PTAB

IPR2019-00380

Bowtech, Inc. v. MCP IP, LLC

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1. Case Identification

2. Patent Overview

  • Title: Balanced Pulley Assembly for Compound Archery Bows, and Bows Incorporating That Assembly
  • Brief Description: The ’281 patent describes a pulley assembly for a compound archery bow that includes a "cable controller." This controller is designed to modify the bow's operation to provide an improved force/draw profile and to make the pulley system inherently self-balancing.

3. Grounds for Unpatentability

Ground 1: Claims 1-2, 5-6, 8-10, and 12-21 are obvious over Mitchell in view of McPherson.

  • Prior Art Relied Upon: Mitchell (Patent 5,390,655) and McPherson (Patent 6,247,466).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Mitchell discloses a conventional dual-cam compound bow that includes nearly all elements of the challenged claims, such as a handle, limbs, two pulleys on pivot axes, a bow string, and two bow cables. Mitchell teaches yoking the bow cables and anchoring them to mounting brackets on the opposing pulley's axle. However, Mitchell lacks the claimed "cable controller." Petitioner asserted that McPherson remedies this deficiency by teaching a pulley assembly with a "cable controller" (termed a "secondary string feed-out") that is independently and rotatably mounted on the cam at a pivot point offset from the main pulley axle. This offset arrangement in McPherson causes the controller to produce the same function claimed in the ’281 patent: an initial "take-up" of the bow cable during the first part of the draw, followed by a "let-out" during the final phase. Petitioner contended that substituting Mitchell's simple cable anchor points with McPherson's functionally identical cable controller would arrive at the invention claimed in the ’281 patent. Dependent claims were argued to be obvious as they recite features also found in the combination, such as the controller being a pivotable member, a "rotatable collar," circular, and having a groove, all of which Petitioner mapped to features of the rotatable bosses taught by Mitchell.
    • Motivation to Combine (for §103 grounds): A person of ordinary skill in the art (POSITA) would have been motivated to combine the references for two primary reasons. First, a POSITA would incorporate McPherson's cable controller into Mitchell's dual-cam bow to achieve an improved force-draw profile and increase the energy stored in the bow, which are well-known and desirable goals in archery design. McPherson explicitly teaches that its controller design provides a "momentary shortening or 'take-up'" that increases energy storage potential. Second, a POSITA would have recognized the well-known difficulty in balancing and tuning dual-cam bows like Mitchell's, where cables are anchored to the opposing axle. A POSITA would have been motivated to replace Mitchell's anchor brackets with McPherson's cable controllers to introduce a self-balancing feature, thereby improving synchronization and reducing maintenance.
    • Expectation of Success (for §103 grounds): Petitioner argued that a POSITA would have had a reasonable expectation of success because the combination involved the simple substitution of one known component (Mitchell's anchor bracket) with another known component (McPherson's controller) to achieve the predictable functions of an improved force-draw profile and self-balancing. Both results were explicitly taught or suggested by McPherson as benefits of its controller design.

4. Key Claim Construction Positions

  • "rotatable collar": Featured in claims 5, 6, 9, and 13-21, Petitioner proposed this term should be construed as "a component that collars a rotation axis, is capable of receiving a bow cable or string, and is capable of rotating." This construction was argued to be critical for mapping the "rotatable bosses" taught in Mitchell, which are described as being "pulley shaped" and having grooves for receiving a cable, onto the claimed "rotatable collar" limitation. The Petitioner contended that during prosecution of the ’281 patent, the applicant acquiesced that similar limitations involving a "rotatable collar" were taught by McPherson.

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-2, 5-6, 8-10, and 12-21 of the ’281 patent as unpatentable.