MCP IP LLC v. Velocity Outdoor Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: MCP IP, LLC (South Dakota)
  • Defendant: Velocity Outdoor Inc. (Delaware)
  • Plaintiff’s Counsel: Fish & Richardson P.C.
• Case Identification: 3:25-cv-00734, D. Del., 07/25/2024
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant Velocity Outdoor Inc. is incorporated in Delaware.
• Core Dispute: Plaintiff alleges that Defendant’s Ravin brand crossbows infringe three patents related to crossbow cabling systems and wide-ratio limb designs.
• Technical Context: The dispute centers on the mechanical design of high-performance compound crossbows, a market where innovations in efficiency, power, and reliability are significant.
• Key Procedural History: The complaint does not reference any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history involving the asserted patents.

Case Timeline

Date	Event
2017-02-09	Priority Date for U.S. Patent Nos. 11,796,277 and 12,000,668
2017-02-10	Priority Date for U.S. Patent No. 12,000,669
2023-10-24	U.S. Patent No. 11,796,277 Issued
2024-06-04	U.S. Patent No. 12,000,668 Issued
2024-06-04	U.S. Patent No. 12,000,669 Issued
2024-07-25	Complaint Filed

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

U.S. Patent No. 11,796,277 - "Archery Bow with Pass Through Cabling" (issued Oct. 24, 2023)

The Invention Explained

• Problem Addressed: The patent's background section notes a continuing need in the field of compound archery bows for "higher performing" designs that offer "high speed shooting using novel structures that are more accurate, lighter in weight and/or more reliable that prior designs" (’277 Patent, col. 1:19-24).
• The Patented Solution: The invention describes a rotatable member (cam) for a crossbow that includes a "pass-through aperture" allowing a power cable to be routed from one side of the cam to the other (’277 Patent, col. 4:56-65; Abstract). This configuration allows a single cable to engage with cable tracks on both sides of the cam, which may improve balance and operational efficiency as the bowstring is drawn and released. Figure 6 of the patent illustrates a crossbow (10) incorporating rotatable members (20, 26) with these pass-through apertures (40, 40b) (’277 Patent, Fig. 6).
• Technical Importance: This pass-through cabling design represents an approach to managing the forces within a compound bow's cam system, potentially enabling more compact or efficient designs.

Key Claims at a Glance

• The complaint asserts independent Claim 1 (Compl. ¶26).
• Essential elements of Claim 1 include:
  • A crossbow with a frame, first and second limbs, a bowstring, a stock, a latch, and a trigger.
  • A first rotatable member with a first side, a second side, a bowstring track, a first cable track on the first side, and a second cable track on the second side.
  • First and second cable segments engaged with the second limb and the first rotatable member, with the segments oriented to the first and second sides of the rotatable member, respectively.
  • A biasing mechanism supported by the stock that biases the first cable segment away from a shooting axis.
  • A concluding "wherein" clause stating that the first and second cable tracks take up the first and second cable segments, respectively, as the bowstring is drawn.
• The complaint states that Velocity has infringed "one or more claims of the '277 patent, including but not limited to Claim 1," reserving the right to assert additional claims (Compl. ¶24).

U.S. Patent No. 12,000,668 - "Archery Bow with Pass Through Cabling" (issued June 4, 2024)

The Invention Explained

• Problem Addressed: Similar to the ’277 Patent, the ’668 Patent addresses the general need for more accurate, lightweight, and reliable high-performance compound bows (’668 Patent, col. 1:21-26).
• The Patented Solution: This invention claims a specific crossbow cabling architecture involving four distinct cable segments. The first and third segments are oriented "above the bowstring plane," while the second and fourth segments are oriented "below the bowstring plane" (’668 Patent, Abstract; col. 8:8-25). This arrangement creates a specific geometric relationship between the power cables and the path of the bowstring, which may contribute to stability and consistent performance. The abstract describes this symmetric routing of cables above and below the bowstring plane.
• Technical Importance: The claimed configuration offers a particular solution for cable management in a compound crossbow, potentially to control cam lean or ensure balanced force distribution during the draw cycle.

Key Claims at a Glance

• The complaint asserts independent Claim 1 (Compl. ¶40).
• Essential elements of Claim 1 include:
  • A crossbow with a stock, first and second limb assemblies supporting first and second rotatable members, a bowstring defining a bowstring plane, a latch, and a trigger.
  • The first rotatable member has a first and second cable track; the second rotatable member has a third and fourth cable track.
  • A first cable segment engaged with the first cable track and oriented above the bowstring plane, attached to the second limb assembly.
  • A second cable segment engaged with the second cable track and oriented below the bowstring plane, attached to the second limb assembly.
  • A third cable segment engaged with the third cable track and oriented above the bowstring plane, attached to the first limb assembly.
  • A fourth cable segment engaged with the fourth cable track and oriented below the bowstring plane, attached to the first limb assembly.
• The complaint reserves the right to assert claims beyond Claim 1 (Compl. ¶38).

U.S. Patent No. 12,000,669 - "Archery Bow With Wide Ratio Limb" (issued June 4, 2024)

Technology Synopsis

This patent addresses the high stresses placed on the flexible limbs of an archery bow (’669 Patent, col. 1:17-20). The invention is directed to a crossbow limb assembly with a specific geometric ratio, claiming a limb assembly where its "width is at least 26% of the length" (’669 Patent, Claim 1). This wide-ratio design may allow for reduced material thickness while maintaining strength, potentially reducing stress and improving durability.

Asserted Claims

The complaint asserts independent Claim 1 (Compl. ¶54).

Accused Features

Plaintiff alleges that the limb assemblies of the Accused Products embody the wide-ratio limb geometry claimed in the ’669 Patent (Compl. ¶21, ¶52-54).

III. The Accused Instrumentality

Product Identification

The complaint identifies the "Ravin R500 and R50X crossbows" as the "Accused Products" (Compl. ¶21).

Functionality and Market Context

The complaint alleges that Defendant Velocity Outdoor Inc., itself or through its wholly owned subsidiary Ravin Crossbows, LLC, designs, manufactures, and sells these crossbows in the United States (Compl. ¶19, ¶21). The complaint does not provide specific technical details about the operation of the Accused Products beyond the allegation that they practice the inventions of the Asserted Patents.

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint. The complaint states that claim charts illustrating the alleged infringement are attached as Exhibits D, E, and F; however, these exhibits were not included with the filed complaint document (Compl. ¶26, ¶40, ¶54). Consequently, the infringement analysis is based on the narrative allegations in the complaint.

U.S. Patent No. 11,796,277 Allegations

• The complaint alleges that the Accused Products directly infringe at least Claim 1 of the ’277 Patent (Compl. ¶26). It does not, however, provide a narrative breakdown of how each element of the claim is met by the accused crossbows, instead referring to the unattached Exhibit D. The core of the infringement allegation is that the Ravin R500 and R50X crossbows incorporate all elements of the claimed crossbow, including the dual-track rotatable member and the biasing mechanism for a cable segment (Compl. ¶26).
• Identified Points of Contention:
  • Scope Question: A potential dispute may arise over the definition of a "biasing mechanism." The question for the court could be whether the accused crossbows contain a structure that performs the claimed function of "biasing the first cable segment away from a shooting axis" under the proper construction of that term.
  • Technical Question: A key factual question will be whether the accused crossbows' rotatable members have distinct first and second cable tracks that "take up" the respective first and second cable segments in the manner required by the claim's final "wherein" clause.

U.S. Patent No. 12,000,668 Allegations

• The complaint alleges that the Accused Products infringe at least Claim 1 of the ’668 Patent, again referring to an unattached exhibit (Exhibit E) for detailed mapping (Compl. ¶40). The infringement theory posits that the Accused Products possess the four-segment cabling system with the specific orientations relative to the bowstring plane and the specific limb assembly attachment points recited in the claim.
• Identified Points of Contention:
  • Technical Question: A central factual issue will be whether the cabling system of the Accused Products is arranged with distinct segments "oriented above the bowstring plane" and "oriented below the bowstring plane" as claimed. This may depend on how the "bowstring plane" is defined and where the measurements are taken.
  • Scope Question: The claim requires cable segments to be "attached to the... limb assembly." The nature of this attachment—whether direct or indirect—and whether the accused devices meet this limitation could become a point of legal and factual dispute.

V. Key Claim Terms for Construction

For the ’277 Patent

• The Term: "biasing mechanism" (from Claim 1)
• Context and Importance: This is a functional term, and its scope will be critical to the infringement analysis. A narrow construction might limit the claim to specific disclosed structures, while a broader one could cover a wider range of cable management systems. Practitioners may focus on this term because the specification provides a specific example—a "cable slider" (’277 Patent, col. 6:11-19)—which could be used to argue for a narrower scope than the plain language might suggest.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term itself is general, and Claim 1 does not recite any specific structure for the mechanism, which may support an argument for a broad, functional definition.
  • Evidence for a Narrower Interpretation: The specification discloses a "cable slider 39" as an embodiment of the "biasing mechanism 38" (’277 Patent, col. 6:11-19). This specific example could be used to argue that the term should be construed as being limited to such slider-type structures.

For the ’668 Patent

• The Term: "bowstring plane" (from Claim 1)
• Context and Importance: The spatial orientation of all four claimed cable segments is defined relative to this plane. The definition of this term is fundamental to determining infringement, as it establishes the geometric reference for the "above" and "below" limitations.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term is descriptive and may be argued to have a plain and ordinary meaning in the context of archery—the two-dimensional plane defined by the bowstring's path of travel.
  • Evidence for a Narrower Interpretation: The patent specification states that the bowstring defines the plane, and figures such as Fig. 18 depict a "central plane 24" that appears to align with the bowstring, suggesting a precise geometric construct (’668 Patent, Claim 1; Fig. 18). An argument could be made that the "plane" must be a static, perfectly flat plane, which may not exist in a dynamic, real-world device.

VI. Other Allegations

• Indirect Infringement: For all asserted patents, Plaintiff alleges induced infringement, stating that Velocity provides instructions and marketing materials (e.g., websites, YouTube videos, advertisements) that encourage and facilitate direct infringement by customers (Compl. ¶27, ¶41, ¶55). The complaint also alleges contributory infringement by selling components of the Accused Products, such as frames, limbs, and rotatable members, that are not suitable for substantial non-infringing use (Compl. ¶29, ¶43, ¶57).
• Willful Infringement: The complaint alleges willful infringement for all three patents. The basis for this allegation is knowledge of the patents "at least as of the date Velocity was served with or otherwise notified of this Complaint," suggesting the claim is based on alleged post-suit continuation of infringement rather than pre-suit knowledge (Compl. ¶32, ¶46, ¶60).

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

This dispute appears to center on specific mechanical and geometric features of modern crossbows. The resolution of the case may turn on the following key questions:

• A core issue will be one of claim construction and scope: How will the court define the functional term "biasing mechanism" from the ’277 Patent and the geometric term "bowstring plane" from the ’668 Patent? The breadth of these definitions will likely determine the outcome of the infringement analysis for those patents.
• A second key question will be one of evidentiary proof and measurement: For the ’669 Patent, can Plaintiff prove that the accused crossbow limbs meet the precise geometric requirement of having a width that is "at least 26% of the length"? This will likely involve expert testimony regarding the proper methodology for measuring these complex components.
• Finally, a significant factual and technical question will be whether the complex, multi-segment cabling systems of the accused Ravin crossbows operate in a way that maps onto the specific elements of the asserted claims in the ’277 and ’668 patents, particularly concerning how cables are routed, oriented, and "taken up" by the cams during operation.