Sport Squad Inc v. All Racquet Sports LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Sport Squad, Inc. d/b/a JOOLA (Maryland)
  • Defendant: All Racquet Sports, LLC (Delaware) and All For Padel S.L. (Spain)
  • Plaintiff's Counsel: K&L Gates LLP
• Case Identification: 1:26-cv-00406, D. Del., 04/09/2026
• Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant All Racquet Sports is incorporated in Delaware, and both defendants transact business and have committed alleged acts of infringement in the district, including the sale of the accused product.
• Core Dispute: Plaintiff alleges that Defendants' pickleball paddles infringe a patent related to the internal construction of game paddles, specifically concerning the use of internal gaps, fillers, and frames to modify performance.
• Technical Context: The technology relates to the design and manufacture of high-performance composite sports paddles, such as those used in pickleball, where internal material composition is engineered to affect characteristics like power, feel, and vibration dampening.
• Key Procedural History: The complaint does not reference any prior litigation, licensing history, or inter partes review proceedings involving the asserted patent.

Case Timeline

Date	Event
2023-08-30	U.S. Patent No. 12,465,826 Priority Date
2025-11-11	U.S. Patent No. 12,465,826 Issued
2026-04-09	Complaint Filed

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

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

• Issued: November 11, 2025 (the "'826 Patent").

The Invention Explained

• Problem Addressed: The patent addresses a general need for sports paddles that can "provide better performance for players" than conventional designs '826 Patent, col. 1:25-26
• The Patented Solution: The invention describes a game paddle, such as a pickleball paddle, constructed with a layered "sandwich structure" comprising a central core between two outer surfaces '826 Patent, col. 3:12-14 The solution involves strategically creating voids or "gaps" in or around the core and introducing "fillers" (e.g., foam) into these gaps and into a surrounding frame '826 Patent, abstract '826 Patent, col. 3:24-27 This allows for tuning the paddle's performance characteristics, such as increasing power, softening the feel, and reducing vibration '826 Patent, col. 3:6-8 The patent illustrates various configurations, including a hollow frame (600) containing a second filler (605) that surrounds a primary core (200) and a first filler (400) '826 Patent, FIG. 6B
• Technical Importance: This approach allows manufacturers to engineer specific performance zones within a paddle by using different materials in different locations, moving beyond monolithic core constructions.

Key Claims at a Glance

• The complaint asserts at least independent claim 1 '826 Patent, Compl. ¶20
• The essential elements of independent claim 1 are:
  • A front surface and an opposing back surface.
  • A core disposed between the surfaces, with the core's outer boundary having two distinct portions: a first portion internal to the paddle's perimeter and a second portion closer to the paddle's perimeter.
  • A "gap formed as a void external to the core" and positioned between the core's outer boundary and the paddle's internal perimeter.
  • A "first filler" disposed within at least a portion of the gap.
  • A "frame" disposed about at least the head portion of the paddle, defining a hollow interior.
  • A "second filler" disposed within the hollow interior of the frame.
• The complaint does not explicitly reserve the right to assert dependent claims, but the prayer for relief requests a declaration of infringement of "one or more claims" '826 Patent, Relief Requested ¶A

III. The Accused Instrumentality

Product Identification

• The AdiPower Pro pickleball paddle '826 Patent, Compl. ¶15

Functionality and Market Context

• The complaint alleges the AdiPower Pro is a "solid sports paddle" that implements the patented technology concerning internal structures designed to affect feel and performance '826 Patent, Compl. ¶15 The complaint alleges Defendants "manufacture, import, offer for sale, and sell" this and other pickleball paddles to resellers, distributors, and consumers throughout the United States '826 Patent, Compl. ¶6

IV. Analysis of Infringement Allegations

The complaint alleges that Defendants directly infringe at least claim 1 of the '826 Patent through the making, using, selling, offering for sale, and/or importing of the Accused Product '826 Patent, Compl. ¶16 Compl. ¶20 The complaint states that a non-limiting claim chart is attached as Exhibit 2 to support its infringement allegations '826 Patent, Compl. ¶20 However, this exhibit was not provided with the complaint document. The narrative portion of the complaint does not contain specific factual allegations mapping features of the Accused Product to the limitations of claim 1.

No probative visual evidence provided in complaint.

• Identified Points of Contention: Lacking a detailed claim chart, the primary questions will revolve around the physical construction of the AdiPower Pro paddle and how its components map to the specific structural language of Claim 1.
  • Scope Questions: A central question may be how the Accused Product's internal structure corresponds to the claimed "core," "gap," and "frame." For example, does the Accused Product contain a distinct "gap formed as a void external to the core" that is separate from a hollow "frame," or are these features integrated in a way that challenges the claim's structural requirements?
  • Technical Questions: Discovery will likely focus on a physical teardown or imaging of the Accused Product to determine if it contains both a "first filler" in a gap external to the core and a separate "second filler" inside a hollow frame, as required by the claim. The material composition of these alleged fillers will also be a point of factual inquiry.

V. Key Claim Terms for Construction

• The Term: "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"
• Context and Importance: This term is critical because it defines the location and nature of the void where the "first filler" resides. The infringement analysis will depend on whether the Accused Product has a structure that can be defined as a "gap" that is simultaneously "external to the core" yet still inside the paddle's perimeter and separate from the "frame." Practitioners may focus on this term to dispute whether a single, foam-filled perimeter structure in the accused device meets both the "gap with first filler" and "frame with second filler" limitations.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes creating the gap by "coring out" or removing sections of the core material, suggesting the gap is simply a space where core material used to be '826 Patent, col. 3:45-48 This could support an argument that any non-core material between the main core body and the paddle edge constitutes the "gap."
  • Evidence for a Narrower Interpretation: Claim 1 explicitly requires both the "gap" (with a first filler) and a separate "frame" (with a second filler). Figure 6B, for instance, shows a clear structural distinction between the core (200), a first filler (400) in a gap, and an encompassing frame (600) with its own second filler (605). This may support a narrower construction requiring two distinct, separately identifiable structures.

VI. Other Allegations

• Indirect Infringement: The complaint does not contain specific allegations of indirect infringement (inducement or contributory infringement).
• Willful Infringement: The complaint alleges that Defendants had "actual knowledge" of the '826 Patent and that their infringement has been "willful, intentional, deliberate, or in conscious disregard" of Plaintiff's patent rights '826 Patent, Compl. ¶17 Compl. ¶24 The basis for this alleged pre-suit knowledge is not specified.

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

1. A Structural Question of Identity: The central issue will be whether the internal construction of the AdiPower Pro paddle contains the specific, multi-part structure recited in Claim 1. Does the product embody a distinct "core," a "gap" external to that core filled with a "first filler," and a separate hollow "frame" filled with a "second filler," or does its design conflate these elements in a way that falls outside the literal scope of the claim?
2. An Evidentiary Question of Knowledge: The willfulness claim will depend on what evidence Plaintiff can produce to show Defendants had pre-suit knowledge of the '826 Patent. The complaint's assertion of "actual knowledge" will require factual support to survive beyond the pleading stage and to form a basis for potential enhanced damages.