Ravin Crossbows LLC v. MCP IP LLC

1. Case Identification

• Case #: IPR2024-00523
• Patent #: 9,354,017
• Filed: March 1, 2024
• Petitioner(s): Ravin Crossbows, LLC
• Patent Owner(s): MCP IP, LLC
• Challenged Claims: 1-6 and 9-20

2. Patent Overview

• Title: Compound Archery Bow with Adjustable Cam Configuration
• Brief Description: The ’017 patent discloses a compound archery bow featuring an adjustable cam system to modify draw weights and lengths. The invention centers on a rotatable member (cam) that includes a power cable, a cam track, a capstan, and a terminal post, configured to allow for user-specific adjustments.

3. Grounds for Unpatentability

Ground 1: Obviousness over Darlington in view of Islas - Claims 1-6 and 9-20 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 relates to a compound archery bow with adjustable pulleys, discloses all elements of independent claims 1 and 12 except for one key feature. Darlington teaches a rotatable member (pulley) with a cam track, a capstan (intermediate post), and a terminal (anchor). However, in Darlington's primary embodiment, the power cable wraps around the capstan in a clockwise direction, which is the same direction the pulley rotates when the bow is drawn. The ’017 patent claims require the power cable to wrap in a direction opposite to the pulley's rotation (e.g., counter-clockwise cable wrap for a clockwise pulley rotation). Petitioner asserted that Islas teaches this exact opposite-direction wrapping configuration. Therefore, a person of ordinary skill in the art (POSITA) would modify Darlington’s pulley system by incorporating the cable wrapping design from Islas to arrive at the claimed invention. Petitioner contended this combination renders obvious independent claims 1 and 12, as well as the additional limitations found in dependent claims 2-6 and 9-20, which relate to geometric arrangements, removable modules, and features of a second, mirrored rotatable member also taught by Darlington.
  • Motivation to Combine: Petitioner asserted a POSITA would combine the teachings of Darlington and Islas for three primary reasons. First, it would improve safety and longevity by creating more space between the power cable and other components, reducing the risk of cable entanglement, abrasion, and fraying. Second, the modification would simplify the bow’s design, allowing for the elimination of certain cam structures disclosed in Darlington (e.g., section 42), thereby reducing manufacturing costs. Third, adopting the Islas wrapping configuration would increase the maximum angular sweep of the pulley, which increases the potential draw capability and maximum arrow velocity for a given cam size, a known goal in the art.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining the references. The proposed modification was not complex, involving the relocation of the cable’s anchor point and capstan on the pulley body taught by Darlington. All necessary physical components were already present in Darlington, and any minor adjustments to component sizes or shapes to ensure operability would have been well within the skill of a POSITA.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under Fintiv would be inappropriate, asserting that the factors favor institution. While the parallel district court trial date (February 24, 2025) is scheduled before the statutory deadline for a Final Written Decision (FWD), Petitioner contended this is outweighed by other factors. Specifically, the parties have invested little in the parallel proceeding, and Petitioner stipulated that it will not pursue in district court any invalidity ground raised or that could have been raised in the IPR petition if instituted. Petitioner argued this stipulation resolves any concerns of duplicative effort and conflicting decisions. Finally, Petitioner asserted that the petition presents a compelling, meritorious unpatentability challenge that, on its own, warrants institution.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-6 and 9-20 of Patent 9,354,017 as unpatentable under 35 U.S.C. §103.