DCT

1:26-cv-07429

100 Speedlab LLC v. Reckless Vision Co LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:26-cv-07429, S.D.N.Y., 08/31/2026
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant has committed acts of patent infringement in the district and maintains a regular and established place of business there.
  • Core Dispute: Plaintiff alleges that Defendant's "Carnage" line of sports eyewear, including goggles and roll-off film systems, infringes two of Plaintiff's utility patents and two of its design patents.
  • Technical Context: The dispute is in the field of high-performance sports eyewear, where features that improve vision clarity, comfort, and durability are critical for activities like motocross and skiing.
  • Key Procedural History: Plaintiff alleges it provided Defendant with actual notice of infringement for three of the four asserted patents via a cease-and-desist letter on April 1, 2026, approximately five months before filing the complaint. This event is cited as a basis for the willfulness allegation.

Case Timeline

Date Event
2013-01-25 '218 Patent Priority Date
2014-05-13 '278 Patent Priority Date
2014-05-16 '558 Patent Priority Date
2016-05-03 U.S. Design Patent D755,278 Issues
2017-12-12 U.S. Patent 9,839,558 Issues
2019-12-31 '799 Patent Priority Date
2020-08-25 U.S. Patent 10,751,218 Issues
2024-09-24 U.S. Design Patent D1,043,799 Issues
2026-04-01 Plaintiff sends cease-and-desist letter to Defendant
2026-08-27 Date of screenshots taken from Defendant's retail website
2026-08-31 Complaint Filing Date

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

U.S. Patent No. 9,839,558 - "ROLL-OFF FILM SYSTEM"

  • Patent Identification: U.S. Patent No. 9,839,558, titled "ROLL-OFF FILM SYSTEM," issued on December 12, 2017 Compl. ¶7

The Invention Explained

  • Problem Addressed: In sports like motocross, roll-off film systems are used to clear a goggle lens, but dirt and mud can enter the interface between the film and the lens, or get inside the film canisters, reducing visibility and potentially jamming the mechanism '558 Patent, col. 1:30-38
  • The Patented Solution: The invention is a roll-off film system with canisters featuring specifically shaped "wing portions" and a "blade portion." These elements are designed to form a barrier that seals the film against the lens to prevent debris intrusion and to scrape mud off the film as it is wound into the receiving canister '558 Patent, col. 2:40-54 The blade section is also slanted to help guide debris away from the user's field of view '558 Patent, col. 2:55-59
  • Technical Importance: The design aims to enhance the reliability of roll-off systems in harsh conditions, a critical factor for competitive racers who depend on consistently clear vision.

Key Claims at a Glance

  • The complaint asserts infringement of the '558 Patent, referencing an unprovided claim chart exhibit Compl. ¶19 Independent Claim 1 is representative of the core technology.
  • Independent Claim 1 includes these essential elements:
    • A film dispensing canister and a film receiving canister.
    • The receiving canister includes a "blade portion" and "upper and lower wing portions".
    • These portions form a "continuous surface" with a "broad, U-shape" that is "configured to collect debris from the film".
    • The geometry of the upper and lower triangular surfaces of the wing portions is specifically defined relative to the blade portion.
  • The complaint does not specify any dependent claims.

U.S. Patent No. 10,751,218 - "AIR COOLED GOGGLE"

  • Patent Identification: U.S. Patent No. 10,751,218, titled "AIR COOLED GOGGLE," issued on August 25, 2020 Compl. ¶8

The Invention Explained

  • Problem Addressed: Sports goggles can trap heat and moisture against the user's skin, leading to discomfort and lens fogging, as they typically prevent natural air cooling of the covered skin area '218 Patent, col. 1:21-25
  • The Patented Solution: The patent describes a goggle frame with integrated cooling vents. These vents consist of an aperture on the frame's outer surface connected by a channel to a second aperture on the frame's inner surface, which is covered by a porous foam liner '218 Patent, col. 3:25-36 This structure allows external air to flow through the frame itself and be disbursed directly into the foam liner, actively cooling the user's skin without directing airflow, dust, or irritants into the eye area '218 Patent, col. 1:26-32 '218 Patent, Fig. 2
  • Technical Importance: This invention provides a method for managing heat and fogging that is distinct from traditional lens-venting, focusing instead on cooling the skin-goggle interface to improve user comfort and performance.

Key Claims at a Glance

  • The complaint asserts infringement of the '218 Patent, referencing an unprovided claim chart exhibit Compl. ¶28 Independent Claim 1 is representative.
  • Independent Claim 1 includes these essential elements:
    • A flexible goggle frame with a lens and a flexible foam liner configured to contact the user's face.
    • A "first aperture" on the outer surface of the frame.
    • A "second aperture" on the inner surface of the frame, covered by the flexible liner.
    • A "channel" extending through the frame, connecting the first and second apertures.
    • The channel is configured to "direct airflow" from the first aperture to the second, dispersing it "directly into the flexible liner to cool the user's face".
  • The complaint does not specify any dependent claims.

U.S. Design Patent No. D1,043,799 - "GOGGLES"

  • Patent Identification: U.S. Design Patent No. D1,043,799, titled "GOGGLES," issued on September 24, 2024 Compl. ¶9
  • Technology Synopsis: This patent protects the ornamental design for a pair of goggles. The claim covers the specific aesthetic and non-functional visual characteristics of the goggle frame, including its particular contours and overall shape, as illustrated in the patent's figures.
  • Asserted Claims: The patent contains a single claim for "The ornamental design for goggles, as shown and described" '799 Patent, "CLAIM"
  • Accused Features: Plaintiff alleges that the overall visual appearance of Defendant's "Carnage" goggles infringes the claimed ornamental design Compl. ¶37

U.S. Design Patent No. D755,278 - "CANISTERS FOR A ROLL OFF FILM SYSTEM"

  • Patent Identification: U.S. Design Patent No. D755,278, titled "CANISTERS FOR A ROLL OFF FILM SYSTEM," issued on May 3, 2016 Compl. ¶10
  • Technology Synopsis: This patent protects the ornamental design for the canisters of a goggle roll-off film system. The protection extends to the unique visual appearance of the canisters, including their shape, proportions, and surface contours, as shown in the patent's drawings.
  • Asserted Claims: The patent contains a single claim for "The ornamental design for canisters for a roll off film system, as shown and described" '278 Patent, "CLAIM"
  • Accused Features: Plaintiff alleges that the ornamental design of the canisters used with Defendant's "Carnage" roll-off system infringes the claimed design Compl. ¶46

III. The Accused Instrumentality

  • Product Identification: The accused instrumentalities are eyewear products marketed by Defendant under the name "Carnage" or similar, which include goggles, lenses, and roll-off system products Compl. ¶12 Compl. ¶13
  • Functionality and Market Context: The "Carnage" products are sold in the United States through Defendant's retail website and third-party resellers Compl. ¶12 Plaintiff asserts that Defendant is a direct competitor Compl. ¶14 The complaint includes several images of the accused products, which depict goggles with and without an attached roll-off film system. One image shows an assembled "Carnage" goggle with a roll-off film system, illustrating the overall product configuration Compl. p. 4 Another image displays the goggle frame without a lens, providing a view of the frame's inner structure and foam liner Compl. p. 5

IV. Analysis of Infringement Allegations

Although the complaint references claim-chart exhibits that were not provided, the following tables summarize the infringement allegations for the utility patents based on the complaint's text and supporting images.

'558 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a film receiving canister configured to receive the film dispensed from the film dispensing canister The accused "Carnage" roll-off system includes a film receiving canister. ¶13; ¶19 col. 9:11-15
a blade portion... an upper wing portion and a lower wing portion with the blade portion disposed between the upper and the lower wing portions The accused canister incorporates structures that Plaintiff alleges are a blade portion and upper and lower wing portions. ¶13; ¶19 col. 9:19-22
wherein an upper triangular surface of the upper wing portion, a sloping surface of the blade portion, and a lower triangular surface of the lower wing portion form a continuous surface configured to collect debris from the film The combination of the alleged blade and wing portions on the accused canister is alleged to form a continuous, U-shaped surface that collects debris. ¶13; ¶19 col. 9:22-26

'218 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a flexible frame comprising an outer surface and an inner surface... a flexible liner provided on the inner surface... and configured to contact the user's face The accused "Carnage" goggle has a flexible frame with an inner foam liner designed to press against the user's face. ¶13; ¶28 col. 3:59-4:3
a first aperture disposed on the outer surface of the flexible frame The accused goggle frame has apertures on its outer surface, as seen in the complaint's product images. ¶13; ¶28 col. 4:4-5
a second aperture disposed on the inner surface of the flexible frame... a channel extending through the flexible frame, connected to the first aperture and to the second aperture The accused goggle frame is alleged to have apertures on its inner surface connected to the outer apertures by an internal channel. ¶13; ¶28 col. 4:6-12
configured to direct airflow from the first aperture to the second aperture to disperse airflow flowing through the second aperture directly into the flexible liner to cool the user's face The venting system on the accused goggle is alleged to direct air into the foam liner to cool the user's skin. ¶13; ¶28 col. 4:12-18
  • Identified Points of Contention:
    • For the '558 Patent: A central issue will be structural. The analysis will question whether the components of the accused canister meet the specific geometric and relational limitations of the claim, such as forming a "continuous surface" with a "broad, U-shape" composed of "triangular" and "sloping" surfaces.
    • For the '218 Patent: A key point of contention will likely be functional. The court may need to determine if the vents on the accused goggle perform the specific function of directing air "directly into the flexible liner to cool the user's face," as required by the claim, or if they serve a different, non-infringing purpose, such as general anti-fog ventilation of the lens cavity.

V. Key Claim Terms for Construction

Term for Construction: "continuous surface" ('558 Patent)

  • Context and Importance: This term is critical because Claim 1 requires the upper wing, blade, and lower wing portions to collectively form a "continuous surface" with a "broad, U-shape." Infringement will depend on whether the accused canister's structure, which may have seams or distinct parts, can be considered "continuous" in the context of the patent.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent describes the surfaces forming a "continuous, broad U-shaped surface" without imposing a requirement that they be a single, monolithic piece, which may support an interpretation where assembled components can form a "continuous" whole '558 Patent, col. 6:3-5
    • Evidence for a Narrower Interpretation: A defendant may argue that the term implies a seamless or uninterrupted surface, pointing to the patent's figures (e.g., Fig. 6) as defining the specific unbroken contour required by the claim '558 Patent, Fig. 6

Term for Construction: "disperse airflow... directly into the flexible liner" ('218 Patent)

  • Context and Importance: This functional language is central to the infringement analysis. The case may turn on the evidentiary standard for proving that airflow is not just generally vented, but specifically directed "into" the foam liner material itself for the purpose of cooling the user's face.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent's abstract describes a general goal of allowing "airflow through the frame to the flexible liner," which could support a less restrictive reading of the claim's functional requirement '218 Patent, abstract
    • Evidence for a Narrower Interpretation: The specification explicitly states the invention's purpose is to "disburse fresh air across areas where the goggle frame is in direct contact with the user's skin, cooling the user" '218 Patent, col. 1:26-30 This, combined with the claim language, suggests a targeted cooling action on the skin-contacting foam, not just passive ventilation of the goggle's interior space.

VI. Other Allegations

  • Indirect Infringement: The complaint does not contain a separate count for indirect infringement.
  • Willful Infringement: The complaint alleges that Defendant's infringement of the '558, '218, and '799 patents is willful Compl. ¶17 Compl. ¶20 Compl. ¶29 Compl. ¶38 The alleged basis for willfulness is Defendant's continuation of infringing activities after receiving a cease-and-desist letter on April 1, 2026, which allegedly provided actual notice of the patents and infringement Compl. ¶15

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

  1. Structural Interpretation ('558 Patent): A primary issue will be whether the physical construction of the accused "Carnage" roll-off canister meets the specific geometric requirements of Claim 1, particularly whether its components form a "continuous surface" with a "broad, U-shape" as defined in the '558 patent.
  2. Functional Operation ('218 Patent): A key evidentiary question will be one of technical function: does the venting system on the accused goggle perform the claimed function of directing cooling air "directly into the flexible liner," or does it operate in a materially different way, such as by providing general ventilation to the lens area?
  3. Ornamental Design Comparison ('799 and '278 Patents): The design patent claims will turn on the "ordinary observer" test. The central question for the court will be whether an ordinary observer, familiar with prior art designs, would find the overall ornamental appearance of the accused "Carnage" goggles and canisters to be substantially the same as the designs claimed in the '799 and '278 patents.