Sport Squad Inc v. Diadem Sports LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Sport Squad, Inc. d/b/a JOOLA (Maryland)
  • Defendant: Diadem Sports, LLC (Florida)
  • Plaintiff's Counsel: K&L Gates LLP
• Case Identification: 0:26-cv-61038, S.D. Fla., 04/09/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Southern District of Florida because Defendant is organized in the district, maintains its principal place of business there, and regularly 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 within a cored-out section and a perimeter frame.
• Technical Context: The patent-in-suit addresses the design of solid sports paddles, like those used for pickleball, focusing on methods to tune performance characteristics such as power, feel, and vibration by creating a composite internal structure.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date	Event
2023-08-30	U.S. Patent No. 12,465,826 - Earliest Priority Date
2025-11-11	U.S. Patent No. 12,465,826 - Issue Date
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's background section identifies a general need for game paddles, such as those for pickleball, that can provide "better performance for players" '826 Patent, col. 1:26-27
• The Patented Solution: The invention describes a method for manufacturing a game paddle with tunable characteristics by altering its internal structure '826 Patent, abstract The process begins with a standard paddle constructed of a core material sandwiched between front and back surfaces '826 Patent, col. 3:10-14 Portions of this core are removed, typically near the perimeter, to create a gap '826 Patent, col. 10:2-5 This gap is then filled with a "first filler," such as foam, to increase power, soften feel, or reduce vibration '826 Patent, col. 3:3-9 A separate frame, which is often a hollow structure containing a "second filler," is then added around the paddle's edge to provide a rigid structure '826 Patent, col. 5:14-24 The manufacturing process is depicted in the flowchart of FIG. 31 '826 Patent, FIG. 31
• Technical Importance: This composite construction allows manufacturers to selectively modify a paddle's weight distribution, stiffness, and vibration dampening in specific areas, thereby engineering its performance characteristics.

Key Claims at a Glance

• Asserted Claims: The complaint asserts at least independent claim 1 '826 Patent, col. 12:4-43 Compl. ¶17
• Essential Elements (Claim 1): The essential elements of independent claim 1 include:
  • A front surface and an opposing back surface.
  • A core disposed between the surfaces, with an outer boundary comprising a "first portion" spaced apart from the paddle's internal perimeter and a "second portion" closer to that perimeter.
  • A "gap" formed as a void external to the core.
  • A "first filler" disposed within the gap.
  • A frame disposed about at least the head portion of the paddle.
  • The frame defining a "hollow interior portion."
  • A "second filler" disposed within the hollow portion of the frame.
• Scope of Allegations: The complaint seeks a judgment that Defendant has infringed "one or more claims" of the patent, suggesting that other claims may be asserted later Compl., Prayer A

III. The Accused Instrumentality

Product Identification

• The complaint identifies the "Diadem Edge BluCore" as an infringing product Compl. ¶13 However, the claim chart provided as Exhibit 2 to the complaint exclusively analyzes the "RPM Friction Pro Paddle," which is attributed to a different entity, "Vegas Pickleball LLC d/b/a RPM Pickleball" Compl., Ex. 2, p. 1 The complaint does not explain the relationship, if any, between Defendant Diadem Sports, LLC and the entity or product identified in the claim chart.

Functionality and Market Context

• Based on the analysis in the complaint's Exhibit 2, the accused RPM Friction Pro Paddle is a pickleball paddle constructed with a polypropylene honeycomb core Compl., Ex. 2, p. 5
• The claim chart includes a photograph of a deconstructed RPM Friction Pro Paddle, which appears to show that portions of the honeycomb core have been removed around its perimeter to create a space between the core and an outer frame Compl., Ex. 2, p. 5 This photograph depicts a cutaway of the accused paddle showing the polypropylene core, front and back surfaces, and a perimeter frame Compl., Ex. 2, p. 5 The complaint alleges this construction mirrors the structure claimed in the '826 Patent.

IV. Analysis of Infringement Allegations

• Claim Chart Summary: The following table summarizes the infringement allegations for claim 1 of the '826 Patent against the RPM Friction Pro Paddle, as detailed in Exhibit 2 of the complaint. All allegations are made by reference in a single paragraph of the complaint.

U.S. Patent No. 12,465,826 Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a front surface; a back surface opposing the front surface;	The accused paddle includes front and back surfaces.	¶17	col. 12:5-6
a core disposed between the front surface and the back surface,	The accused paddle contains a polypropylene honeycomb core between the surfaces. A photograph in the claim chart shows this internal core.	¶17	col. 12:7-8
the core having an outer boundary including: (i) a first portion shaped and dimensioned to terminate internal to, and spaced apart from, an internal perimeter of the pickleball paddle, and (ii) a second portion shaped and dimensioned to terminate closer to the internal perimeter of the pickleball paddle relative to the first portion;	The complaint alleges the accused core has an outer boundary with these first and second portions.	¶17	col. 12:9-17
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;	A photograph in the claim chart purports to show a gap between the recessed edge of the core and the paddle's outer perimeter.	¶17	col. 12:18-24
a first filler disposed within at least a portion of the gap beyond the outer boundary of the core;	A red-colored material, identified as the "first filler," is shown in the gap area of the deconstructed paddle.	¶17	col. 12:25-27
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,	A perimeter frame is shown surrounding the head of the paddle.	¶17	col. 12:28-34
the frame defining a hollow interior portion; and	A close-up photograph of the accused paddle's edge purports to show that the frame is hollow.	¶17	col. 12:35-36
a second filler disposed within at least a portion of the hollow interior portion of the frame.	The photograph in the claim chart purports to show material, identified as the "second filler," inside the hollow frame.	¶17	col. 12:37-39

• Identified Points of Contention:
  • Scope Questions: A primary question may be whether the accused paddle's core, which appears to have a single, uniformly recessed perimeter, meets the claim limitation of having an "outer boundary including... a first portion... and... a second portion." The defense may argue this language requires two distinct boundary geometries, not just one continuous recessed edge.
  • Technical Questions: The complaint relies on visual evidence from a deconstructed paddle but does not specify the composition of the alleged "first filler" or "second filler." A key factual dispute may concern whether the materials used in the accused product are functionally and materially consistent with the types of fillers described in the patent, such as foam, elastomer, or other specified materials '826 Patent, col. 4:62-66 '826 Patent, col. 5:32-37

V. Key Claim Terms for Construction

• The Term: "a core having an outer boundary including: (i) a first portion shaped and dimensioned to terminate internal to, and spaced apart from, an internal perimeter of the pickleball paddle, and (ii) a second portion shaped and dimensioned to terminate closer to the internal perimeter of the pickleball paddle relative to the first portion"
• Context and Importance: The definition of this term is central to the infringement analysis. The dispute may turn on whether the accused core, which appears to be recessed from the paddle's edge in a continuous manner, can be said to possess two distinct portions as claimed. Practitioners may focus on this term because the visual evidence provided does not explicitly show two different sections of the core's boundary.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent specification describes a general process of "coring out" sections of the core to create a gap '826 Patent, col. 3:20-24 A party could argue that any resulting boundary that is not perfectly uniform relative to the paddle edge implicitly creates different "portions."
  • Evidence for a Narrower Interpretation: The use of separate labels "(i) a first portion" and "(ii) a second portion" could support an interpretation that the claim requires two structurally distinct and identifiable sections of the core's outer boundary, rather than a single, uniform recessed edge.

VI. Other Allegations

• Willful Infringement: The complaint alleges that Defendant had "actual knowledge" of the '826 Patent and that its infringement has been "willful, intentional, deliberate, or in conscious disregard of rights under the patent" Compl. ¶15 Compl. ¶21 The complaint does not, however, plead specific facts establishing when or how Defendant acquired this knowledge, such as through a notification letter from the Plaintiff.

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

• A core issue will be one of definitional scope: can the claim language requiring a core boundary with a "first portion" and a "second portion" be construed to read on a core with a single, continuous recessed edge, as appears to be the case in the accused product's design? The case may depend heavily on whether this two-part limitation is found to require two distinct geometric structures.
• A significant procedural and evidentiary question is the mismatch of accused parties and products: why does the complaint, filed against Diadem Sports, LLC concerning its "Edge BluCore" product, rely exclusively on an infringement chart that analyzes the "Friction Pro Paddle" from an apparently unrelated entity, Vegas Pickleball LLC? This discrepancy raises fundamental questions about the factual basis of the allegations against the named defendant that will need to be resolved.