IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF ILLINOIS
`EASTERN DIVISION
`
`
`RIDDELL, INC.,
`
`
`Plaintiff,
`
`INITIAL INFRINGEMENT CONTENTIONS
`
`Pursuant to Local Patent Rule 2.2, Plaintiff Riddell, Inc. (“Riddell”) hereby provides its
`
`Initial Infringement Contentions against Defendant Kranos Corporation, d/b/a Schutt Sports
`
`(“Schutt”) for U.S. Patent Nos. 8,938,818 (“the ’818 patent”), 8,528,118 (“the ’118 patent), and
`
`8,813,269 (“the ’269 patent) (collectively, “the patents-in-suit”). Riddell reserves the right to
`
`amend and/or supplement these contentions as discovery continues in this case.
`
`I.
`
`INFORMATION REQUIRED UNDER LPR 2.2(a) - LPR 2.2(b)
`
`The asserted claims of the patents-in-suit corresponding to each accused product are as
`
`listed in the below table. This list of accused products is based on the information available to
`
`date. To the extent that discovery reveals additional infringing lines of helmets, Riddell reserves
`
`the right to amend and/or supplement these contentions. To the extent that Riddell becomes
`
`aware of additional models within the helmet lines listed here, Riddell’s claim charts should be
`
`treated as applying equally to those models to the extent that they are not colorably different.
`
`Patent
`’818 patent
`
`Asserted Claims
`1-3, 5-6, 8-12, 14-16, 18-
`19, 21-25, 27, 29-32, 34,
`36-42, 49-50, 56-58, 60-
`62, 64-65
`
`Accused Product(s)
`Vengeance - all models, including but not
`limited to:
`Vengeance Z10
`Vengeance Pro
`
`115001-0005/130798119.1
`
`
`
`
`
`Civil Action No.: 1:16-cv-4496
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`
`KRANOS CORPORATION, d/b/a
`SCHUTT SPORTS
`
`
`v.
`
`Defendant.
`
`
`
`
`
`Kranos Exhibit 1027, Page 1
`Kranos Corp. v. Riddell, Inc.
`
`

`
`
`
`’118 patent
`
`’269 patent
`
`1, 2, 5, 6, 11-13, 25-28,
`30, 32-37
`1, 3-9, 11-12
`
`Vengeance VTD
`Vengeance VTD II
`Vengeance DCT
`Youth Vengeance DCT
`Vengeance DCT Hybrid
`Vengeance DCT Hybrid+
`Same as listed for ’818 patent above
`
`All helmets incorporating Schutt’s “Quarter
`Turn Release System,” including but not limited
`to:
`ION4D (standard)
`Air XP Elite (standard)
`DNA Pro+ Elite (standard)
`Vengeance (upgrade)
`Vengeance VTD (upgrade)
`Air XP Pro (upgrade)
`Air XP Pro VTD (upgrade)
`DNA Pro+ (upgrade)
`Youth Vengeance (upgrade)
`Youth Air XP Pro (upgrade)
`Youth DNA Pro+ (upgrade)
`Hybrid+ Series (upgrade)
`Hybrid Series (upgrade)
`Air Standard V (upgrade)
`Schutt’s Quarter Turn Release System
`
`’269 patent
`
`13-20, 22-23
`
`
`
`The applicable statutory subsections of 35 U.S.C. § 271 are as follows:
`
`Claims
`
`Statute
`
`’818 patent - all asserted claims
`
`35 U.S.C. § 271(a) - (c)
`
`’118 patent - claims 1, 2, 5, 6, 11-13, 30, 33-37
`
`35 U.S.C. § 271(a)
`
`’118 patent - claims 25-28, 32
`
`’269 patent - all asserted claims
`
`35 U.S.C. § 271(a) - (c)
`
`35 U.S.C. § 271(a) - (c)
`
`II.
`
`INFORMATION REQUIRED UNDER LPR 2.2(c)
`
`A claim chart corresponding to the ’818 patent is provided herewith as Appendix A. A
`
`claim chart corresponding to the ’118 patent is provided herewith as Appendix B. Throughout
`
`
`115001-0005/130798119.1
`
`- 2 -
`
`
`
`Kranos Exhibit 1027, Page 2
`Kranos Corp. v. Riddell, Inc.
`
`

`
`these claim charts, the claim elements are identified on a Schutt Vengeance DCT helmet, unless
`
`otherwise noted. Because the shell configuration does not meaningfully differ between the
`
`various Vengeance helmet models, these claim charts are intended to be representative of
`
`Riddell’s positions with respect to each of the accused Schutt helmet models. In the event that
`
`Schutt later asserts that there is a meaningful difference between the Vengeance DCT helmet and
`
`any other Vengeance helmets, Riddell reserves the right to amend or supplement these
`
`contentions (and accompanying claim charts).
`
`A claim chart corresponding to the ’269 patent is provided herewith as Appendix C.
`
`Because the Quarter Turn Release System does not meaningfully differ between the various
`
`Schutt helmet models, these claim charts are intended to be representative of Riddell’s positions
`
`with respect to each of the accused products.
`
`III.
`
`INFORMATION REQUIRED UNDER LPR 2.2(d)
`
`As seen in the claim charts provided as Appendices A-C, each element of each asserted
`
`claim is literally present in the accused products. As discovery has just begun and the Court has
`
`not yet provided its claim constructions, however, Riddell reserves the right to later assert that
`
`any element of any of the asserted claims is present in the accused products under the doctrine of
`
`equivalents.
`
`IV.
`
`INFORMATION REQUIRED UNDER LPR 2.2(e)
`
`From the information available to date, it appears that Schutt sells at least some of the
`
`accused helmets without a faceguard. Schutt’s catalogs, web site, manuals, and marketing
`
`materials demonstrate that the helmets are intended to be used with faceguards and instruct
`
`consumers regarding the use of the helmets with faceguards. Thus, to the extent that claims of
`
`the ’818 or ’118 patent require a faceguard, Schutt contributorily infringes and induces
`
`
`115001-0005/130798119.1
`
`- 3 -
`
`
`
`Kranos Exhibit 1027, Page 3
`Kranos Corp. v. Riddell, Inc.
`
`

`
`infringement of the ’818 and ’118 patents by offering to sell and selling Schutt Varsity and
`
`Youth football helmets in the Vengeance model line to customers, buyers, users and others who
`
`directly infringe the patents. Infringement can be found through use of the accused helmets,
`
`which are not staple articles or commodities of commerce suitable for substantial non-infringing
`
`use in an ordinary and intended manner. Schutt contributes to and induces infringement of the
`
`’818 and ’118 patents by inducing its customers to use Schutt Varsity and Youth football helmets
`
`in the Vengeance model line in the United States, with knowledge of the patents at least as of
`
`April 21, 2016.
`
`From the information available to date, it appears that Schutt sells the accused helmets
`
`with a chin strap. In the event that discovery reveals that any accused helmets are sold without a
`
`chin strap, Riddell reserves the right to amend or supplement this disclosure to assert indirect
`
`infringement of relevant claims of the ’818 and ’118 patents under 35 USC § 271(b) and/or 35
`
`USC § 271(c). For example, Schutt’s catalogs, web site, manuals, and marketing materials
`
`demonstrate that the helmets are intended to be used with chin straps and instruct consumers
`
`regarding the use of the helmets with chin straps.
`
`In addition, to the extent that the asserted claims of the ’269 patent are construed to
`
`require a face guard or require the actions of others to constitute infringement, Schutt contributes
`
`to and induces infringement of the ’269 patent by offering to sell and selling the Quarter Turn
`
`Release System (and helmets including the Quarter Turn Release System) to customers, buyers,
`
`users and others who directly infringe the patents. Infringement can be found through use of the
`
`accused Quarter Turn Release System, which is not a staple article or commodity of commerce
`
`suitable for substantial non-infringing use in an ordinary and intended manner. Schutt
`
`contributes to and induces infringement of the ’269 patent by inducing its customers to use the
`
`
`115001-0005/130798119.1
`
`- 4 -
`
`
`
`Kranos Exhibit 1027, Page 4
`Kranos Corp. v. Riddell, Inc.
`
`

`
`Quarter Turn Release System in the United States, with knowledge of the ’269 patent at least as
`
`of July 15, 2015.
`
`V.
`
`INFORMATION REQUIRED UNDER LPR 2.2(f)
`
`All asserted claims of the ’818 patent and the ’118 patent have a priority date of May 1,
`
`2002. All asserted claims of the ’269 patent have a priority date of April 16, 2007.
`
`VI.
`
`INFORMATION REQUIRED UNDER LPR 2.2(g)
`
`Schutt has been on notice of the ’818 patent and the ’118 patent since at least April 21,
`
`2016, the date of filing of Riddell’s Complaint (and on which date Schutt Sports CEO Robert
`
`Erb made public comments responding to the filing of the lawsuit). Schutt has been on notice of
`
`the ’269 patent since at least July 15, 2015, when it was included on a Notice of References
`
`Cited in connection with the prosecution of U.S. Patent Application No. 13/526,077.
`
`Information regarding willful infringement is in the possession of Schutt, which has not
`
`produced documents or provided witnesses for deposition at this early stage of litigation. Riddell
`
`therefore expressly reserves the right to amend or supplement this disclosure based on discovery
`
`in this matter.
`
`VII.
`
`INFORMATION REQUIRED UNDER LPR 2.2(h)
`
`The following Riddell helmets are commercial embodiments of the ’818 patent and the
`
`’118 patent: Riddell SpeedFlex, Riddell Speed, Riddell Speed Classic, Riddell 360, Riddell
`
`Revolution IQ, Riddell Revolution, Riddell Foundation, Riddell Edge, Riddell Revolution
`
`Attack, Riddell Revolution Attack-i, Riddell Attack, Riddell Victor-i, Riddell Victor. These
`
`products are marked with the patent numbers for the patents-in-suit via www.riddell.com/patents.
`
`
`115001-0005/130798119.1
`
`- 5 -
`
`
`
`Kranos Exhibit 1027, Page 5
`Kranos Corp. v. Riddell, Inc.
`
`

`
`Riddell’s Quick Release Facemask Connector is a commercial embodiment of the ’269
`
`patent.
`
` This product
`
`is marked with
`
`the patent number for
`
`the ’269 patent via
`
`www.riddell.com/patents.
`
`Dated: August 5, 2016
`
`PERKINS COIE LLP
`
`
`
`
`Rodger K. Carreyn
`
`RCarreyn@perkinscoie.com
`
`Christopher G. Hanewicz
`
`CHanewicz@perkinscoie.com
`
`
`Gabrielle E. Bina
`GBina@perkinscoie.com
`
` Michelle M. Umberger
` MUmberger@perkinscoie.com
` 1 East Main Street, Suite 201
`
`Madison, WI 53703
`
`(608) 663-7460 (Phone)
`(608) 663-7499 (Facsimile)
`
`Douglas L. Sawyer (ARDC#6275849)
`DSawyer@perkinscoie.com
`131 South Dearborn Street, Suite 1700
`Chicago, IL 60603-5559
`(312) 324-8400 (Phone)
`(312) 324-9400 (Facsimile)
`
`
`
`Attorneys for Plaintiff,
`Riddell, Inc.
`
`
`
`
`115001-0005/130798119.1
`
`- 6 -
`
`
`
`Kranos Exhibit 1027, Page 6
`Kranos Corp. v. Riddell, Inc.
`
`

`
`Kranos Exhibit 1027, Page 7
`Kranos Corp. v. Riddell, Inc.
`
`

`
`APPENDIX C: INITIAL INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,813,269
`
`Claim Language
`
`A sports helmet comprising:
`
`
`CLAIM 1 OF THE ’269 PATENT
`
`Location in Accused Products
`
`The accused products are sports helmets. See, e.g., Schutt’s 2015 Catalog at page 28 (advertising the “Quarter-
`Turn Release System” on various varsity football helmets):
`
`
`
`See also Schutt’s 2015 Catalog at page 50 (advertising the “Quarter-Turn Release System” on various youth
`football helmets):
`
`
`
`
`
`Kranos Exhibit 1027, Page 8
`Kranos Corp. v. Riddell, Inc.
`
`

`
`
`
`See also, e.g., Schutt’s 2016 catalog at pages 29-30.
`
`
`
`
`
`C-2
`
`
`Kranos Exhibit 1027, Page 9
`Kranos Corp. v. Riddell, Inc.
`
`

`
`a shell;
`
`
`The accused products include a shell (image from Schutt 2015 Catalog page 28):
`
`shell
`
`a faceguard;
`
`
`The accused products include a faceguard:
`
`
`
`faceguard
`
`
`While it appears that Schutt’s face guards are sometimes sold separately from Schutt’s helmet shells, Schutt’s
`catalogs, web site, manuals, and marketing materials demonstrate that the helmets are intended to be used with
`faceguards and instruct consumers regarding the use of the helmets with faceguards. See, e.g., Schutt 2015
`Football Catalog; Schutt website (http://www.schuttsports.com/).
`
`The accused products include a faceguard connector assembly:
`
`faceguard
`connector
`assembly
`
`
`
`C-3
`
`
`a faceguard connector assembly having a
`bracket with at least one channel that
`receives an extent of the faceguard, the
`faceguard connector assembly further
`having a releasable coupler mechanism that
`extends through both the bracket and an
`opening in the shell to secure the faceguard
`to the shell in a use position, the releasable
`coupler mechanism including:
`
`
`
`Kranos Exhibit 1027, Page 10
`Kranos Corp. v. Riddell, Inc.
`
`

`
`The faceguard connector assembly has a bracket with at least one channel that receives an extent of the
`faceguard, as well as a releasable coupler mechanism that extends through both the bracket and an
`opening in the shell to secure the faceguard to the shell in a use position:[NN1]
`
`releasable
`coupler
`mechanism
`
`bracket
`
`channel that
`receives an extent
`of the faceguard
`
`
`The releasable coupler mechanism includes a washer having a main body that extends substantially perpendicular
`from a flange of the washer, the main body having a central opening and extending into and positioned within the
`shell opening; a cylindrical body that extends through the bracket and the shell opening, wherein an extent of the
`cylindrical body is received by the central opening of the washer in the use position; and a head positioned within
`the bracket, the head configured to receive a tool that applies an actuation force:
`
`cylindrical body
`
`head configured to
`receive a tool that
`applies an actuation
`force
`
`main body of the washer
`
`flange of the washer
`
`central opening
`
`
`
`
`
`C-4
`
`
` a
`
` washer having a main body that extends
`substantially perpendicular from a flange of
`the washer, the main body having a central
`opening and extending into and positioned
`within the shell opening;
`
`a cylindrical body that extends through the
`bracket and the shell opening, wherein an
`extent of the cylindrical body is received by
`the central opening of the washer in the use
`position; and,
`
`a head positioned within the bracket, the
`head configured to receive a tool that
`applies an actuation force; and,
`
`Kranos Exhibit 1027, Page 11
`Kranos Corp. v. Riddell, Inc.
`
`

`
`Schutt provides the following instructions for using the Quarter-Turn Release System (by way of example):
`
`
`
`C-5
`
`
`Kranos Exhibit 1027, Page 12
`Kranos Corp. v. Riddell, Inc.
`
`

`
`
`
`C-6
`
`
`Kranos Exhibit 1027, Page 13
`Kranos Corp. v. Riddell, Inc.
`
`

`
`See also video at https://www.youtube.com/watch?v=V40WPO17Qsg (demonstrating how the Quarter-Turn
`Release System works).
`
`As seen in the instructions reproduced above (see Step 14 for “Elite” and Step 9 for “Ion), in the accused
`products, the actuation force is applied to the coupler mechanism to move the coupler mechanism from the use
`position to a disconnected position that allows for removal of the bracket from the shell to permit the faceguard to
`be displaced with respect to the shell:
`
`See also, e.g., Schutt’s 2015 Catalog at page 9 (left) and 2016 Catalog at page 11 (right):
`
`wherein the actuation force is applied to the
`coupler mechanism to move the coupler
`mechanism from the use position to a
`disconnected position that allows for
`removal of the bracket from the shell to
`permit the faceguard to be displaced with
`respect to the shell.
`
`
`
`See also, e.g., Schutt’s Website:
`
`
`
`
`
`
`
`C-7
`
`
`Kranos Exhibit 1027, Page 14
`Kranos Corp. v. Riddell, Inc.
`
`

`
`
`See also video at https://www.youtube.com/watch?v=V40WPO17Qsg (demonstrating how the Quarter-Turn
`Release System works):
`
`
`
`
`
`
`
`C-8
`
`
`Kranos Exhibit 1027, Page 15
`Kranos Corp. v. Riddell, Inc.
`
`

`
`Claim Language
`
`The sports helmet of claim 1,
`wherein the head has an outer diameter
`that exceeds both an outer diameter of the
`cylindrical body and an outer diameter of
`the central opening.
`
`CLAIM 3 OF THE ’269 PATENT
`
`Location in Accused Products
`
`See claim chart for Claim 1, supra.
`As shown below, an outer diameter of the head exceeds both an outer diameter of the cylindrical body and an outer
`diameter of the central opening:
`
`cylindrical body
`
`head
`
`central opening
`
`
`
`
`
`
`
`CLAIM 4 OF THE ’269 PATENT
`
`Location in Accused Products
`
`See claim chart for Claim 1, supra.
`As shown below, the cylindrical body has a first segment with a first diameter and a second segment with a second
`diameter, wherein the first diameter is different than the second diameter:
`
`Claim Language
`
`The sports helmet of claim 1,
`the cylindrical body having a first
`segment with a first diameter and a
`second segment with a second diameter,
`wherein the first diameter is different than
`the second diameter.
`
`C-9
`
`
`Kranos Exhibit 1027, Page 16
`Kranos Corp. v. Riddell, Inc.
`
`

`
`second segment
`with a second
`diameter
`
`first segment
`with a first
`diameter
`
`Claim Language
`
`The sports helmet of claim 4,
`the releasable coupler mechanism further
`comprising a spring, the spring being
`operably connected to the first segment of
`the cylindrical body.
`
`
`
`
`
`
`
`CLAIM 5 OF THE ’269 PATENT
`
`Location in Accused Products
`
`See claim chart for Claim 4, supra.
`As shown below, the releasable coupler mechanism comprises a spring, the spring being operably connected to
`the first segment of the cylindrical body:
`
`
`spring
`
`first
`segment of
`the
`cylindrical
`body
`
`
`
`
`
`C-10
`
`
`Kranos Exhibit 1027, Page 17
`Kranos Corp. v. Riddell, Inc.
`
`

`
`Claim Language
`
`The sports helmet of claim 5,
`wherein the spring is retained by a notch
`formed between the first segment of the
`cylindrical body and the second segment of
`the cylindrical body.
`
`CLAIM 6 OF THE ’269 PATENT
`
`Location in Accused Products
`
`See claim chart for Claim 5, supra.
`As shown below, the spring is retained by a notch formed between the first segment of the cylindrical body and
`the second segment of the cylindrical body:
`
`notch
`
`
`
`
`
`
`
`CLAIM 7 OF THE ’269 PATENT
`
`Location in Accused Products
`
`See claim chart for Claim 1, supra.
`As shown in the images above, the cylindrical body lacks threads.
`
`
`CLAIM 8 OF THE ’269 PATENT
`
`Location in Accused Products
`
`See claim chart for Claim 1, supra.
`As shown in the images above, the washer lacks threads.
`
`
`Claim Language
`
`The sports helmet of claim 1,
`wherein the cylindrical body lacks threads.
`
`Claim Language
`
`The sports helmet of claim 1,
`wherein the washer lacks threads.
`
`C-11
`
`
`Kranos Exhibit 1027, Page 18
`Kranos Corp. v. Riddell, Inc.
`
`

`
`Claim Language
`
`Location in Accused Products
`
`CLAIM 9 OF THE ’269 PATENT
`
`See claim chart for Claim 1, supra.
`See description of this claim element in the claim chart for Claim 4, supra.
`
`
`As shown below, the second segment has an engaging structure, the main body of the washer has an internal
`engaging structure, and the internal engaging structure of the main body engages the engaging structure of the
`second segment in the use position.
`
`internal engaging
`structure of the main
`body of the washer
`
`
`
`The sports helmet of claim 1,
`the cylindrical body having a first segment
`with a first diameter and a second segment
`with a second diameter,
`wherein the second segment has an
`engaging structure, the main body of the
`washer having an internal engaging
`structure, and
`wherein the internal engaging structure of
`the main body engages the engaging
`structure of the second segment in the use
`position.
`
`
`engaging structure of
`
`the second segment
`
`
`
`
`CLAIM 11 OF THE ’269 PATENT
`
`Claim Language
`
`Location in Accused Products
`
`The sports helmet of claim 1,
`wherein an extent of the flange engages an
`inner surface of the shell in the use position.
`
`See claim chart for Claim 1, supra.
`
`As shown below, an extent of the flange engages an inner surface of the helmet in the use position:
`
`
`
`
`C-12
`
`
`Kranos Exhibit 1027, Page 19
`Kranos Corp. v. Riddell, Inc.
`
`

`
`flange
`
`inner surface of
`the helmet
`
`
`
`CLAIM 12 OF THE ’269 PATENT
`
`
`
`Claim Language
`
`Location in Accused Products
`
`The sports helmet of claim 4,
`wherein the second segment of the
`cylindrical body has an end wall opening
`that spans a diameter of the second segment
`
`See claim chart for Claim 4, supra.
`As shown below, the second segment of the cylindrical body has an end wall opening that spans a diameter of the
`second segment:
`
`
`
`
`
`
`
`end wall opening
`that spans a
`diameter of the
`second segment
`
`C-13
`
`
`Kranos Exhibit 1027, Page 20
`Kranos Corp. v. Riddell, Inc.
`
`

`
`CLAIM 13 OF THE ’269 PATENT
`
`Location in Accused Products
`
`The accused Quarter-Turn Release System is a quick release connector for securing a faceguard to a football helmet:
`
`Claim Language
`
`A quick release connector for securing a
`faceguard to a football helmet, the
`connector comprising:
`
`
`
`
`See also images from Schutt catalog provided in the claim chart for Claim 1, supra.
`
`
`
`C-14
`
`
`Kranos Exhibit 1027, Page 21
`Kranos Corp. v. Riddell, Inc.
`
`

`
`The connector includes a bracket with an aperture and at least one channel configured to receive an extent of the
`faceguard:
`
`
`
`channel
`configured to
`receive an
`extent of the
`faceguard
`
`bracket
`
`aperture
`
`
`
`
`The connector includes a releasable coupler mechanism that extends through both the bracket aperture and an
`opening in the helmet to secure the faceguard to the helmet in a use position:
`
`
`
`releasable coupler
`mechanism that
`extends through both
`the bracket aperture
`and an opening in the
`helmet
`
`
`
`
`
`
`C-15
`
`
`a bracket with a aperture and at least one
`channel configured to receive an extent of
`the faceguard;
`
`
`
`a releasable coupler mechanism that
`extends through both the bracket aperture
`and an opening in the helmet to secure the
`faceguard to the helmet in a use position,
`the releasable coupler mechanism
`including:
`
`
`
`Kranos Exhibit 1027, Page 22
`Kranos Corp. v. Riddell, Inc.
`
`

`
`The releasable coupler mechanism includes a washer having a main body that extends substantially perpendicular
`from a flange of the washer, the main body having a central opening and extending into and positioned within the
`helmet opening; a cylindrical body that extends through the bracket and the helmet opening, wherein an extent of the
`cylindrical body is received by the central opening of the washer in the use position; and, a head positioned within
`the bracket, the head configured to receive a tool that applies an actuation force:
`
`
`head configured to
`receive a tool that
`applies an
`actuation force
`
`central opening
`
`
`
`a washer having a main body that extends
`substantially perpendicular from a flange
`of the washer, the main body having a
`central opening and extending into and
`positioned within the helmet opening;
`
`a cylindrical body that extends through
`the bracket and the helmet opening,
`wherein an extent of the cylindrical body
`is received by the central opening of the
`washer in the use position; and,
`
`a head positioned within the bracket, the
`head configured to receive a tool that
`applies an actuation force; and,
`
`
`
`wherein the actuation force is applied to
`the coupler mechanism to displace the
`coupler mechanism from the use position
`to a disconnected position that allows for
`removal of the bracket from the helmet to
`permit the faceguard to be displaced with
`respect to the helmet.
`
`
`
`cylindrical body
`
`main body of the washer
`
`flange of the washer
`
`See also the instructions reproduced in the claim chart for claim 1, supra.
`
`As seen in the instructions reproduced above (see Step 14 for “Elite” and Step 9 for “Ion), in the accused products,
`the actuation force is applied to the coupler mechanism to displace the coupler mechanism from the use position to a
`disconnected position that allows for removal of the bracket from the helmet to permit the faceguard to be displaced
`with respect to the helmet:
`See also, e.g., Schutt’s 2015 Catalog at page 9 (left) and 2016 Catalog at page 11 (right):
`
`C-16
`
`
`Kranos Exhibit 1027, Page 23
`Kranos Corp. v. Riddell, Inc.
`
`

`
`See also, e.g., Schutt’s Website:
`
`
`
`
`
`
`
`
`
`See also video at https://www.youtube.com/watch?v=V40WPO17Qsg (demonstrating how the Quarter-Turn Release
`System works):
`
`
`
`C-17
`
`
`Kranos Exhibit 1027, Page 24
`Kranos Corp. v. Riddell, Inc.
`
`

`
`
`
`CLAIM 14 OF THE ’269 PATENT
`
`
`
`Claim Language
`
`The quick release connector of claim 13,
`wherein the head has an outer diameter that
`exceeds both an outer diameter of the
`cylindrical body and an outer diameter of
`the central opening.
`
`Location in Accused Products
`
`See claim chart for Claim 13, supra.
`See description of this claim element in the claim chart for Claim 3, supra.
`
`
`
`
`
`
`CLAIM 15 OF THE ’269 PATENT
`
`Claim Language
`
`The quick release connector of claim 13,
`the cylindrical body having a first segment
`with a first diameter and a second segment
`with a second diameter, wherein the first
`diameter is different than the second
`diameter.
`
`Location in Accused Products
`
`See claim chart for Claim 13, supra.
`See description of this claim element in the claim chart for Claim 4, supra.
`
`
`
`
`C-18
`
`
`Kranos Exhibit 1027, Page 25
`Kranos Corp. v. Riddell, Inc.
`
`

`
`CLAIM 16 OF THE ’269 PATENT
`
`Claim Language
`
`The quick release connector of claim 15,
`the releasable coupler mechanism further
`comprising a spring, the spring being
`operably connected to the first segment of
`the cylindrical body.
`
`Location in Accused Products
`
`See claim chart for Claim 15, supra.
`See description of this claim element in the claim chart for Claim 5, supra.
`
`
`
`
`
`
`CLAIM 17 OF THE ’269 PATENT
`
`Claim Language
`
`The quick release connector of claim 16,
`wherein the spring is retained by a notch
`formed between the first segment of the
`cylindrical body and the second segment of
`the cylindrical body.
`
`Location in Accused Products
`
`See claim chart for Claim 16, supra.
`See description of this claim element in the claim chart for Claim 6, supra.
`
`
`
`
`
`
`CLAIM 18 OF THE ’269 PATENT
`
`Claim Language
`
`The quick release connector of claim 13,
`wherein the cylindrical body lacks threads.
`
`Location in Accused Products
`
`See claim chart for Claim 13, supra.
`See description of this claim element in the claim chart for Claim 7, supra.
`
`CLAIM 19 OF THE ’269 PATENT
`
`Claim Language
`
`The quick release connector of claim 13,
`wherein the washer lacks threads.
`
`Location in Accused Products
`
`See claim chart for Claim 13, supra.
`See description of this claim element in the claim chart for Claim 8, supra.
`
`
`C-19
`
`
`Kranos Exhibit 1027, Page 26
`Kranos Corp. v. Riddell, Inc.
`
`

`
`CLAIM 20 OF THE ’269 PATENT
`
`Claim Language
`
`Location in Accused Products
`
`See claim chart for Claim 13, supra.
`See description of this claim element in the claim chart for Claim 9, supra.
`
`
`The quick release connector of claim 13,
`the cylindrical body having a first segment
`with a first diameter and a second segment
`with a second diameter, wherein the second
`segment has an engaging structure, the main
`body of the washer having an internal
`engaging structure, and wherein the internal
`engaging structure of the main body
`engages the engaging structure of the
`second segment in the use position.
`
`
`
`CLAIM 22 OF THE ’269 PATENT
`
`Claim Language
`
`The quick release connector of claim 13,
`wherein an extent of the flange engages an
`inner surface of the helmet in the use
`position.
`
`Location in Accused Products
`
`See claim chart for Claim 13, supra.
`See description of this claim element in the claim chart for Claim 11, supra.
`
`
`
`
`CLAIM 23 OF THE ’269 PATENT
`
`Claim Language
`
`Location in Accused Products
`
`The quick release connector of claim 15,
`wherein the second segment of the
`cylindrical body has an end wall opening
`that spans a diameter of the second segment.
`
`See claim chart for Claim 15, supra.
`See description of this claim element in the claim chart for Claim 12, supra.
`
`
`
`
`C-20
`
`
`Kranos Exhibit 1027, Page 27
`Kranos Corp. v. Riddell, Inc.