PTAB

IPR2023-00407

Hunter's Mfg Co Inc v. Ravin Crossbows LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: String Guide System for a Bow
  • Brief Description: The ’015 patent describes a crossbow with a string guide system. The system uses a pair of rotatable string guides, each comprising a draw string journal and a "helical power cable take-up journal" that extends perpendicularly to the plane of rotation of the draw string journal, allowing power cables to be displaced axially as they wrap.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claim 1 by Stanziale ’302

  • Prior Art Relied Upon: Stanziale ’302 (Application # 2012/0125302)
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Stanziale ’302 discloses every element of claim 1. Specifically, Stanziale ’302 teaches a crossbow with first and second pulley assemblies (claimed "string guides") that are mounted to the limbs and are rotatable. Crucially, Petitioner asserted that the examiner’s reason for allowance—the lack of a "helical power cable take-up journal" in the prior art of record—was incorrect. Stanziale ’302 explicitly discloses that its pulley assemblies have upper and lower pulleys with take-up journals (track 521) that "may have a spiral or helical shape so as to wind a plurality of turns of a flexible element." Petitioner contended these helical journals extend perpendicular to the plane of rotation of the draw string journal (track 511), thereby meeting the key limitation of claim 1.

Ground 2: Obviousness of Claim 1 over Darlington and Norkus

  • Prior Art Relied Upon: Darlington (Application # 2011/0030666) and Norkus (Patent 7,578,289)
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Darlington discloses a crossbow meeting every limitation 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 rotatable cams (string guides), each having a draw string journal and a power cable journal.
    • Motivation to Combine (for §103 grounds): Darlington teaches the desirability of achieving a "higher level of stored energy" and increased power stroke for better performance. Norkus teaches that a longer power stroke can be accomplished by enabling cams to rotate more than 360 degrees, which is achieved by using helical cable journals. Therefore, a POSITA seeking to increase the power stroke and energy storage of the Darlington crossbow would combine it with the helical cable journal design from Norkus.
    • Expectation of Success (for §103 grounds): A POSITA would have reasonably expected success in this combination, as Norkus explicitly links the use of helical journals to the goal of achieving a longer power stroke, the same goal articulated in Darlington.

Ground 3: Obviousness of Claim 1 over Kempf ’871 and Norkus

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

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Kempf ’871, similar to Darlington, discloses all elements of claim 1 except for the helical power cable journals. Kempf ’871 describes a reverse draw crossbow with string guides (pulley 28, cam 36) that include draw string journals and power cable take-up journals.
    • Motivation to Combine (for §103 grounds): Kempf ’871 discloses the goal of increasing a crossbow's draw length (power stroke) to increase its power and speed, while minimizing the axle-to-axle distance. As Norkus teaches using helical journals to achieve a longer power stroke, a POSITA would be motivated to apply the helical journals from Norkus to the Kempf ’871 crossbow to achieve the desired longer power stroke while maintaining a compact axle-to-axle distance.
    • Expectation of Success (for §103 grounds): A POSITA would have reasonably expected that incorporating Norkus's helical journals into the Kempf ’871 design would successfully increase the power stroke, as both references address the same mechanical principles in archery technology.

  • Additional Grounds: Petitioner asserted additional anticipation and obviousness challenges based on Stanziale ’062 (WO 2011/158062) and Stanziale ’771 (WO 2011/141771). Further obviousness grounds were asserted based on combinations including Kempf ’871 in view of Park (Application # 2012/0312287) or Stanziale ’302, and Islas (Application # 2011/0308508) in view of Darlington and Park, all relying on similar motivations to add helical journals to increase performance.

4. Key Claim Construction Positions

  • "helical power cable take-up journal": Petitioner proposed the construction "a helical structure that accepts at least one power cable." This construction relies on the plain meaning of "helical" and an agreed-upon definition for the non-helical portion of the term from the parallel district court litigation.
  • "mounted to": Petitioner argued this term should mean "connected to, either directly or indirectly." Petitioner contended that the Patent Owner’s proposed construction in district court, which requires rotation about a fixed axis and prohibits other movement, improperly imports limitations from the specification and would render other claim terms, such as "rotatable around a first axis," superfluous.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under Fintiv would be inappropriate. The parallel district court litigation was in its infancy, with no trial date set and discovery just beginning. Petitioner noted that the median time-to-trial in the district (D. Nev.) was 50.4 months, far exceeding the IPR statutory deadline. Petitioner also stipulated that it would not pursue in the parallel proceeding the same grounds raised in the petition or any grounds that could have reasonably been raised. Finally, Petitioner argued the petition presented a "compelling, meritorious challenge" because it presented multiple prior art references disclosing the very feature—the helical power cable take-up journal—that was the sole basis for the patent’s allowance.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claim 1 of the ’015 patent as unpatentable under 35 U.S.C. §§ 102 and/or 103.