PTAB

IPR2018-01137

Garmin International, Inc. v. Wisconsin Archery Products, LLC

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1. Case Identification

2. Patent Overview

  • Title: Auto-Correcting Bow Sight
  • Brief Description: The ’551 patent discloses an auto-correcting bow sight for archery. The system uses a range finder to determine the distance to a target and an inclinometer to measure the bow's angle, then automatically calculates and displays a precise aiming point to compensate for these factors.

3. Grounds for Unpatentability

Ground 1: Claims 1-2, 7-8, 12-13, 20, and 23-26 are obvious over Hargrove in view of Williams.

  • Prior Art Relied Upon: Hargrove (Patent 5,914,775) and Williams (Patent 6,079,111).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Hargrove discloses nearly all elements of the challenged claims. Hargrove teaches an auto-correcting bow sight with a processor, a point-to-point measuring device (range finder), an angle sensitive transducer (inclinometer), and a see-through LCD that displays a movable crosshair based on calculated distance and angle. Hargrove's system includes a manually actuated switch to begin the evaluation. However, Petitioner contended Hargrove only implicitly discloses actuating this switch while the bow is at a full draw.
    • Motivation to Combine (for §103 grounds): Petitioner asserted that Williams explicitly teaches the missing element: a manually actuated input device (trigger mechanism) arranged on the bow to allow an archer to make sight adjustments "while maintaining the bow...at full draw." A person of ordinary skill in the art (POSITA) would combine Williams’s full-draw actuation method with Hargrove’s advanced electronic sight to improve its functionality, as archers require the ability to make final sighting adjustments at the moment of the shot, which occurs at full draw. This combination represents the use of a known technique to improve a similar device for an expected and useful result.
    • Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success in this combination because it involves a simple and predictable modification. The switch in Hargrove is already located near the archer's hand, and modifying its placement or linkage for easier actuation at full draw, as taught by Williams, would be a routine design choice.

Ground 2: Claims 4-5, 9, and 21-22 are obvious over Hargrove in view of Williams and further in view of London.

  • Prior Art Relied Upon: Hargrove (Patent 5,914,775), Williams (Patent 6,079,111), and London (Patent 5,634,278).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds upon the combination of Hargrove and Williams and adds London to teach additional specific features. Petitioner argued that London discloses using a series of light-emitting diodes (LEDs) to project a single discrete aiming dot onto a sight glass (Claim 4, Claim 9). London also explicitly teaches the use of a conventional peep sight mounted on the bowstring for aligning the targeting sight with the target (Claim 5, Claim 21). Hargrove’s primary embodiment uses an LCD to generate a crosshair, not discrete LED dots.
    • Motivation to Combine (for §103 grounds): A POSITA would be motivated to substitute London's LED system for Hargrove's LCD to provide a sighting mechanism more familiar to archers (similar to a multiple-pin sight) and to gain significant power and weight savings. The motivation to add London's peep sight to the Hargrove/Williams combination is to incorporate a well-known, conventional archery accessory to improve aiming consistency and accuracy, a stated goal of the ’551 patent.
    • Expectation of Success (for §103 grounds): The proposed modifications would have been simple substitutions of known components into an existing system. Integrating an LED-based aiming point or adding a standard peep sight were predictable and well-understood design choices in the field of archery sights, promising a high likelihood of success.

4. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1-2, 4-5, 7-9, 12-13, and 20-26 of the ’551 patent as unpatentable.