DCT

3:26-cv-00004

Qubicaamf Worldwide LLC v. Brunswick Bowling Products LLC

Log In
Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:26-cv-00004, W.D. Va., 01/14/2026
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant has a regular and established place of business in the district, is qualified to transact business in Virginia, maintains a registered office there, and has allegedly committed acts of infringement within the district, including offering the accused products for sale.
  • Core Dispute: Plaintiff alleges that Defendant’s string pinsetter systems, particularly the Boost ST String Pinsetter equipped with the 360 Controller, infringe a patent related to technology for adjusting the slack length of the strings used to reset bowling pins.
  • Technical Context: The lawsuit concerns automated string pinsetters, which reset bowling pins using attached cords, a common technology in the bowling industry that competes with traditional free-fall pinsetters.
  • Key Procedural History: The complaint alleges that Plaintiff provided Defendant with written notice of the patent and the alleged infringement in March 2025, approximately ten months before filing the lawsuit. This pre-suit notice is cited as a basis for the willfulness and indirect infringement claims.

Case Timeline

Date Event
2023-06-21 ’527 Patent Priority Date
2024-11-12 ’527 Patent Issue Date
2025-03-01 Alleged pre-suit notice of infringement to Defendant (approx. date)
2026-01-14 Complaint Filing Date

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

U.S. Patent No. 12,138,527 - *BOWLING CENTER SYSTEM*, Issued November 12, 2024

The Invention Explained

  • Problem Addressed: Conventional string pinsetters face a trade-off. If the string length provides too much slack, the strings can become entangled during play, leading to machine downtime. If the string length is too short, the string's tension can unnaturally alter how a pin falls when struck, potentially affecting the outcome of a game, a particular concern for professional bowlers who expect performance similar to free-fall systems (’527 Patent, col. 1:46-col. 2:14).
  • The Patented Solution: The patent describes a system that allows for adjustable string slack. The core component is a motor-driven "drawbar" that moves along a path to either retract or release the strings. The invention adds a control system that can direct this drawbar to move to "at least a third alternative operating game position" beyond its standard positions. This third position releases a "second working length" of string that is different from the "first working length," allowing an operator to configure the pinsetter for different playing conditions—for example, a shorter slack for casual play to reduce tangles or a longer slack for professional play to better mimic free-fall pin action (’527 Patent, Abstract; col. 3:33-41). Figure 1 of the patent illustrates the key components, including the bowling lane (1), pins (2), strings (3), movable drawbar (6), and control system (9).
  • Technical Importance: The invention aims to provide the operational flexibility to overcome the inherent compromise between minimizing string entanglement and ensuring natural pin fall dynamics, thereby improving the performance and versatility of string pinsetter systems (’527 Patent, col. 2:21-24).

Key Claims at a Glance

The complaint asserts infringement of claims 1 and 3-18, with specific counts directed to independent claims 1 and 12 (Compl. ¶19, ¶25, ¶37).

  • Independent Claim 1:
    • A bowling centre system comprising a bowling lane, pins, strings, a constrain system, and a pulley system.
    • The pulley system includes a motor-driven drawbar movable between a first position (to lift pins) and a second position (to lower pins and release a "first working length" of string).
    • A control device for controlling the drawbar's position.
    • A "control, drive and selection system" configured to allow the drawbar to move to "at least a third alternative operating game position," allowing the string to be slackened by releasing a "further, second working length" different from the first.
  • Independent Claim 12:
    • A bowling centre system comprising pins, strings, a constrain system, and a pulley system with a movable drawbar.
    • A control device controlling the drawbar's position in a first operating position (pins lifted), a second operating position (pins lowered with a "first working length" of slack), and a "third operating position in which the string is further slackened."
    • A "control, drive and selection system" configured to allow the drawbar to move to the third operating position.

III. The Accused Instrumentality

Product Identification

  • The accused instrumentality is Defendant’s "Boost ST String Pinsetter" when used in combination with its "360 Controller," which allegedly provides a feature called "Precise String-Length Optimization (PSO)" (Compl. ¶13, ¶16). The complaint collectively refers to these as the "Accused Product" (Compl. ¶18).

Functionality and Market Context

  • The complaint alleges the Boost ST pinsetter includes a motor-driven carriage (equivalent to the patent's drawbar) and a pulley system to manage the pin strings (Compl. ¶14). The key accused functionality resides in the 360 Controller and its PSO feature, which is alleged to be "configured to allow the string pinsetter to lengthen the working length of the string when the pins are set on the bowling lanes" (Compl. ¶16). A screenshot of the 360 Controller's user interface is provided, showing a setting for "USBC String Length," which Plaintiff contends enables the infringing variable string length functionality (Compl. p. 8, ¶30). The complaint asserts that Defendant sells these systems for new bowling center installations and as retrofits or software updates for existing pinsetters (Compl. ¶11, ¶16). A technical diagram from what is described as an "Operation Manual for a Boost ST" is included to illustrate the mechanical components of the accused system (Compl. p. 4, ¶14).

IV. Analysis of Infringement Allegations

U.S. Patent No. 12,138,527 Infringement Allegations (Claim 1)

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a motor driven drawbar, movable along a predetermined path The accused Boost ST pinsetter includes a "motor driven carriage (e.g., moveable drawbar)" that is "movable along a predetermined path." ¶14, ¶15, ¶29 col. 3:14-17
the drawbar being movable between a first position ... and a second operating game position, allowing ... each string to be slackened by the release of a further first working length The accused drawbar is movable between a "first position of game preparation" (pins lifted) and a "second operating game position" (pins lowered and slackened). ¶15, ¶29 col. 3:18-28
a control device for controlling the position of the movable drawbar The accused system includes a "control for controlling the position of the movable drawbar," which can be mechanical, electrical, or software components. ¶30 col. 3:30-32
a control, drive and selection system...configured to allow the movable drawbar to move...to at least a third alternative operating game position...allowing the string to be slackened by the release of a further, second working length different from the first working length The accused "360 Controller" with "PSO" allegedly allows the drawbar to move to a third position, releasing a different, second working length of string. This functionality is allegedly enabled via the controller's user interface. ¶17, ¶31 col. 3:33-41

U.S. Patent No. 12,138,527 Infringement Allegations (Claim 12)

Claim Element (from Independent Claim 12) Alleged Infringing Functionality Complaint Citation Patent Citation
a drawbar movable along a predetermined path and operatively configured to manage a predetermined length of each string The accused pinsetter includes a "motor driven drawbar...movable along a predetermined path and operatively configured to manage a predetermined length of each string." ¶39, ¶40 col. 6:53-57
a control device controlling the position of the movable drawbar along the predetermined path in a first operating position...a second operating position...and a third operating position in which the string is further slackened The accused system's control allegedly controls the drawbar in three operating positions corresponding to lifted pins, lowered pins with a first slack length, and lowered pins with a further slackened string. ¶41 col. 6:58-col. 7:4
a control, drive and selection system connected to the movable drawbar and to the control device and configured to allow the movable drawbar to move...to the third operating position The "360 Controller" is alleged to be the control system that allows the drawbar to move to the third position to further slacken the strings, as shown in the user interface screen. ¶41 col. 7:5-9
  • Identified Points of Contention:
    • Scope Questions: A central dispute may concern the meaning of "third alternative operating game position." The defense could argue that a software-based setting for a single operating mode, as suggested by the screenshot of the "360 Controller" (Compl. p. 12, ¶41), does not constitute a distinct physical "position" of the drawbar as contemplated by the patent. The question is whether a software-selectable parameter that results in a different string length is equivalent to the claimed "third... position."
    • Technical Questions: The complaint alleges that the 360 Controller and PSO feature cause the "motor driven carriage to move... to at least a third alternative operating game position" (Compl. ¶17). A key factual question will be what the accused system actually does. Does the PSO feature operate by physically moving the drawbar to a different resting point, or does it achieve variable slack through an alternative mechanism not described in the complaint, such as a different component or a change in the timing of the string release?

V. Key Claim Terms for Construction

  • The Term: "third alternative operating game position" (Claim 1) and "third operating position" (Claim 12)
  • Context and Importance: This term is the central feature of the asserted independent claims and the alleged point of novelty over the prior art. The outcome of the infringement analysis will likely depend on whether the accused product's functionality falls within the court's construction of this term.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: Plaintiff may argue that "position" should be interpreted functionally to mean any state or configuration of the system that results in the release of a "second working length" of string. The patent claims a "system," which includes the "electronic/computerized" control system, suggesting the specific position can be defined by software commands, not just a mechanical stop (’527 Patent, col. 3:42-44).
    • Evidence for a Narrower Interpretation: Defendant may argue that "position" refers to a distinct physical location along the drawbar's path of travel. The specification repeatedly describes the drawbar as being "movable along a predetermined path" and reaching "different positions along its predetermined path," suggesting a focus on physical movement and location (’527 Patent, col. 3:14-15; col. 4:49-50). The patent figures appear to show the drawbar (6) in physically different locations to achieve different string lengths (e.g., comparing FIG. 2 and FIG. 4).

VI. Other Allegations

  • Indirect Infringement:
    • The complaint alleges contributory infringement, stating that Defendant’s Boost ST Pinsetter and 360 Controller are material parts of the patented invention, are not staple articles of commerce, and have no substantial non-infringing uses (Compl. ¶49, ¶51, ¶54, ¶56).
    • Inducement is alleged based on Defendant having knowledge of the patent since at least March 2025 and actively encouraging infringement by providing product manuals and instructions for using the accused features (Compl. ¶59-60).
  • Willful Infringement: The complaint alleges willful infringement based on Defendant's alleged continuation of infringing activities despite having actual knowledge of the ’527 Patent. This knowledge is alleged to have been established via a written notice from Plaintiff in March 2025, as well as by the filing of the complaint itself (Compl. ¶21-22, ¶36).

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

  1. A core issue will be one of claim construction: does the term "third... operating... position," as used in the patent, require the system’s drawbar to physically move to and rest at a distinct spatial location, or can it be construed more broadly to cover any software-enabled configuration that results in a different amount of string slack?
  2. A key evidentiary question will be one of technical operation: does the accused "Precise String-Length Optimization" feature in Brunswick's 360 Controller actually function by causing the pinsetter's drawbar to move to different physical positions as the patent appears to describe, or does it achieve variable string length through a different, potentially non-infringing, mechanism?