MCP IP v. Ravin Crossbows — W.D. Wis. Grants Mixed Summary Judgment Across Ten Crossbow Patents, Send Two to Damages Trial

Background

MCP IP, LLC sued Ravin Crossbows, LLC for infringement of ten MCP patents covering crossbow mechanisms: the ‘375, ‘757, ‘665, ‘433, ‘939, ‘435, ‘893, ‘056, ‘220 utility patents and the D’195 design patent. The accused product is Ravin’s R500 crossbow. Ravin denied infringement across the board, challenged four of the utility patents as invalid, and asserted that the ‘435 patent is unenforceable because of inequitable conduct during prosecution. Both sides cross-moved for partial summary judgment. The court addressed the merits in an 85-page opinion and order, along with motions to strike experts, discovery objections, and a late-in-the-case motion by Ravin to amend its invalidity contentions to add a 1980s-era prior-art crossbow.

The Court’s Holding

The summary-judgment results are patent-specific:

• ‘375 patent — Ravin granted non-infringement on all asserted claims.
• ‘757 patent — Ravin granted non-infringement on all asserted claims.
• ‘665 patent — Ravin’s non-infringement motion denied on claim 1 and claim 12. The court issued a show-cause order asking Ravin to explain why the court should not grant MCP summary judgment of infringement on those claims and the claims that depend from them.
• ‘433 patent — MCP granted summary judgment of infringement on all asserted claims; Ravin’s invalidity counterclaims (indefiniteness and obviousness) rejected on summary judgment.
• ‘939 patent — MCP granted summary judgment of infringement on all asserted claims; Ravin’s invalidity counterclaims (indefiniteness and obviousness) rejected.
• ‘435 patent — Ravin’s non-infringement motion denied on claim 1; show-cause order on whether MCP should win infringement summary judgment on claim 1 and its dependent claims. MCP granted summary judgment defeating Ravin’s inequitable-conduct counterclaim.
• ‘893 patent — Ravin granted non-infringement on all asserted claims.
• ‘056 patent — Ravin granted non-infringement on claims 5, 6, 14, 15. Show-cause order on whether MCP should win infringement summary judgment on claim 1 and claim 12 and their dependents.
• ‘220 patent — Ravin granted non-infringement on all asserted claims. Ravin’s invalidity counterclaims on the ‘220 dismissed without prejudice.
• D’195 design patent — Ravin granted non-infringement on the asserted claim. Ravin’s invalidity counterclaim dismissed without prejudice.

Trial will proceed on damages for Ravin’s infringement of the ‘433 and ‘939 patents, and on whichever of the ‘665, ‘435, and ‘056 patents survive the show-cause briefing. Ravin must respond by April 16, 2026; MCP’s reply is due April 27, 2026.

Evidentiary rulings. The court partially granted Ravin’s motion to strike the supplemental report of MCP’s expert David Paulus, excluding his opinions on the “latch” limitation of the ‘435 patent and his opinions on the ‘220 patent (paragraphs 33–61), but preserving his analysis of the late-disclosed CAD files (paragraphs 7–32) and his opinions on Ravin’s design-arounds. MCP’s cross-motion to strike Ravin’s design-around expert opinions was denied. Both sides’ objections to magistrate-judge discovery orders — MCP’s on email discovery and Ravin’s on royalty-rate document production — were overruled.

Late invalidity contentions denied. Ravin moved for leave to supplement its invalidity contentions with a new obviousness theory based on the Barnett Thunderbolt, a 1980s crossbow Ravin learned about through an unsolicited tip, arguing the product pre-dated the internet and couldn’t reasonably have been found earlier. The court denied the motion. Judge Peterson noted that Ravin’s duty of diligence on prior-art searches is not limited to internet-accessible sources — trade magazines and historical industry material are fair game — and that late invalidity amendments are inherently disruptive so close to trial. “Sometimes a lucky break just comes too late in the case to fairly accommodate it.”

Inequitable conduct defeated. On the ‘435 patent, Ravin’s inequitable-conduct counterclaim was built around a MCP–Bowtech licensing agreement that MCP had characterized in interrogatory responses as “nothing relevant related to [the Bowtech] lawsuit.” The magistrate judge (affirmed here) held that this phrasing was not an express denial of the agreement’s existence, and Ravin should not have relied on it as such. Ravin’s diligence failures, combined with the other evidence, did not clear the high Therasense bar for inequitable conduct.

Key Takeaways

• MCP walked in with ten patents and leaves trial-ready on at most five. Non-infringement summary judgment landed on the ‘375, ‘757, ‘893, ‘220, D’195 entirely, and the ‘056 on four claims. The ‘433 and ‘939 are now liability-only trials on damages. The ‘665, ‘435, and ‘056 (on remaining claims) are under show-cause and likely to tilt toward MCP based on the court’s denial of Ravin’s non-infringement motions.
• Inequitable conduct remains a hard defense to win. Ravin built its ‘435 inequitable-conduct theory on a pre-trial discovery dispute over a licensing agreement. Under Therasense‘s materiality-plus-specific-intent standard, even a discovery misstep by the patentee usually falls short absent clear evidence the patentee specifically intended to deceive the PTO. The court’s extensive discussion of diligence failures on both sides is worth reading for practitioners drafting either side of an inequitable-conduct claim.
• Pre-internet prior art is not a free pass for late disclosure. Judge Peterson’s rejection of Ravin’s Barnett Thunderbolt amendment is a clean articulation that an invalidity search must cover historical trade material, not just patents and online sources. This aligns with the court’s own Signify North America v. Menard from 2024 on late invalidity contentions.
• Show-cause as a docket-management tool. Rather than denying both sides’ motions and leaving disputed infringement theories for trial, the court used the show-cause device to reach summary-judgment-of-infringement findings on claims where Ravin’s non-infringement theory failed. Expect to see more of this structure in multi-patent W.D. Wis. cases.

Why It Matters

This is one of the more significant patent rulings to land on an outdoor-equipment docket this year. MCP IP is the licensing arm behind a number of compound-bow and crossbow patents; Ravin Crossbows is a category leader in high-end crossbows. The ‘433 and ‘939 patents, which will go to damages trial, cover mechanical features that Ravin’s entire R500 product line implements. For the wider patent bar, the case shows how a carefully structured ten-patent assertion gets pruned at summary judgment — and how a defendant’s narrow design-around expert testimony and prior-art diligence can rescue or sink non-infringement positions patent-by-patent. Watch the show-cause briefing in the next two weeks for the final trial scope.