Ravin Crossbows, LLC v. Squires

Court of Appeals for the Federal Circuit·Decided August 6, 2026·No. 24-2136·Unpublished

Opinion

NOTE: This disposition is nonprecedential.

United States Court of Appeals for the Federal Circuit

RAVIN CROSSBOWS, LLC,

Appellant

v.

JOHN A. SQUIRES, UNDER SECRETARY OF COMMERCE FOR INTELLECTUAL PROPERTY AND DIRECTOR OF THE UNITED STATES PATENT AND TRADEMARK OFFICE, Intervenor

2024-2136

Appeal from the United States Patent and Trademark Office, Patent Trial and Appeal Board in No. IPR2023- 00407.

Decided: August 6, 2026

KADIE M. JELENCHICK, Foley & Lardner LLP, Milwaukee , WI, argued for appellant. Also represented by MICHELLE A. MORAN, SARAH E. RIEGER.

MONICA BARNES LATEEF, Office of the Solicitor, United 2 RAVIN CROSSBOWS, LLC V. SQUIRES

States Patent and Trademark Office, Alexandria, VA, argued for intervenor. Also represented by JUSTIN BOVA, NICHOLAS THEODORE MATICH, IV.

Before MOORE, Chief Judge, CUNNINGHAM, Circuit Judge, and KOVNER, District Judge. 1 MOORE, Chief Judge.

Ravin Crossbows, LLC (Ravin) appeals a final written decision of the Patent Trial and Appeal Board (Board) holding claim 1 of U.S. Patent No. 9,354,015 unpatentable. For the following reasons, we affirm.

BACKGROUND

Ravin owns the ’015 patent, which relates to archery bows and crossbows, wherein rotatable string guides are in tension with the draw string that drives an arrow. ’015 patent at Abstract, 1:66–2:23. Claim 1 is at issue:

1. A crossbow, comprising: a central portion comprising a down-range side and an up-range side; first and second flexible limbs attached to the central portion; a first string guide mounted to the first bow limb and rotatable around a first axis, the first string guide comprising a first draw string journal having a first plane of rotation perpendicular to the first axis, and a first helical power cable take-up journal

1 Honorable Rachel P. Kovner, District Judge, United States District Court for the Eastern District of New York, sitting by designation.

RAVIN CROSSBOWS, LLC v. SQUIRES 3

extending in a direction perpendicular to the first plane of rotation of the first draw string journal; a second string guide mounted to the second bow limb and rotatable around a second axis, the second string guide comprising a second draw string journal having a second plane of rotation perpendicular to the second axis, and a second helical power cable take-up journal extending in a direction perpendicular to the second plane of rotation of the second draw string journal; a draw string received in the first and second draw string journals and secured to the crossbow in a reverse draw configuration with the draw string adjacent the down-range side of the string guides in a released configuration, wherein the draw string translates from the down-range side toward the up- range side and unwinds between the first and second string, guides to a drawn configuration; a first power cable received in the first helical power cable take-up journal; and a second power cable received in the second helical power cable take-up journal, wherein as the bow is drawn from the released configuration to the drawn configuration the first and second power cables wrap onto the first and second helical, power cable take-up journals and are displaced along the first and second axes away from the first and second planes of rotation of the first and second draw string journals, respectively.

Id. at 7:63–8:34 (emphases added).

Ravin sued Hunter’s Manufacturing Company, Inc.

dba TenPoint Crossbow Technologies (TenPoint) in the U.S. District Court for the District of Nevada for infringing six of Ravin’s crossbow patents. Ravin Crossbows, LLC v.

4 RAVIN CROSSBOWS, LLC V. SQUIRES

Hunter’s Mfg. Co., No. 5:23-CV-598, 2024 WL 895156, at *1 (N.D. Ohio Mar. 1, 2024) (Claim Construction Order). The case was transferred to the District Court for the Northern District of Ohio. Id. Ravin later voluntarily withdrew two asserted patents, including the ’015 patent. Id. Like claim 1 of the ’015 patent, several claims of the remaining asserted patents recite the “mounted to” limitation. Id. at *3. The parties disputed the meaning of “mounted to.” Id. at *3–5. The district court concluded “mounted to” did not require construction because the term was readily understood by a skilled artisan and should thus be given its plain and ordinary meaning. Id. at *5. The district court rejected the proposed constructions (i.e., “mounted to allow only rotation about a fixed axis” and “connected to, either directly or indirectly”) as unhelpful. Id. at *3–4.

After being sued for infringement, TenPoint filed a petition for inter partes review (IPR) challenging claim 1 of the ’015 patent as anticipated or obvious over the prior art. J.A. 68–135. The Board instituted IPR. J.A. 237–78. While acknowledging the district court’s claim construction order in the related litigation, the Board adopted Ten- Point’s proposed construction of “mounted to” to mean “connected to, either directly or indirectly” because both parties disputed the plain and ordinary meaning of the term. Hunter’s Mfg. Co. v. Ravin Crossbows, LLC, No. IPR2023- 00407, 2024 WL 3347293, at *8–10 (P.T.A.B. July 9, 2024) (Final Written Decision). The Board then held claim 1 unpatentable as anticipated by International Patent Application Publication No. WO 2011/141771 (Stanziale) without reaching any other grounds presented in TenPoint’s petition . Id. at *12–14. Ravin appealed, arguing the Board erred in its construction of “mounted to” and that under

RAVIN CROSSBOWS, LLC v. SQUIRES 5

Ravin’s proposed claim construction, 2 claim 1 would not have been anticipated by Stanziale. TenPoint withdrew from the appeal after the parties settled the underlying dispute , and the Director intervened to defend the Board’s decision . We have jurisdiction under 28 U.S.C. § 1295(a)(4)(A).

DISCUSSION

We review the Board’s claim construction and any supporting determinations based on intrinsic evidence de novo. Seabed Geosols. (US) Inc. v. Magseis FF LLC, 8 F.4th 1285, 1287 (Fed. Cir. 2021). Claim terms are generally given their plain and ordinary meaning, i.e., the meaning the terms would have to a skilled artisan at the time of the invention when read in the context of the specification and prosecution history. See Phillips v. AWH Corp., 415 F.3d 1303, 1312–13 (Fed. Cir. 2005) (en banc).

Ravin argues the Board erred in construing “mounted to” in claim 1 to mean “connected to, either directly or indirectly .” Appellant’s Br. 22–26; Final Written Decision, 2024 WL 3347293, at *10. According to Ravin, this construction is overbroad because it allows components to be mounted to one another no matter how far apart they are or how many components are between them. Appellant’s Br. 28–38. Ravin further argues the Board’s construction conflicts with the specification’s teachings that the string guide be able to rotate about an axis relative to the limb.

2 Ravin’s proposed construction before the Board differs slightly from its proposed construction before the district court. Compare Final Written Decision, 2024 WL 3347293, at *3 (“physically connected to allow only rotation about a fixed axis”), with Claim Construction Order, 2024 WL 895156, at *3 (“mounted to allow only rotation about a fixed axis”).

6 RAVIN CROSSBOWS, LLC V. SQUIRES

Appellant’s Br. 39–42. In Ravin’s view, the correct construction of “mounted to” is “physically connected to allow only rotation about a fixed axis.” Appellant’s Br. 40. The Director responds that the Board properly determined the plain and ordinary meaning of “mounted to” is “connected to, either directly or indirectly.” Intervenor’s Br. 20. The Director asserts the claim’s functional language constrains the meaning of “mounted to” such that force applied to the string guide affects the bow limb. Intervenor’s Br. 26–31; see also Oral Arg. at 14:10–15:04. We agree with the Director that claim 1’s structural limitations help define the scope of the claim.

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