Sport Squad Inc v. Vegas Pickleball LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Sport Squad, Inc. d/b/a JOOLA (Maryland)
  • Defendant: Vegas Pickleball, LLC d/b/a RPM Pickleball (Florida)
  • Plaintiff's Counsel: K&L Gates LLP
• Case Identification: 9:26-cv-80403, S.D. Fla., 04/09/2026
• Venue Allegations: Venue is alleged to be proper as Defendant 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 two patents related to the internal construction of game paddles, specifically concerning the use of foam fillers within a paddle's core and frame to modify performance characteristics.
• Technical Context: The technology relates to advanced composite manufacturing techniques for sports equipment, where internal material composition and structure are engineered to control player-perceptible qualities like vibration, feel, and power.
• Key Procedural History: The complaint does not reference any prior litigation, licensing history, or post-grant proceedings involving the asserted patents.

Case Timeline

Date	Event
2023-08-30	Earliest Priority Date for '826 and '891 Patents
2025-07-15	U.S. Patent No. 12,357,891 Issues
2025-11-11	U.S. Patent No. 12,465,826 Issues
2026-04-09	Complaint Filed

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

U.S. Patent No. 12,465,826 - "Game Paddle" (Issued Nov. 11, 2025)

The Invention Explained

• Problem Addressed: The patent seeks to provide game paddles with "better performance for players" '826 Patent, col. 4:23-25 The background implies a need to move beyond simple solid-core paddle constructions to enhance characteristics like power, feel, and vibration reduction '826 Patent, col. 3:3-6
• The Patented Solution: The invention involves a multi-step manufacturing process for a "sandwich structure" paddle '826 Patent, col. 3:10-12 A portion of the paddle's internal core material is first removed ("cored out") to create a gap '826 Patent, col. 3:19-22 A "first filler," such as foam, is then inserted into this gap '826 Patent, col. 3:25-28 A hollow frame, which itself contains a "second filler," is then wrapped around the paddle's perimeter '826 Patent, col. 3:30-34 This composite construction of core, fillers, and frame allows for engineered control over the paddle's performance characteristics. The manufacturing process is outlined in a flowchart '826 Patent, FIG. 31
• Technical Importance: This approach represents a method for creating zonal variations in material properties within a paddle, allowing manufacturers to tune specific areas for stiffness, weight, or dampening without altering the entire paddle structure.

Key Claims at a Glance

• The complaint asserts independent claim 1 '826 Patent, col. 12:4-41 Compl. ¶17
• Claim 1 Elements:
  • A pickleball paddle comprising: a front surface and an opposing back surface.
  • A core disposed between the surfaces, the core having an "outer boundary" with a first portion terminating "internal to, and spaced apart from, an internal perimeter of the pickleball paddle," and a second portion terminating "closer to the internal perimeter."
  • A "gap" formed as a void external to the core, positioned between the core's outer boundary and the paddle's internal perimeter.
  • The gap extending around at least the first portion of the core's outer boundary.
  • A "first filler" disposed within at least a portion of the gap.
  • A "frame" disposed about at least a head portion of the paddle along an edge.
  • The frame is at least partially disposed between the front and back surfaces.
  • The frame defines a "hollow interior portion."
  • A "second filler" is disposed within the hollow interior portion of the frame.
• The complaint reserves the right to assert additional claims '826 Patent, Ex. 2, p. 1

U.S. Patent No. 12,357,891 - "Game Paddle" (Issued Jul. 15, 2025)

The Invention Explained

• Problem Addressed: The patent identifies technical challenges in conventional paddle design related to weight distribution, balance, vibration dampening, and durability '891 Patent, col. 1:45-54 Excessive vibration, in particular, can lead to player discomfort and reduced control '891 Patent, col. 1:49-52
• The Patented Solution: The invention describes a paddle with a core material that has at least two "gaps" created by the "absence of the first material of the core" '891 Patent, col. 21:30-32 These gaps are specifically located on opposite sides of the paddle, "substantially adjacent to a throat portion" '891 Patent, col. 21:33-39 A "first filler" material is placed within these gaps, and a frame is disposed between the paddle's surfaces that is "accommodated by" the gaps and forms a boundary along an interior portion of the gaps '891 Patent, col. 21:40-49 Some embodiments also disclose making the filler visible through a window in the edge guard '891 Patent, col. 17:5-12 '891 Patent, FIG. 32
• Technical Importance: This design focuses on modifying the paddle's structure at the throat-a critical area for flex and vibration transmission-to selectively dampen vibrations and adjust the paddle's feel.

Key Claims at a Glance

• The complaint asserts independent claims 1 and 26 '891 Patent, Ex. 4, p. 2 '891 Patent, Ex. 4, p. 9 Compl. ¶28
• Claim 1 Elements:
  • A pickleball paddle with a first and second surface.
  • A core disposed between the surfaces, comprising a "first material."
  • At least two "gaps" in the core defined by the absence of the first material.
  • A first gap on a first side of the paddle "substantially adjacent to a throat portion."
  • A second gap on a second side of the paddle "substantially adjacent to the throat portion."
  • A "first filler" disposed within one or more of the gaps.
  • A "frame" disposed between the surfaces, "accommodated by the first gap and the second gap," and "shaped to form a boundary of each of the first gap and the second gap along an interior portion of the paddle."
• Claim 26 Elements:
  • Claim 26 is similar to Claim 1, reciting a paddle with a core, two gaps at the throat, a filler, and a frame.
  • However, its final element differs, requiring a frame "accommodated by the first gap and the second gap via the frame including one or more indented portions that are accommodated by the first gap and the second gap."
• The complaint reserves the right to assert additional claims '891 Patent, Ex. 4, p. 1

III. The Accused Instrumentality

• Product Identification: The RPM Friction Pro Paddle Compl. ¶13 Compl. ¶24
• Functionality and Market Context:
  • The complaint identifies the accused product as a pickleball paddle sold by the Defendant Compl. ¶4 The infringement allegations are supported by photographs of a disassembled RPM Friction Pro Paddle Compl. Ex. 2, p. 5 Compl. Ex. 4, p. 5
  • These photographs purport to show that the accused paddle is constructed with a polypropylene honeycomb core situated between two outer surfaces Compl. Ex. 2, p. 5 The images further allege the presence of a distinct material (a "first filler") placed in voids between the core and a perimeter frame, as well as a "second filler" inside the frame itself Compl. Ex. 2, p. 14
  • A photograph from the complaint shows the internal components of the accused paddle, including the core, a surrounding frame, and filler material placed in the throat area Compl. Ex. 4, p. 8
  • The complaint does not provide specific details regarding the accused product's market positioning beyond alleging it is sold to resellers, distributors, and consumers throughout the United States Compl. ¶4

IV. Analysis of Infringement Allegations

U.S. Patent No. 12,465,826 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 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 Accused Product includes a polypropylene core with an outer boundary. The complaint alleges this boundary has a first portion (annotated in blue) and a second portion that are shaped and dimensioned as required by the claim.	¶17; Ex. 2, p. 7	col. 4:45-54
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...	A void or gap is allegedly formed between the core's outer boundary and the paddle's internal perimeter frame.	¶17; Ex. 2, p. 8	col. 4:48-49
a first filler disposed within at least a portion of the gap beyond the outer boundary of the core	A red-colored foam-like material is allegedly disposed in the gap between the core and the frame.	¶17; Ex. 2, p. 10	col. 4:61-64
a frame disposed about at least a head portion of the pickleball paddle along an edge portion thereof...	A perimeter frame is allegedly disposed around the head of the Accused Product.	¶17; Ex. 2, p. 11	col. 5:15-18
the frame defining a hollow interior portion; and	The complaint alleges the frame of the Accused Product is hollow.	¶17; Ex. 2, p. 12	col. 5:30-32
a second filler disposed within at least a portion of the hollow interior portion of the frame.	A foam-like "second filler" is allegedly disposed within the hollow interior of the Accused Product's frame. A teardown photo purports to show this filler.	¶17; Ex. 2, p. 13	col. 5:32-34

U.S. Patent No. 12,357,891 Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a core disposed between the first surface and the second surface, the core comprising a first material	The Accused Product includes a polypropylene honeycomb core, which is alleged to be the "first material."	¶28; Ex. 4, p. 5	col. 7:1-5
at least two gaps in the core defined by absence of the first material of the core...	The complaint identifies two alleged gaps in the core, located near the throat, where the honeycomb material is absent.	¶28; Ex. 4, p. 5	col. 17:33-35
a first gap... disposed on a first side of the paddle substantially adjacent to a throat portion thereof, and a second gap... disposed on a second side of the paddle substantially adjacent to the throat portion thereof	The teardown photos purport to show these two gaps located symmetrically on either side of the paddle's throat area.	¶28; Ex. 4, p. 6	col. 17:35-40
a first filler disposed within one or more of the first gap and the second gap	A red-colored foam-like material is allegedly disposed within these throat-adjacent gaps.	¶28; Ex. 4, p. 7	col. 17:41-43
a frame... accommodated by the first gap and the second gap, and wherein the frame is shaped to form a boundary of each of the first gap and the second gap along an interior portion of the paddle.	The Accused Product's frame allegedly fits into the space created by the gaps and forms an interior border for those gaps.	¶28; Ex. 4, p. 8	col. 21:42-49

• Identified Points of Contention:
  • Scope Questions: The infringement theory for the '826 Patent hinges on the geometric claim that the accused core has an "outer boundary" with two distinctly-defined portions relative to the paddle's "internal perimeter." The determination of whether the accused product's core is "shaped and dimensioned" in this specific manner, or if any variation suffices, may be a central dispute.
  • Technical Questions: For the '891 Patent, a primary question will be the proper construction of "substantially adjacent to a throat portion." The patent offers more than one definition for the "throat" '891 Patent, col. 8:1-29, and the parties may dispute which definition applies and whether the accused product's filled voids fall within that defined region. Further, the nature of the interaction between the frame and the gaps-specifically whether the frame is "accommodated by" the gaps and "shaped to form a boundary" in the claimed manner-suggests a possible point of dispute over the precise structural relationship required by the claim.

V. Key Claim Terms for Construction

• The Term: "outer boundary" (including its "first portion" and "second portion") '826 Patent, Claim 1

  • Context and Importance: This term's construction is critical for the '826 Patent, as it defines the shape of the core itself, which in turn defines the location of the allegedly infringing "gap." Infringement depends on proving the accused core has two geometrically distinct boundary sections as measured against the paddle's perimeter.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the core being "cored out" to create a gap, but does not explicitly define the resulting "outer boundary" in the two-part manner required by the claim '826 Patent, col. 4:45-49 The absence of a specific definition may support a broader reading where any variation in the core's edge could satisfy the limitation.
    • Evidence for a Narrower Interpretation: The claim language "shaped and dimensioned to terminate" implies a deliberate and specific geometry. Figures like 7D depict a core (200) with a clear and intentionally uniform setback from the frame (600), creating the gap. A party could argue this shows the "outer boundary" must be a result of a specific engineering design, not incidental manufacturing variations.

• The Term: "substantially adjacent to a throat portion" '891 Patent, Claim 1

  • Context and Importance: This phrase dictates the location of the allegedly infringing "gaps" and "filler." If the accused product's filled voids are found to not be "substantially adjacent" to the "throat portion," the infringement allegation may fail.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term "substantially" is a term of approximation, which may support an interpretation that the gaps only need to be in the general vicinity of the throat.
    • Evidence for a Narrower Interpretation: The specification provides two alternative, relatively precise definitions for the "throat portion," such as "the bottom one third" of the paddle face height ('891 Patent, col. 8:12-29). A party may argue that "adjacent" requires the gaps to be directly next to or within this narrowly-defined region. The patent's figures consistently show the gaps in the curved transition area between the paddle head and handle (e.g., '891 Patent, FIG. 34).

VI. Other Allegations

• Willful Infringement: The complaint alleges that the Defendant, RPM, has had "actual knowledge" of both the '826 Patent and the '891 Patent and of its own infringement Compl. ¶15 Compl. ¶26 The complaint further alleges that RPM's infringement "has been and continues to be willful, intentional, deliberate, or in conscious disregard of rights under the patent," forming the basis for a request for enhanced damages Compl. ¶21 Compl. ¶32

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

• A core issue will be one of definitional scope: can the complex geometric limitations of the '826 patent's "outer boundary" and the locational requirement of the '891 patent's "substantially adjacent to a throat portion" be construed to read on the specific internal structure of the accused paddle? The case may turn on whether the accused product exhibits the precise shapes and locations claimed, or if a more general similarity is sufficient.
• A second key question will involve structural relationships: does the accused product's frame have the specific, cooperative relationship with the internal core and gaps required by the asserted claims? This includes whether the frame is "accommodated by" and "shaped to form a boundary" of the gaps ('891 Patent) and whether it possesses a "hollow interior portion" containing a distinct "second filler" ('826 Patent), raising evidentiary questions about the product's exact construction.