CAFC Affirms PTAB Invalidation of Crossbow Patent, Rejects Patent Owner’s Narrow Claim Construction Argument

The U.S. Court of Appeals for the Federal Circuit (CAFC) issued a decision Thursday in Ravin Crossbows, LLC v. Squires, affirming a Patent Trial and Appeal Board (PTAB) final written decision that found claim 1 of U.S. Patent No. 9,354,015 unpatentable. The dispute centered on how the Board construed the claim term “mounted to” in an inter partes review (IPR) brought by Hunter’s Manufacturing Company, doing business as TenPoint Crossbow Technologies.

The ‘015 patent, owned by Ravin Crossbows, LLC (Ravin), covers archery bows and crossbows featuring rotatable string guides that maintain tension with the draw string used to propel an arrow. Claim 1 recites first and second string guides mounted to the crossbow’s limbs and rotatable around separate axes, with draw string journals and helical power cable take-up journals built into each guide.

The underlying litigation began when Ravin filed a lawsuit against TenPoint in the U.S. District Court for the District of Nevada, later transferred to the Northern District of Ohio, alleging infringement of six crossbow patents. Ravin subsequently withdrew two of the asserted patents, including the ‘015 patent, from that case. Before the withdrawal, the district court determined that “mounted to” required no construction because a skilled artisan would readily understand its plain and ordinary meaning, and it rejected both proposed alternative definitions as unhelpful.

After being named as a defendant, TenPoint petitioned for an IPR challenging claim 1 of the ‘015 patent as anticipated or obvious in light of prior art. The Board instituted review and, despite acknowledging the district court’s earlier order, adopted TenPoint’s proposed construction of “mounted to” as meaning “connected to, either directly or indirectly.” Under that construction, the Board held claim 1 unpatentable as anticipated by International Patent Application Publication No. WO 2011/141771 (Stanziale), without reaching the remaining grounds raised in TenPoint’s petition.

Ravin appealed, arguing the Board’s construction was overly broad since it would allow components separated by any distance or number of intervening parts to qualify still as “mounted to” one another. Ravin proposed instead that the term should mean “physically connected to allow only rotation about a fixed axis.” TenPoint withdrew from the appeal after settling the underlying dispute with Ravin, and the Under Secretary of Commerce for Intellectual Property and Director of the United States Patent and Trademark Office (USPTO) intervened to defend the Board’s decision.

Moreover, the court reviewed the Board’s claim construction de novo, consistent with Seabed Geosolutions (US) Inc. v. Magseis FF LLC, and relied on the framework set out in Phillips v. AWH Corp. to examine the disputed term against the specification and prosecution history.

It found that neither side disputed that “mounted to” carried its plain and ordinary meaning, though each urged a different reading of what that meaning was. Since claim 1 separately requires that each string guide be “rotatable around” an axis, the court determined that this additional limitation bounds the scope of “mounted to.” As a result, the term encompasses both direct and indirect connections, provided the string guide remains rotatable relative to that axis.

The court also found support for its reading in the claim language describing how the draw string unwinds between the guides and how the power cables wrap onto the take-up journals. According to the court, this language shows that the connection between the string guide and the limb is defined by the claim’s structural and functional limitations, rather than by Ravin’s proposed restriction to a single fixed axis.

Furthermore, the court cited Intel Corp. v. Qualcomm Inc. in explaining that claim terms should not be construed in a way that renders other language superfluous. Since claim 1 already specifies that the string guides are “rotatable,” the court found that adopting Ravin’s construction would strip that separate limitation of independent meaning. The opinion stated, “we strongly disfavor construing terms in a way that renders them void, meaningless, or superfluous,” and noted that the specification’s repeated description of the string guides as both mounted to the limbs and rotatable reinforced that conclusion.

The court also rejected Ravin’s argument that the Board improperly departed from the district court’s earlier claim construction order. According to the opinion, the Board considered the district court’s ruling and sought additional briefing specifically because the parties disputed what the plain and ordinary meaning actually was, consistent with its obligations under 37 C.F.R. Section 42.100(b). The court cited ParkerVision, Inc. v. Vidal in confirming that the Board remains free to adopt a construction it independently determines to be correct even where a district court reached a different result in related litigation.

The CAFC concluded that “we see no error in the Board’s construction of ‘mounted to’ to mean ‘connected to, either directly or indirectly.’” Since Ravin raised no separate challenge to the Board’s anticipation finding under that construction, the court affirmed the determination that claim 1 of the ‘015 patent is unpatentable. Ultimately, the opinion stated that the court had considered Ravin’s remaining arguments and found them unpersuasive