Sport Squad Inc v. Friday Labs LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Sport Squad, Inc. D/B/A JOOLA (Maryland)
  • Defendant: Friday Labs LLC (California)
  • Plaintiff's Counsel: K&L Gates LLP
• Case Identification: 3:26-cv-03069, N.D. Cal., 04/09/2026
• Venue Allegations: Venue is alleged to be proper in the Northern District of California because Defendant is organized in the district, maintains a regular and established place of business there, and transacts business within the district.
• Core Dispute: Plaintiff alleges that Defendant's pickleball paddles infringe a patent related to the internal construction of game paddles, specifically the use of fillers and frames to modify performance characteristics.
• Technical Context: The technology addresses methods for manufacturing solid sports paddles, like those used in pickleball, to enhance player feel, power, and vibration dampening through specific multi-component core and frame designs.
• Key Procedural History: The complaint does not specify any prior litigation, licensing history, or other procedural events relevant to the patent-in-suit.

Case Timeline

Date	Event
2023-08-30	Earliest Priority Date for U.S. Patent No. 12,465,826
2025-01-17	Filing Date for U.S. Patent No. 12,465,826
2025-11-11	Issue Date for U.S. Patent No. 12,465,826
2026-04-09	Complaint Filing Date

II. Technology and Patent(s)-in-Suit Analysis

• Patent Identification: U.S. Patent No. 12,465,826, "Game Paddle," issued November 11, 2025 (the "'826 Patent").

U.S. Patent No. 12,465,826 - "Game Paddle"

The Invention Explained

• Problem Addressed: The patent identifies a need for solid game paddles, such as those for pickleball, that can provide "better performance for players" than existing designs '826 Patent, col. 1:24-26 The invention aims to affect performance, comfort, and enjoyment, in part by providing vibration dampening '826 Patent, abstract
• The Patented Solution: The patent discloses a multi-stage manufacturing process and resulting paddle structure. The process begins with a standard paddle having a core material (e.g., honeycomb) sandwiched between two surfaces '826 Patent, col. 3:9-18 A key step involves "coring out" or removing a portion of this core, typically near the perimeter, to create a void or "gap" '826 Patent, col. 4:45-48 '826 Patent, FIG. 2 This gap is then filled with a "first filler," such as foam, to alter the paddle's characteristics '826 Patent, col. 4:59-66 Finally, a separate, typically hollow, "frame" is wrapped around the paddle's edge '826 Patent, col. 5:15-18 This frame can itself contain a "second filler," which may be the same as or different from the first, to further tune performance '826 Patent, col. 6:30-40 The cross-sectional diagram in FIG. 6B illustrates the complete assembly, showing the core (200), the first filler (400) in the gap, and the frame (600) containing the second filler (605).
• Technical Importance: This layered construction method allows for precise engineering of a paddle's weight distribution, stiffness, and dampening properties by using different materials in distinct locations (the core, the gap, and the perimeter frame).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 Compl. ¶18
• The essential elements of independent claim 1 are:
  • A pickleball paddle with a front surface, a back surface, and a core disposed between them.
  • The core has an outer boundary with a "first portion" that terminates spaced apart from the paddle's internal perimeter and a "second portion" that terminates closer to the perimeter.
  • A "gap" formed as a void external to the core, positioned between the core's outer boundary and the paddle's internal perimeter, extending around at least the first portion of the core's boundary.
  • A "first filler" disposed in at least a portion of this gap.
  • A "frame" disposed around at least the head of the paddle, defining a hollow interior portion.
  • A "second filler" disposed within at least a portion of the frame's hollow interior.
• The complaint reserves the right to assert additional claims as the case progresses Compl. ¶19 Compl. Ex. 2, p. 1

III. The Accused Instrumentality

Product Identification

• The Friday Fever 102 pickleball paddle Compl. ¶19

Functionality and Market Context

• The accused Friday Fever 102 is a pickleball paddle sold by Defendant Compl. Ex. 2, p. 2 The complaint provides marketing materials and photographs that describe its internal construction Compl. Ex. 2, pp. 7-16
• The complaint highlights several technical features described in Defendant's marketing, including a "10mm Honeycomb" core, an "EVA Foam Ring" that "Enhances Power + Pop," an "ElasTECH Perimeter" that "Increases Power, Sweet Spot, and Stability," and a "Carbon-Wrapped Edge Foam" that "Strengthens Throat + Handle" Compl. Ex. 2, p. 8 A marketing diagram provided in the complaint shows these components arranged with the foam elements surrounding the central honeycomb core Compl. Ex. 2, p. 8 The complaint also includes a photograph of a disassembled paddle, showing a honeycomb core and a separate, surrounding foam-like perimeter piece Compl. Ex. 2, p. 5

IV. Analysis of Infringement Allegations

• Claim Chart Summary: The complaint provides a preliminary claim chart in Exhibit 2, which maps elements of claim 1 of the '826 Patent to features of the Friday Fever 102 paddle.

'826 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a core disposed between the front surface and the back surface,	The Friday Fever 102 includes a polypropylene honeycomb core between its front and back surfaces. A photograph shows the paddle disassembled with the core visible.	¶18; Ex. 2, p. 5	col. 3:15-18
the core having an outer boundary including a first portion shaped and dimensioned to terminate internal to, and spaced apart from, an internal perimeter of the pickleball paddle, and a second portion shaped and dimensioned to terminate closer to the internal perimeter of the pickleball paddle relative to the first portion	The accused paddle's core has an outer boundary with distinct portions. A marketing diagram annotates "First portion" and "Second portion" on the core.	¶18; Ex. 2, p. 7	col. 12:8-15
a gap formed as a void external to the core and positioned between the outer boundary of the core and the internal perimeter of the pickleball paddle, the gap extending around at least the first portion of the outer boundary of the core;	The accused paddle allegedly has a gap between the core and the paddle's perimeter. A photograph of a disassembled paddle includes a label pointing to the "gap."	¶18; Ex. 2, p. 9	col. 12:16-21
a first filler disposed within at least a portion of the gap beyond the outer boundary of the core;	The accused paddle's "EVA Foam Ring" allegedly constitutes the first filler within the gap. A photo of a disassembled paddle points to this material as the "first filler."	¶18; Ex. 2, p. 12	col. 12:22-24
a frame disposed about at least a head portion of the pickleball paddle along an edge portion thereof, the frame at least partially disposed between the front surface and the back surface along the edge portion,	The accused paddle's "Carbon-Wrapped Edge Foam" or "ElasTECH Perimeter" is alleged to be the claimed frame. A photograph of a disassembled paddle includes a label pointing to the "frame."	¶18; Ex. 2, p. 13	col. 12:25-31
the frame defining a hollow interior portion; and	The accused frame is alleged to be hollow. A photograph shows a cross-section of the edge piece with a hollow interior.	¶18; Ex. 2, p. 14	col. 12:31
a second filler disposed within at least a portion of the hollow interior portion of the frame.	The accused frame allegedly contains a second filler within its hollow portion. A photograph of a disassembled paddle points to a material inside the frame as the "second filler."	¶18; Ex. 2, p. 16	col. 12:32-35

• Identified Points of Contention:
  • Scope Questions: The complaint alleges that multiple named features from the accused product's marketing material (e.g., "EVA Foam Ring," "ElasTECH Perimeter," "Carbon-Wrapped Edge Foam") map to the distinct claim elements of "first filler" and "frame" containing a "second filler." A central question may be whether these are distinct structures as recited in the claim or if they represent a single, integrated component. For example, the analysis may focus on whether the "Carbon-Wrapped Edge Foam" constitutes both the "frame" and the "second filler" simultaneously, or if it is only a frame containing a separate filler material.
  • Technical Questions: A key factual question will be how the physical construction of the Friday Fever 102 paddle corresponds to the marketing diagrams presented in the complaint Compl. Ex. 2, p. 8 Discovery will likely focus on whether the materials and arrangement in the actual product match the discrete "core," "gap," "first filler," "frame," and "second filler" architecture required by claim 1.

V. Key Claim Terms for Construction

• The Term: "frame"

• Context and Importance: The definition of "frame" is critical to determining infringement. The claim requires a "frame" that is distinct from the "first filler" and contains a "second filler." The accused product has a "Carbon-Wrapped Edge Foam" and an "ElasTECH Perimeter" Compl. Ex. 2, p. 8 Whether these features meet the definition of the claimed "frame" will be a central point of dispute.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification states the frame can be comprised of "any material that provides a rigid structure," including "carbon, glass, or any synthetic or natural fiber with resin, plastic, rubber, metal" '826 Patent, col. 5:18-21 This language may support arguing that various types of reinforced edge constructions could qualify.
  • Evidence for a Narrower Interpretation: The patent describes the frame as a component that is "added around the edge of the paddle" and "wrap[s] around the perimeter" in a distinct manufacturing step '826 Patent, col. 3:31-32 '826 Patent, col. 10:49-51 This could support a narrower construction requiring the frame to be a discrete, separately applied component, rather than an integrated part of the paddle body. FIG. 6B also depicts the frame (600) as a distinct outer structure enclosing the core (200) and first filler (400).

• The Term: "gap formed as a void external to the core"

• Context and Importance: This term defines the location and nature of the space where the "first filler" resides. The relationship between the "core," the "gap," and the "frame" is fundamental to the claim's structure. The infringement read will depend on whether the space between the accused product's honeycomb core and its perimeter foam qualifies as a "gap external to the core."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language "positioned between the outer boundary of the core and the internal perimeter of the pickleball paddle" suggests the gap is simply the space between the core and the paddle's edge '826 Patent, col. 12:17-20 This could encompass any design where the core does not extend to the full edge of the paddle.
  • Evidence for a Narrower Interpretation: The specification repeatedly describes the gap as being actively created by "coring out (remov[ing]) a portion of the core" '826 Patent, col. 3:19-21 '826 Patent, col. 10:1-3 This may support an argument that the term requires a space that was carved from a larger, pre-existing core, rather than being formed by assembling a smaller core inside a larger frame from the outset.

VI. Other Allegations

• Willful Infringement: The complaint alleges that Defendant had "actual knowledge" of the '826 Patent and that its infringement "has been and continues to be willful, intentional, deliberate, or in conscious disregard of" Plaintiff's patent rights Compl. ¶15 Compl. ¶22 The complaint does not, however, plead any specific facts supporting when or how Defendant allegedly became aware of the patent pre-suit.

VII. Analyst's Conclusion: Key Questions for the Case

• A core issue will be one of structural mapping: Do the various named foam components in the accused paddle's marketing materials and physical construction correspond to the distinct, multi-part architecture of a "core," a "gap," a "first filler," a "frame," and a "second filler," as strictly required by the claim language, or is there a structural and functional mismatch?
• A second key issue will turn on claim construction: Can the term "frame," which the patent describes as a hollow structure "added around the edge," be construed to read on the accused product's "Carbon-Wrapped Edge Foam" or "ElasTECH Perimeter," or do those features represent a different, un-claimed type of edge reinforcement technology?
• Finally, a central evidentiary question will be one of physical proof: Beyond the marketing materials, what will a technical analysis of the actual Friday Fever 102 paddle reveal about its internal composition, and does that physical evidence satisfy each specific limitation of the asserted claim?