PTAB

IPR2023-00407

Hunter's MFG Co v. Ravin Crossbows LLC

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1. Case Identification

2. Patent Overview

  • Title: String Guide System for a Bow
  • Brief Description: The ’015 patent discloses a string guide system for a crossbow, particularly one with a reverse draw configuration. The system uses a pair of rotatable string guides mounted to the bow limbs, where each guide includes a draw string journal and a helical power cable take-up journal designed to displace the power cables along the axis of rotation as the bow is drawn.

3. Grounds for Unpatentability

Ground 1: Anticipation by Stanziale ’302 - Claim 1 is anticipated by Stanziale ’302 under 35 U.S.C. §102.

  • Prior Art Relied Upon: Stanziale ’302 (Application # 2012/0125302).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Stanziale ’302, which discloses an archery crossbow, teaches every element of claim 1. Specifically, Stanziale ’302 discloses a crossbow with string guides (pulley assemblies 50) mounted to the limbs, rotatable around an axis, and featuring a draw string journal (perimetral track 511). Crucially, Petitioner asserted that Stanziale ’302 explicitly discloses that its power cable take-up journals (perimetral track 521) may have a "spiral or helical shape" to wind multiple turns of a cable. This helical journal extends perpendicular to the plane of rotation of the draw string journal, directly teaching the key limitation that the Examiner found lacking in other prior art during prosecution. The reference also allegedly shows the required reverse draw configuration and the displacement of the power cables away from the draw string plane as the bow is drawn.
    • Key Aspects: This ground directly challenges the Examiner’s basis for allowance by presenting a single prior art reference that allegedly contains the specific "helical power cable take-up journal" feature.

Ground 2: Obviousness over Darlington and Norkus - Claim 1 is obvious over Darlington in view of Norkus under 35 U.S.C. §103.

  • Prior Art Relied Upon: Darlington (Application # 2011/0030666) and Norkus (Patent 7,578,289).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Darlington discloses a crossbow with all elements of claim 1 except for the helical nature of the power cable journals and the resulting axial displacement of the power cables. Darlington teaches a reverse draw crossbow with string guides (cams 102, 104) that have both draw string journals and power cable take-up journals. Norkus was introduced to supply the missing elements, as it discloses a bow cam with a planar bowstring journal and a helical journal for a power cable.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these references to improve performance. Darlington teaches the desirability of a "higher level of stored energy" and increased power stroke. Norkus teaches that using helical cable journals allows for greater cam rotation (e.g., 720 degrees), which achieves a longer power stroke. Therefore, a POSITA would be motivated to incorporate Norkus's helical journal design into Darlington's crossbow to increase its power stroke and energy storage.
    • Expectation of Success: The combination was argued to be a predictable application of known technologies, as both references relate to cam and pulley systems in archery, and the result of achieving a longer power stroke would be reasonably expected.

Ground 3: Obviousness over Kempf ’871 and Norkus - Claim 1 is obvious over Kempf ’871 in view of Norkus under §103.

  • Prior Art Relied Upon: Kempf ’871 (Patent 7,836,871) and Norkus (Patent 7,578,289).

  • Core Argument for this Ground:

    • Prior Art Mapping: This argument paralleled the one based on Darlington. Petitioner asserted that Kempf ’871, which discloses a reverse draw crossbow, teaches all elements of claim 1 except for the helical power cable journals. Norkus was again cited to supply this missing feature.
    • Motivation to Combine: The motivation was similar: Kempf ’871 discloses the desirability of increasing a crossbow’s draw length while minimizing its axle-to-axle distance. A POSITA would have recognized that applying the helical power cable journals from Norkus to the Kempf ’871 crossbow would achieve a longer power stroke (and thus greater speed) while maintaining or reducing the axle-to-axle distance, fulfilling the desired goals of Kempf ’871.
    • Expectation of Success: Success would be reasonably expected, as it involved combining known cam designs to achieve a well-understood benefit in the field of crossbows.

  • Additional Grounds: Petitioner asserted numerous additional grounds. These included anticipation and obviousness challenges based on Stanziale ’062 (WO 2011/158062) and Stanziale ’771 (WO 2011/141771), which were argued to similarly disclose all claim elements. Further obviousness grounds combined Darlington or Kempf ’871 with Park (Application # 2012/0312287) or Stanziale ’302, and combined Islas (Application # 2011/0308508) with Darlington and Park, all relying on similar motivations to increase power stroke and performance by incorporating known helical journal designs.

4. Key Claim Construction Positions

  • "helical power cable take-up journal": Petitioner argued this term should be construed as "a helical structure that accepts at least one power cable." This construction relies on the plain and ordinary meaning of the words and is consistent with the parties' agreement that a "power cable take-up journal" is "a structure that accepts at least one power cable."
  • "mounted to": Petitioner asserted this term should mean "connected to, either directly or indirectly." This is based on the specification's usage and illustrations. Petitioner argued against the Patent Owner's proposed construction ("mounted to allow only rotation about a fixed axis") because it improperly imports a functional limitation (rotation) and a negative limitation (prohibiting other movement) not present in the claim language. Arguing that the separate claim term "rotatable" would be rendered superfluous under the Patent Owner's construction.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under Fintiv is inappropriate. The parallel district court case was in its infancy, with no trial date set and minimal investment by the court or parties. Based on median time-to-trial statistics for the venue (D. Nev.), any trial would occur long after the IPR's final written decision (FWD) deadline. Petitioner also stipulated it would not pursue in the district court the same grounds raised in the IPR, or any grounds that could have reasonably been raised. Finally, Petitioner asserted the petition presented a "compelling, meritorious challenge" because it cited prior art teaching the key "helical journal" limitation, which the Examiner had not previously considered, making institution appropriate to correct a clear error.

6. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claim 1 of Patent 9,354,015 as unpatentable under 35 U.S.C. §§ 102 and/or 103.