Xiamen Disdeer Outdoor Sports Co Ltd v. FeraDyne Outdoors LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Xiamen Disdeer Outdoor Sports Co., Ltd. (China)
  • Defendant: FeraDyne Outdoors, LLC (Wisconsin)
  • Plaintiff’s Counsel: West Atlantic Law Firm, PLLC
• Case Identification: 3:25-cv-00381, W.D. Wis., 01/28/2026
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is a Wisconsin corporation that directs business activities to the state, and a substantial part of the events giving rise to the claim, specifically Defendant's patent enforcement actions via Amazon.com, occurred in the judicial district.
• Core Dispute: Plaintiff seeks a declaratory judgment that its lighted arrow nocks do not infringe Defendant's patent and that the patent is invalid, filed in response to Defendant's patent infringement accusations made through Amazon's intellectual property enforcement program.
• Technical Context: The technology relates to illuminated nocks for archery arrows, which are designed to help archers see an arrow's trajectory and locate it after a shot.
• Key Procedural History: The dispute began when Defendant submitted an infringement complaint against Plaintiff to Amazon on or about April 23, 2025, which prompted Plaintiff to file this declaratory judgment action.

Case Timeline

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

U.S. Patent No. 8,758,177 - Device and Method for Illuminating an Arrow Nock

• Patent Identification: U.S. Patent No. 8,758,177, issued on June 24, 2014 (the "’177 Patent").

The Invention Explained

• Problem Addressed: The patent’s background section details numerous drawbacks with prior art lighted nocks, including unreliable activation, the need for pre-shot activation that could alert game, complex installation requiring magnets or special backstops, and insufficient brightness from chemical light sources (’177 Patent, col. 1:47 - col. 3:17). Specifically, some designs would turn off upon impact or required electrically conductive arrows, limiting their use and reliability ’177 Patent, col. 2:50-67
• The Patented Solution: The invention is an arrow nock containing a self-contained light source assembly (power source, light source, and switch) that is activated by the force of the bowstring upon release ’177 Patent, Abstract The nock is designed with a slot having a first, shallower portion to hold the bowstring when drawn, and a second, deeper portion into which the bowstring moves upon release. This movement causes the bowstring to physically contact and actuate a protruding part of the internal switch, completing the circuit and illuminating the nock at the moment of the shot ’177 Patent, col. 4:46-54; Fig. 2
• Technical Importance: This design provides for an automatic and reliable illumination that occurs precisely at the moment of firing, which avoids alerting animals with a pre-lit nock and does not require external components or special arrow preparation ’177 Patent, col. 3:15-19

Key Claims at a Glance

• The complaint seeks a declaratory judgment of non-infringement of "any valid and enforceable claim of the ‘177 patent" Compl. ¶30 The patent’s independent claims are 1, 5, 9, 13, 17, 20, and 23. Claim 1 is representative of the core apparatus.
• Independent Claim 1 requires:
  • A nock body with an arrow attachment portion and a "proximate end" for the bowstring.
  • The proximate end has a first and second "arcuately shaped portion" to receive a bowstring in a drawn position.
  • The proximate end has a distinct third and fourth "arcuately shaped portion" to receive the bowstring after it is released.
  • A light source assembly (power source, light source, switch) inside the nock body.
  • The light source is not activated when the bowstring is in the first/second portions but is activated when it moves into the third/fourth portions.
  • A part of the light source assembly "protrudes into the proximate end" to be contacted by the bowstring.

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused products as "Plaintiff's lighted nocks," referred to as the "Non-Infringing Product" Compl. ¶3 The complaint lists numerous Amazon Standard Identification Numbers (ASINs) corresponding to these products Compl. ¶18, ¶29

Functionality and Market Context

The complaint does not provide any technical description of how the accused lighted nocks operate or are constructed. It only alleges that they are sold on the Amazon marketplace and that these sales constitute a "significant portion of Plaintiff's business" Compl. ¶17

IV. Analysis of Infringement Allegations

The complaint does not contain an affirmative infringement theory or claim chart, as it is an action for declaratory judgment of non-infringement. It makes only the conclusory allegation that its products "do not infringe the '177 Patent because none of the Non-Infringing Products possess all the elements and limitations of any claim" Compl. ¶26 Without technical details on the accused products' functionality, a direct comparison to the patent claims is not possible based on the complaint alone.

No probative visual evidence provided in complaint.

Identified Points of Contention

Based on the patent’s claims, the central dispute over infringement will likely involve two key questions:

• Structural Question: Do the accused nocks feature the specific two-stage slot geometry required by claim 1, comprising distinct first/second and third/fourth "arcuately shaped portions" for holding the bowstring in its drawn versus released positions?
• Functional Question: What is the activation mechanism of the accused nocks? Specifically, do they employ a mechanism where the bowstring’s movement upon release causes it to physically contact and actuate a "protruding" portion of an internal light assembly, as claimed in the ’177 Patent?

V. Key Claim Terms for Construction

"a third arcuately shaped portion and a corresponding fourth arcuately shaped portion adapted to receive the bowstring after the bowstring is released"

• Context and Importance: This term is critical because it defines the specific physical structure within the nock's slot that enables the patented activation-on-release function. The infringement analysis will likely turn on whether the accused products' nock slots possess this claimed two-stage geometry.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes this area more generally as a "second portion 32 where the bowstring moves to after the archer releases the bowstring" ’177 Patent, col. 4:50-52 A party could argue that any nock slot that deepens to allow the bowstring to travel further inward upon release meets the functional spirit of this limitation, even if it lacks four distinctly delineated arcuate shapes.
  • Evidence for a Narrower Interpretation: The claim language itself is highly specific, reciting four distinct portions. The patent figures show a clear structural difference between the initial placement area for the bowstring (30) and the deeper activation area (32) ’177 Patent, Fig. 2 A party may argue this requires two physically distinct pairs of carved-out arcs within the nock slot.

"at least a portion of the light source assembly protrudes into the proximate end"

• Context and Importance: This limitation defines the direct mechanical interface between the bowstring and the internal electronics. Practitioners may focus on this term because infringement requires a finding that a physical part of the internal assembly extends into the nock opening to be actuated by the string.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The "light source assembly" is defined in the claim as comprising the power source, light source, and switch. An argument could be made that any part of these three components extending into the nock slot—such as the switch actuator or a push rod—satisfies the "protrudes" limitation ’177 Patent, col. 11:13-14
  • Evidence for a Narrower Interpretation: The embodiments consistently depict a distinct, movable component, such as the "slide switch 70" or "push rod 273," as the protruding element that is physically moved by the bowstring ’177 Patent, col. 5:26-30; col. 7:1-6 This could support an interpretation that the limitation requires a dedicated actuator, rather than just an edge of the overall assembly's housing being near the bowstring.

VI. Other Allegations

Indirect Infringement

The complaint makes a defensive assertion that "Plaintiff alone does not perform all the steps recited the claims of the '177 patent as is required for direct infringement," which may be a preemptive defense against allegations of infringing the patent’s method claims Compl. ¶32 No specific facts are alleged to support this.

Willful Infringement

As a declaratory judgment plaintiff, Disdeer does not allege willfulness. Instead, it seeks a judgment that the case is "exceptional" under 35 U.S.C. § 285, entitling it to attorneys' fees, on the grounds that Defendant's infringement accusations are "baseless" Compl. ¶34; Prayer ¶4

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

• A central issue will be one of mechanical operation: Does the Plaintiff's "Non-Infringing Product" use the specific activation mechanism of the ’177 Patent? The case will likely require a detailed factual analysis of whether the accused nocks are activated by the physical movement of the bowstring into a deeper portion of the nock slot, causing it to directly engage a protruding part of the internal electronics.
• A second core issue will be one of invalidity, likely focused on obviousness: Plaintiff has alleged the ’177 Patent is invalid over prior art Compl. ¶38 The key question for the court will be whether the claimed combination of a two-stage nock slot and a string-activated internal switch would have been obvious to a person of ordinary skill in the art at the time of the invention, given the existing landscape of lighted nocks with different activation systems.