals to displace power cables away from the string guides during the draw cycle. This displacement allows for increased rotation of the string guides, a longer power stroke, and greater energy storage (’936 Patent, Abstract).
  • Asserted Claims: At least independent claim 1 (Compl. ¶60).
  • Accused Features: The accused features are the crossbows incorporating "Vector Quad Cable Technology," which allegedly utilize the patented helical journal system (Compl. ¶¶23, 61).

U.S. Patent No. 10,254,073 - "Crossbow"

  • Patent Identification: U.S. Patent No. 10,254,073, titled “Crossbow,” issued April 9, 2019.
  • Technology Synopsis: This patent discloses a crossbow with cams having helical power cable take-up journals. As the bow is drawn, the power cables wrap onto these journals and are displaced away from the draw string journals, permitting the cams to rotate more than 360 degrees, which enables a longer power stroke (’073 Patent, Abstract; col. 2:49-53).
  • Asserted Claims: At least independent claim 1 (Compl. ¶69).
  • Accused Features: The accused features are the crossbows incorporating "Vector Quad Cable Technology," which allegedly utilize the patented helical journal system (Compl. ¶¶23, 70).

U.S. Patent No. 10,712,118 - "Crossbow"

  • Patent Identification: U.S. Patent No. 10,712,118, titled “Crossbow,” issued July 14, 2020.
  • Technology Synopsis: This patent discloses a crossbow with string guides that include upper and lower helical power cable journals. The helical journals are not co-planar with the draw string journals, and this configuration displaces the power cables to allow for cam rotation of at least 300 degrees, resulting in a longer power stroke and higher arrow speeds (’118 Patent, Abstract).
  • Asserted Claims: At least independent claim 1 (Compl. ¶78).
  • Accused Features: The accused features are the crossbows incorporating "Vector Quad Cable Technology," which allegedly utilize the patented helical journal system (Compl. ¶¶23, 79).

U.S. Patent No. 11,085,728 - "Crossbow with Cabling System"

  • Patent Identification: U.S. Patent No. 11,085,728, titled “Crossbow with Cabling System,” issued August 10, 2021.
  • Technology Synopsis: This patent describes a crossbow cabling system where power cables are attached to a static power cable bracket rather than to an opposing limb or cam. The system uses helical power cable journals on the cams to displace the cables vertically, allowing for increased cam rotation and preventing interference (’728 Patent, Abstract; claim 1).
  • Asserted Claims: At least independent claim 10 (Compl. ¶87).
  • Accused Features: The accused features are the crossbows incorporating "Vector Quad Cable Technology," which allegedly utilize the patented helical journal system (Compl. ¶¶23, 88).

III. The Accused Instrumentality

Product Identification

  • A series of crossbows sold by Defendant, including the Nitro 505, Vapor RS470, Havoc RS440, Vengent S440, and Siege RS410 models, collectively referred to as the "Infringing Crossbows" (Compl. ¶21).

Functionality and Market Context

  • The complaint alleges that the Infringing Crossbows incorporate "Vector Quad Cable Technology," which Plaintiff contends is an implementation of its patented HeliCoil® system (Compl. ¶23). This technology is alleged to use four power cables where one end of each cable attaches to a static terminal on the crossbow's riser and the other end anchors to a cam (Compl. ¶23). The complaint asserts that each cam on the accused crossbows includes helical power cable journals that wrap around the top and bottom of the cam, extending vertically away from the draw string journal (Compl. ¶24). This configuration allegedly displaces the power cables, creating space that allows anchors on the cams to pass by the cables, enabling cam rotation in excess of 270 degrees and advertised rotations of up to 360 or 404 degrees (Compl. ¶¶25, 26, 34). An annotated image of the TenPoint Siege RS410 crossbow in the complaint identifies the upper and lower power cables and their anchors (Compl. ¶23, p. 12). Plaintiff alleges that Defendant’s development of these crossbows was a direct response to Plaintiff's products and that Defendant does not offer crossbows capable of exceeding 400 feet per second without this technology (Compl. ¶21).

IV. Analysis of Infringement Allegations

'015 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a first string guide mounted to a first bow limb and a second string guide mounted to a second bow limb The accused crossbows include cams mounted between pairs of flexible limbs (Compl. ¶22). An image shows cams mounted on the limbs of the Vengent S440 and Vapor RS470 crossbows (Compl. p. 11). ¶22, p. 11 col. 4:47-52
a draw string received in a draw string journal on each of the first and second string guides A draw string is drawn from a draw string journal on each cam (Compl. ¶28). An image of an accused cam identifies a "Draw String Journal" (Compl. p. 13). ¶28, p. 13 col. 4:53-56
a first power cable take-up journal on the first string guide... [and a second on the second] Each cam includes helical power cable journals that receive power cables (Compl. ¶24). An image of an accused cam identifies "Upper Power Cable Journal" and "Lower Power Cable Journal" (Compl. p. 13). ¶24, p. 13 col. 4:57-60
wherein the first power cable take-up journal translates the first power cable away from the first string guide... As power cables wrap into the helical power cable journals, they are displaced vertically away from the draw string journal (Compl. ¶25). This vertical displacement is alleged to create space allowing cam anchors to pass the cables (Compl. ¶25). ¶25 col. 5:11-16

'379 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a riser located proximate a down-range side of a center rail The accused crossbows include a riser that extends away from a barrel and to which flexible limbs are secured (Compl. ¶22). The riser is identified in an image of the Vengent S440 and Vapor RS470 crossbows (Compl. p. 11). ¶22, p. 11 col. 8:37-40
first and second cams mounted to the first and second bow limbs... each of the cams having a string guide journal, an upper power cable take-up journal, and a lower power cable take-up journal Each cam on the accused crossbows allegedly includes a helical power cable journal that displaces power cables away from the draw string journal (Compl. ¶¶17, 24). An image of a cam from an accused crossbow identifies these distinct journals (Compl. p. 13). ¶17, ¶24, p. 13 col. 8:43-51
upper and lower power cables for each of the first and second cams having first ends secured to each of the first and second cams and second ends secured to the center rail without crossover The "Vector Quad Cable Technology" in the accused crossbows allegedly includes four power cables, with one end attached to a static terminal on the riser and the other anchored to a cam (Compl. ¶23). ¶23 col. 8:55-62
wherein the upper and lower power cables are... displaced away from the respective draw string journals as the bow is drawn As power cables wrap into the helical journals on the cams, they are displaced vertically away from the draw string journal, creating space between the cables and the cam surfaces (Compl. ¶25). ¶25 col. 9:1-6

Identified Points of Contention

  • Scope Questions: The ’015 Patent claims a "string guide," while the complaint and the ’379 Patent describe the accused component as a "cam." The litigation may turn on whether the term "string guide" as used and defined in the ’015 Patent is broad enough to read on the "cams" of the accused crossbows.
  • Technical Questions: A central technical question will be whether the accused "Vector Quad Cable Technology" functions in the same way as the claimed inventions. The complaint alleges that vertical displacement of the power cables is what "allows each of the cams to rotate in excess of 270 degrees" (Compl. ¶25). A potential point of dispute could be whether this specific mechanism of creating clearance for "power cable anchors" to pass is precisely how the accused products achieve increased rotation, or if there is a functional difference in their operation that takes them outside the scope of the claims.

V. Key Claim Terms for Construction

The Term: "string guide" (’015 Patent, claim 1)

  • Context and Importance: This term's construction is critical because the claim requires components identified as "string guides," while the accused products are described as having "cams." Plaintiff will need the term to be construed broadly enough to encompass the accused cams, while Defendant may argue for a narrower definition that distinguishes the two.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification of the related ’073 Patent, which shares a common ancestry, states that "The string guides can be cams or pulleys with a variety of round and non-round shapes" (’073 Patent, col. 5:65-67).
    • Evidence for a Narrower Interpretation: Defendant may argue that the embodiments depicted in the ’015 Patent's figures show a specific structure, suggesting that a "string guide" should be limited to what is shown and described, potentially distinguishing it from the specific "cam" structures in the accused products.

The Term: "translates the first power cable away from the first string guide" (’015 Patent, claim 1) / "displaced away from the respective draw string journals" (’379 Patent, claim 1)

  • Context and Importance: This functional language describes the core mechanism of the invention. The dispute will likely focus on the nature and extent of this "translation" or "displacement." Practitioners may focus on this term because the infringement allegation hinges on the accused helical journals performing this specific function to create clearance for cam rotation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the function as serving "to displace the power cables 102 away from the string guides 104, so the first attachment points 106 do not contact the power cables 102" (’015 Patent, col. 6:11-15). This functional description may support a broader reading covering any structure that achieves this displacement for this purpose.
    • Evidence for a Narrower Interpretation: The figures show a distinct helical channel (e.g., ’015 Patent, Fig. 7). A defendant could argue that the claims require this specific helical structure to perform the translation, and that a different structure, even if it creates vertical displacement, would not infringe.

VI. Other Allegations

Indirect Infringement

  • The complaint does not plead separate counts for indirect infringement, but the factual allegations supporting willfulness, such as pre-suit knowledge, could also be used to support a claim for induced infringement.

Willful Infringement

  • Willfulness is alleged for all six patents-in-suit. The complaint alleges that Defendant knew of the patents based on its status as a direct competitor, as well as specific pre-suit communications (Compl. ¶¶35-36, 46, 55, 64, 73, 82, 91). These communications allegedly include a July 15, 2017 email from Plaintiff’s representative to Defendant’s representative listing patents, and a November 27, 2017 contact from Defendant’s representative to Plaintiff’s representative "seeking a potential license to Ravin's helical cam patents" (Compl. ¶36).

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

  • A core issue will be one of definitional scope: can the term "string guide," as used in the ’015 Patent, be construed to cover the more complex "cams" used in the accused crossbows, and will the patents in the family with broader language inform this construction?
  • A key evidentiary question will be one of functional operation: does the accused "Vector Quad Cable Technology" achieve increased cam rotation through the same mechanism of vertical cable "translation" or "displacement" to create clearance as required by the claims, or is there a fundamental mismatch in the way the accused products technically operate?
  • A central issue for damages will be intent: what was the nature and substance of the alleged pre-suit communications between the parties regarding patents and licensing, and will this evidence be sufficient to support a finding of willful infringement, potentially leading to enhanced damages?