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: 9:26-cv-80402, S.D. Fla., 04/09/2026
• Venue Allegations: Venue is asserted on the basis that Defendant Diadem Sports, LLC is organized in the Southern District of Florida and maintains a regular and established place of 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 concerning the use of fillers within a cored-out internal structure and perimeter frame.
• Technical Context: The technology relates to advanced composite structures in sports equipment, aiming to tune performance characteristics such as vibration damping, power, and feel by selectively modifying the paddle's internal materials.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or post-grant proceedings related to the patent-in-suit. Notably, the complaint's infringement analysis, provided in Exhibit 2, is directed at a product from a non-party entity, Vegas Pickleball LLC, rather than the named Defendant, Diadem Sports, LLC.

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 Issue Date
2026-04-09	Complaint Filing Date

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

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

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

The Invention Explained

• Problem Addressed: The patent seeks to provide game paddles, such as those used for pickleball, with "better performance for players" than conventional designs '826 Patent, col. 1:25-26
• The Patented Solution: The invention describes a method for manufacturing a paddle with customized performance characteristics by altering its internal structure '826 Patent, col. 3:10-12 The process involves starting with a standard "sandwich structure" paddle (comprising a core between two face sheets) and "coring out," or removing, a portion of the internal core material to create a gap '826 Patent, col. 3:20-24 '826 Patent, FIG. 31 This gap is then filled with a "first filler," such as foam, to influence properties like power, feel, and vibration '826 Patent, col. 3:5-8 '826 Patent, col. 3:24-27 Additionally, a frame, which can be hollow and contain a "second filler," is wrapped around the paddle's perimeter to provide a rigid structure '826 Patent, col. 3:30-34
• Technical Importance: This design allows for precise tuning of a paddle's playing characteristics by strategically placing different materials within the core and frame, potentially offering performance advantages over paddles with homogenous core constructions '826 Patent, abstract

Key Claims at a Glance

• The complaint asserts at least independent claim 1 '826 Patent, ¶17
• The essential elements of independent claim 1 include:
  • A front surface, a back surface, and a core disposed between them.
  • The core has a specific outer boundary with a "first portion" spaced apart from the paddle's internal perimeter and a "second portion" closer to that perimeter.
  • A "gap" exists as a void external to the core, between the core's outer boundary and the paddle's internal perimeter.
  • A "first filler" is disposed within this gap.
  • A "frame" is disposed about at least the head portion of the paddle.
  • The frame is at least partially between the front and back surfaces and defines a "hollow interior portion."
  • A "second filler" is disposed within the frame's hollow interior portion.
• The complaint reserves the right to assert additional claims as the case progresses '826 Patent, ¶18

III. The Accused Instrumentality

Product Identification

• The complaint identifies the "Diadem Edge BluCore" as an Accused Product Compl. ¶13

Functionality and Market Context

• The complaint does not provide specific technical details regarding the Diadem Edge BluCore. However, it attaches a claim chart (Exhibit 2) that analyzes the "RPM Friction Pro Paddle," a product attributed to a non-party, Vegas Pickleball LLC Compl. ¶17 Compl. Ex. 2
• The infringement allegations and visual evidence in the complaint rely entirely on the analysis of the RPM Friction Pro Paddle Compl. Ex. 2 The provided visual evidence, showing a disassembled RPM paddle, depicts a honeycomb polymer core, a distinct perimeter frame, and a red-colored foam-like material situated in a gap between the core and the frame Compl. Ex. 2, p. 53 Compl. Ex. 2, p. 58 This structure is alleged to embody the technology of the '826 Patent. The photograph of the disassembled paddle shows its internal honeycomb core and a perimeter frame filled with a reddish filler material Compl. Ex. 2, p. 53

IV. Analysis of Infringement Allegations

The complaint provides a claim chart in Exhibit 2, which analyzes the RPM Friction Pro Paddle. The complaint alleges these infringement contentions apply to the Accused Product, defined as the Diadem Edge BluCore Compl. ¶13 Compl. ¶17

'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 RPM paddle includes a polypropylene honeycomb core situated between its front and back surfaces.	Ex. 2, p. 53	col. 4:40-42
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 RPM paddle's core is alleged to have an outer boundary with distinct portions at different distances from the paddle's internal perimeter.	Ex. 2, p. 55	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;	A gap is allegedly formed between the core's edge and the paddle's perimeter frame, extending around at least the "first portion" of the core.	Ex. 2, p. 56	col. 12:16-22
a first filler disposed within at least a portion of the gap beyond the outer boundary of the core;	A red-colored foam material allegedly serves as a "first filler" and is disposed within the gap external to the core.	Ex. 2, p. 58	col. 4:60-61
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 RPM paddle includes a perimeter frame around its head, positioned between the front and back surfaces. A photograph shows the frame disposed between the paddle's front and back surfaces Compl. Ex. 2, p. 60	Ex. 2, p. 59	col. 5:16-18
the frame defining a hollow interior portion; and	The perimeter frame of the RPM paddle is alleged to be hollow.	Ex. 2, p. 61	col. 5:31-32
a second filler disposed within at least a portion of the hollow interior portion of the frame.	The hollow interior of the RPM paddle's frame is allegedly filled with a material serving as a "second filler."	Ex. 2, p. 62	col. 5:32-34

Identified Points of Contention

• Pleading Question: A threshold issue is the complaint's reliance on an infringement analysis of a non-party's product (RPM Friction Pro Paddle) to support its claims against Defendant's product (Diadem Edge BluCore). The court may need to address whether this satisfies federal pleading standards.
• Scope Questions: The definition of the core's "outer boundary" with its "first portion" and "second portion" will be critical. The dispute may focus on whether the accused paddle's core has the specific, differentiated geometry required by the claim language, or if it has a uniform perimeter.
• Technical Questions: A key factual question will be whether the accused product's perimeter frame is indeed a "hollow" structure containing a distinct "second filler" as claimed, or if it is a solid component. Evidence regarding the internal composition of the frame will be central to this determination.

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: This lengthy limitation defines the specific geometric relationship between the core and the paddle's edge. The infringement analysis hinges on whether the accused core is shaped with this specific two-part, stepped, or variable-distance boundary. Practitioners may focus on this term because it appears to be the primary structural point of novelty for the core itself.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent specification describes numerous embodiments with fillers in various locations, which could suggest the exact shape of the core boundary is less critical than the overall concept of creating a gap for a filler '826 Patent, FIGS. 8-13
  • Evidence for a Narrower Interpretation: The explicit "first portion" and "second portion" language in the claim itself provides a precise structural definition. The patent figures do not clearly depict this two-part boundary, which may lead a court to rely heavily on the plain meaning of the claim's text, potentially favoring a narrower, more structurally demanding interpretation.

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

• Context and Importance: The construction of "external to the core" is central to defining the location of the claimed gap and first filler. The dispute will turn on whether this requires the gap to be located entirely outside the original material volume of the core, as opposed to a cavity created within the core material.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The manufacturing description explains the process as "coring out (removing) a portion of the core," which creates a gap "where the core previously existed" '826 Patent, col. 3:20-22 '826 Patent, col. 4:47-49 This may support an interpretation where the gap is simply a space created by removing core material.
  • Evidence for a Narrower Interpretation: The claim language "external to the core" and "positioned between the outer boundary of the core and the internal perimeter of the pickleball paddle" could be argued to require a structure where the core is a distinct, smaller component, and the gap is the space surrounding it, rather than a channel cut into it '826 Patent, col. 12:16-19

VI. Other Allegations

• Willful Infringement: The complaint alleges that Defendant's infringement has been and continues to be willful, intentional, and deliberate Compl. ¶21 The pleading asserts that Defendant had "actual knowledge" of the '826 Patent and that it "actually knew or should have known" its conduct constituted an unjustifiably high risk of infringement Compl. ¶15 Compl. ¶21 The complaint does not plead specific facts detailing the basis for this alleged knowledge, such as a pre-suit notice letter.

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

1. A Threshold Pleading Issue: The case presents a fundamental procedural question of whether infringement allegations against a named defendant and its product can be sustained when the complaint's only substantive technical analysis and evidence (Exhibit 2) pertains to a different product manufactured by an entirely separate, non-party entity.
2. A Question of Definitional Scope: A core technical issue will be the construction of the claim term defining the core's "outer boundary" with distinct "first" and "second" portions. The viability of the infringement claim will depend on whether this language is construed to require a specific, complex geometry that is present in the accused product.
3. An Evidentiary Question of Internal Structure: The dispute will likely focus on the physical composition of the accused paddle. A key evidentiary question will be whether the accused product's perimeter element is a "frame defining a hollow interior portion" that contains a "second filler", as claimed, or if it is a solid structure, which could present a significant challenge to proving literal infringement of the final claim elements.