Ravin Crossbows, LLC v. Squires — “Mounted To” Construction Leaves Crossbow Claim Anticipated

Background

Ravin Crossbows owns U.S. Patent No. 9,354,015, which covers a reverse-draw crossbow whose string guides and helical cable journals coordinate the bowstring and power cables. Claim 1 requires each string guide to be “mounted to” a flexible bow limb and “rotatable around” an axis.

After Ravin sued Hunter’s Manufacturing Company, doing business as TenPoint Crossbow Technologies, TenPoint petitioned for inter partes review. The Patent Trial and Appeal Board construed “mounted to” as “connected to, either directly or indirectly” and found claim 1 anticipated by the Stanziale international patent publication. TenPoint later settled and withdrew from the appeal, leaving the USPTO Director to defend the Board’s ruling.

The Court’s Holding

The Federal Circuit affirmed the Board’s decision that claim 1 is unpatentable. Chief Judge Kimberly A. Moore explained that the claim’s other structural and functional language limits what qualifies as a connection even though “mounted to” itself includes direct and indirect connections.

Ravin urged a narrower construction—“physically connected to allow only rotation about a fixed axis.” The court rejected that reading because the claim separately says the string guides are “rotatable around” their axes. Building rotation into “mounted to” would make the express rotatability language superfluous. The specification likewise describes the guides as both mounted and rotatable, signaling that the two concepts are distinct.

The panel also held that the Board properly considered, but was not bound by, a district court’s claim-construction order from related litigation. Because Ravin did not separately challenge the anticipation finding under the Board’s construction, affirmance followed.

Key Takeaways

• Ordinary-meaning claim construction must account for surrounding limitations; an otherwise broad connection term can be bounded by the claim’s functional structure.
• A proposed construction that repeats a separately recited limitation risks being rejected as rendering claim language superfluous.
• PTAB must consider a timely submitted district-court construction, but it may adopt a different construction after conducting its own analysis.
• When an appellant ties patentability entirely to claim construction, losing that construction dispute may end the appeal if no independent merits challenge remains.

Why It Matters

The nonprecedential decision illustrates a recurring drafting and litigation problem: courts generally resist importing a functional restriction into one term when the claim states that function elsewhere. Patent owners challenging an IPR result should also preserve substantive attacks on the prior-art finding rather than rely exclusively on obtaining a narrower construction.