I. Executive Summary and Procedural Information
- Parties & Counsel:
- Case Identification: 5:25-cv-00042, N.D. Ohio, 01/10/2025
- Venue Allegations: Venue is alleged to be proper as Defendant resides in and has its principal place of business within the Northern District of Ohio, where the alleged acts of infringement occurred.
- Core Dispute: Plaintiff alleges that Defendant’s archery bow stabilizers infringe three design patents that protect the ornamental appearance of Plaintiff's "Bridge-Lock" line of stabilizers.
- Technical Context: The technology at issue involves archery bow stabilizers, which are accessories attached to a bow to improve balance, reduce vibration, and enhance shooting accuracy.
- Key Procedural History: The complaint states that Plaintiff sent a letter to Defendant on January 2, 2024, identifying the asserted patents and alleging infringement. This letter was sent approximately one year before the complaint was filed.
Case Timeline
| Date |
Event |
| 2022-01-01 |
Mathews Bridge-Lock® Stabilizer released (approximate) |
| 2023-01-12 |
Priority Date for '295, '293, and '294 Patents |
| 2024-01-02 |
Mathews sends letter to Redline alleging patent infringement |
| 2024-10-29 |
'295, '293, and '294 Design Patents Issued |
| 2025-01-10 |
Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Design Patent No. D1,049,295 - Archery Bow Stabilizer Bar (Issued Oct. 29, 2024)
The Invention Explained
- Problem Addressed: The complaint suggests that prior to Plaintiff's innovation, archery bow stabilizers often possessed a conventional, round appearance. (Compl. ¶14, Fig. 2).
- The Patented Solution: The '295 Patent protects the specific ornamental design for the top rail of a stabilizer bar. (Compl. ¶64). The design, as shown in the patent's figures, provides a distinct visual appearance that departs from the traditional cylindrical form factor. (Compl. ¶15).
- Technical Importance: The complaint alleges that this unique ornamental design serves as a key product differentiator and is associated with the Plaintiff's brand and reputation as an innovator. (Compl. ¶76).
Key Claims at a Glance
- The patent contains a single claim for "The ornamental design for an archery bow stabilizer bar as shown and described." ('295 Patent, Claim).
- The claimed design is limited to the visual characteristics of the top rail, as depicted in solid lines in the patent's drawings. The remainder of the stabilizer bar is shown in broken lines and is not part of the claimed design. ('295 Patent, Figs. 1, 6).
U.S. Design Patent No. D1,049,293 - Archery Bow Stabilizer Bar (Issued Oct. 29, 2024)
The Invention Explained
- Problem Addressed: As described above, the patent addresses the need for a distinct ornamental appearance in the crowded market for archery accessories. (Compl. ¶¶14-15).
- The Patented Solution: The '293 Patent protects the ornamental design for the top and bottom rails of a stabilizer bar, which features a repeating pattern of cutouts creating a truss-like or bridge-like visual effect. (Compl. ¶80; '293 Patent, Fig. 1). This design is part of Plaintiff's "Bridge-Lock" product line. (Compl. ¶15).
- Technical Importance: The distinct ornamental design is alleged to be a core feature of a commercially successful product that consumers associate exclusively with the Plaintiff. (Compl. ¶¶15, 76).
Key Claims at a Glance
- The patent asserts a single claim for "The ornamental design for an archery bow stabilizer bar as shown and described." ('293 Patent, Claim).
- The claim covers the ornamental appearance of the main body of the stabilizer, as shown in solid lines. The end portions of the stabilizer are depicted in broken lines, indicating they are environmental structure and not part of the claimed design. ('293 Patent, Fig. 1).
Multi-Patent Capsule: U.S. Design Patent No. D1,049,294
- Patent Identification: U.S. Design Patent No. D1,049,294, Archery Bow Stabilizer Bar, Issued Oct. 29, 2024.
- Technology Synopsis: This design patent protects the ornamental appearance of the profiles of the top and bottom rails of the stabilizer bar. (Compl. ¶96). The design consists of a specific cross-sectional shape, contributing to the overall unique aesthetic of the product line. ('294 Patent, Figs. 2-4).
- Asserted Claims: The single claim for the ornamental design as shown in the patent's figures.
- Accused Features: The overall shape and profile of Defendant's "Bridge" series stabilizer are alleged to be substantially similar to the design claimed in the '294 Patent. (Compl. ¶99).
III. The Accused Instrumentality
Product Identification
- Defendant's "Bridge Carbon Hunting Stabilizer" or "Bridge Series" stabilizer, offered in 8- and 12-inch models (the "Redline Accused Products"). (Compl. ¶¶35-36).
Functionality and Market Context
- The Redline Accused Products function as archery bow stabilizers, intended to improve a bow's balance and reduce vibration. (Compl. ¶13). The complaint alleges the products are "knockoff stabilizers for use with Mathews' patented bows" and were created by "copying elements" of Mathews' design. (Compl. ¶¶35, 38). An image in the complaint shows a side-by-side comparison of the Plaintiff's and Defendant's products, highlighting their visual similarities. (Compl. ¶35, Fig. 6). The complaint further alleges that Defendant's marketing describes the product as a "bridge lock bar" and compatible with Mathews' "bridge lock" system, creating a purported association. (Compl. ¶36, ¶46).
IV. Analysis of Infringement Allegations
D1,049,295 Infringement Allegations
| Claim Element (from the single design claim) |
Alleged Infringing Functionality |
Complaint Citation |
Patent Citation |
| The ornamental design for the top rail of the archery bow stabilizer bar as shown and described. |
The complaint alleges that the top rail of the Redline Accused Product embodies a design that an ordinary observer would believe is substantially similar to the design claimed in the '295 Patent. An exemplary image juxtaposes the accused product with the patented design. (Compl. p. 21). |
¶67 |
'295 Patent, Fig. 1 |
D1,049,293 Infringement Allegations
| Claim Element (from the single design claim) |
Alleged Infringing Functionality |
Complaint Citation |
Patent Citation |
| The ornamental design for the top and bottom rails of the archery bow stabilizer bar as shown and described. |
The complaint alleges that the overall ornamental appearance of the Redline Accused Product, including its truss-like side rail structure, is substantially similar to the claimed design such that it would deceive an ordinary observer. A side-by-side comparison is provided. (Compl. p. 26). |
¶83 |
'293 Patent, Fig. 1 |
Identified Points of Contention
- Scope Questions: The primary scope question is how the disclaimed portions of the designs (shown in broken lines, such as end caps) will affect the "ordinary observer" analysis. The court's analysis will focus only on the visual impression created by the elements shown in solid lines in the patent drawings.
- Visual Similarity Questions: The core factual dispute is one of visual comparison. A key question for the court will be whether an ordinary observer, taking into account the prior art, would perceive the designs of the accused products as substantially the same as the patented designs. The complaint's side-by-side photographic comparisons, such as Figure 6, will be central to this analysis. (Compl. ¶35, Fig. 6). A related question may be whether the prominent "REDLINE" branding on the accused product is sufficient to prevent visual confusion. (Compl. p. 21, Exemplary Redline Accused Product).
V. Key Claim Terms for Construction
In design patent litigation, the "claim" is the design itself as depicted in the drawings, and the construction of written terms is less common than in utility patent cases. The primary interpretive task is determining the scope of the design from the figures.
- The Term: "The ornamental design... as shown and described."
- Context and Importance: This phrase defines the scope of the patent right. The infringement analysis depends entirely on comparing this claimed visual design, as a whole, to the design of the accused product. Practitioners will focus on this "term" by carefully analyzing what is shown in solid lines (the claimed design) versus broken lines (the unclaimed environment) to define the boundaries of the right for the "ordinary observer" test.
- Intrinsic Evidence for Interpretation: The patent drawings are the primary evidence.
- Evidence for a Broader Interpretation: A party may argue that the claim's scope should be viewed from the perspective of its overall visual gestalt. For the '293 Patent, this would be the general impression of a truss-like or bridge-like structure, rather than focusing on minute details of each cutout.
- Evidence for a Narrower Interpretation: A party may argue that the scope is strictly limited to the precise proportions, curvatures, and angles depicted in the solid-line drawings. Any deviation in the accused product's design from these specific features could be argued as a basis for non-infringement.
VI. Other Allegations
- Indirect Infringement: The complaint does not plead indirect patent infringement.
- Willful Infringement: The complaint alleges willful infringement based on both pre-suit and post-suit knowledge. It alleges that Defendant was aware of Plaintiff's stabilizer design and copied elements of it. (Compl. ¶¶37-38). More specifically, it alleges that Plaintiff provided Defendant with actual notice of the asserted patents in a letter dated January 2, 2024, more than a year before the suit was filed. (Compl. ¶¶39, 70, 86, 102). The complaint also points to Plaintiff's public patent marking website as a source of notice. (Compl. ¶41, Fig. 7).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of visual comparison: Applying the "ordinary observer" test, is the ornamental design of the Redline stabilizer "substantially the same" as the patented designs, considering the claimed elements as a whole and in light of the prior art, such that an observer would be deceived into purchasing one thinking it was the other?
- A key evidentiary question will be the impact of branding: Does the prominent "REDLINE" logo on the accused product create a sufficiently different overall visual impression to avoid a finding of infringement, or is the underlying ornamental design so similar that the branding is insufficient to prevent confusion?
- A critical question for damages will be one of willfulness: Given the allegation that Plaintiff provided actual, written notice of the specific patents-in-suit a full year before filing the complaint, did Defendant's continued sales constitute "deliberate disregard" of Plaintiff's patent rights, potentially justifying an award of enhanced damages?