Ravin Crossbows LLC v. MCP IP LLC

1. Case Identification

• Case #: IPR2024-00522
• Patent #: 8,683,989
• Filed: March 1, 2024
• Petitioner(s): Ravin Crossbows, LLC
• Patent Owner(s): MCP IP, LLC
• Challenged Claims: 1-4 and 7-19

2. Patent Overview

• Title: Adjustable Compound Archery Bow
• Brief Description: The ’989 patent describes a compound archery bow featuring rotatable cam members designed to provide an adjustable range of draw weights and lengths. The invention focuses on a specific cam configuration, including the routing of a power cable around a capstan and its attachment to a terminal, to control the bow's performance characteristics.

3. Grounds for Unpatentability

Ground 1: Claims 1-4 and 7-19 are obvious over Darlington in view of Islas.

• Prior Art Relied Upon: Darlington (Patent 8,205,607) and Islas (Application # 2008/0135032).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Darlington, which was not considered during prosecution, discloses a compound bow with nearly all elements of the challenged claims. This includes a riser, limbs, first and second rotatable members (pulleys), a drawstring track, a cam track, a capstan (intermediate post 72), and a terminal (anchor 56). Darlington also teaches that its drawstring and cam tracks are in offset planes. The key difference is that in Darlington’s design, the power cable wraps around the capstan in the same rotational direction that the pulley rotates when drawn. The ’989 patent claims require the power cable to wrap in a direction opposite to the pulley's rotation when drawn (limitation 1(f)). Petitioner asserted that Islas teaches this exact opposite-direction wrapping configuration.
  • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine the teachings of Islas with Darlington’s bow design for three primary reasons:
    • 1. Improved Safety and Reduced Wear: Modifying Darlington to have the power cable wrap outwardly, as taught by Islas, would increase the separation between the power cable and other components of the pulley. This would reduce the likelihood of cable contact, entanglement, abrasion, and fraying, thereby increasing the bow's safety and the longevity of the power cable.
    • 2. Simplified Design and Lower Cost: The proposed modification would eliminate the need for certain structural features of the Darlington cam (e.g., section 42), simplifying the design and reducing manufacturing costs.
    • 3. Enhanced Performance: The ’989 patent itself states that an opposite-wrapping configuration provides for "added draw capability." A POSITA would recognize that eliminating potential obstructions by re-routing the cable outwardly would allow for a greater maximum angular sweep of the pulley, increasing the maximum arrow velocity for a given cam size.
  • Expectation of Success: Petitioner contended a POSITA would have a high expectation of success. The proposed modification was not a complex redesign but a minor reconfiguration of existing components. Darlington itself teaches that its components, such as the draw length modules and the capstan post, are adjustable and replaceable, expressly inviting a POSITA to make such modifications to achieve a desired draw profile. The physical components needed were already present in Darlington, and the modification was a predictable implementation of known archery principles taught by Islas.
  • Key Aspects: The core of the challenge rests on modifying Darlington by applying the specific power cable wrapping direction from Islas. Petitioner argued this modification would render obvious not only the main independent claims (1, 11, 12, 19) but also the dependent claims, which relate to predictable consequences of this modification. For example, claim 1(g), which requires the axle and terminal to be on opposite sides of a plane defined by the power cable, was argued to be a direct and obvious result of re-routing the cable to wrap outwardly per Islas. Similarly, for claim 10, Petitioner argued a POSITA would be motivated to incorporate weight-reducing "cutouts" taught by Islas into Darlington's pulleys to create a lighter, easier-to-handle bow, which is a common design goal in the field.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under Fintiv is inappropriate. Although the scheduled trial date in a parallel district court case (February 24, 2025) is before the statutory deadline for a Final Written Decision (FWD), other factors strongly favor institution. Petitioner asserted that it intends to seek a stay in the district court litigation. Furthermore, investment in the parallel proceeding has been minimal, with no depositions taken and dispositive motions not yet due. Crucially, Petitioner stipulated that if the IPR is instituted, it will not pursue the same invalidity grounds in the district court. Petitioner concluded that the compelling nature of its unpatentability challenge weighs heavily in favor of institution.

5. Relief Requested

• Petitioner requests the institution of an inter partes review and the cancellation of claims 1-4 and 7-19 of the ’989 patent as unpatentable.