Gambit Training Techs. v. Simon - Complaint
Gambit Training Techs. v. Simon - Complaint
Plaintiff Gambit Training Technologies, LLC (“Gambit”) brings this action to obtain a
declaratory judgment that its hockey training device does not infringe any of the claims of U.S.
Patent Nos. D801, 456 (“the ’456 design patent”), 9,636,561 (“the ’561 patent”), and 10,076,695
(“the ’695 patent”) (collectively, the “Simon Patents”), purportedly owned by Defendant Thomas
C. Simon (“Simon”). This action is filed pursuant to 28 U.S.C. §§ 2201 and 2202 for the purpose
PARTIES
1. Plaintiff Gambit is a Texas limited liability company with its principal place of
business located at 1905 Stone Myers Parkway, Grapevine, Texas 76051. Gambit’s principal office
is in the Northern District of Texas. Gambit makes the SuperDeker®, a patented, electronic,
dryland training device for hockey players. SuperDeker® devices simulate the anticipation,
New Hampshire. Simon may be served at his place of residence at 580 Amherst Street, Manchester,
1
Case 3:20-cv-03748-L Document 1 Filed 12/30/20 Page 2 of 16 PageID 2
New Hampshire 03104. According to Simon’s counsel, 1 Simon is “the President and Founder of
Plastix Graphixs and Shooting Star Hockey[,]” 2 which offer for sale “unique plastic” boards that
in the State of Texas but does not maintain a regular place of business or a designated agent for
service here and this lawsuit arises out of that business, Simon may be served with process by
1
According to Simon’s June 17, 2019 Application for Renewal of Trade Name filed with the New
Hampshire Secretary of State (attached hereto as Exhibit 1), Simon is the “Owner” and “CEO” of
Plastix Graphixs.
2
October 20, 2020 patent enforcement letter (“Letter”) (attached hereto as Exhibit 2) at 1.
3
See https://www.shootingstarhockey.com/about.
2
Case 3:20-cv-03748-L Document 1 Filed 12/30/20 Page 3 of 16 PageID 3
serving the Texas Secretary of State at Service of Process, Secretary of State, P.O. Box 12079,
Austin, Texas 78711. See FED. R. CIV. P. 4(e); TEX. CIV. PRAC. & REM. CODE § 17.044(b).
3. Gambit brings this action under the Declaratory Judgment Act, 28 U.S.C. §§ 2201
and 2202, to obtain a judicial declaration that the Simon Patents, purportedly owned by Simon,
have not been infringed by Gambit. This action arises under the patent laws of the United States,
35 U.S.C. §§ 1-390, and is based upon an actual and justiciable controversy between the parties
4. This Court has jurisdiction over the subject matter of this action under 28 U.S.C.
5. This Court has personal jurisdiction over Simon because, by voluntarily sending a
patent enforcement letter to Gambit in this judicial district that claims the SuperDeker®
“infringes” the Simon Patents, he submitted himself to the Court’s personal jurisdiction. See Jack
Henry & Assocs., Inc. v. Plano Encryption Techs., 910 F.3d 1199, 1202-06 (Fed. Cir. 2018). Upon
information and belief, Simon also has sufficient business or contacts within the State of Texas to
justify jurisdiction under the United States Constitution and the Texas Long Arm Statute.
6. Venue is proper in this Court under 28 U.S.C. § 1391(b) because a substantial part
of the events giving rise to the claims occurred in this judicial district. Upon information and belief,
Simon regularly engages in business within this judicial district. As stated herein, Simon has also
threatened patent infringement against Gambit in this judicial district. See Deprenyl Animal
Health, Inc. v. Univ. of Toronto Innovations Found., 297 F.3d 1343, 1356 (Fed. Cir. 2002) (“Just
as a state has a substantial interest in preventing patent infringement within its borders, it also has
3
Case 3:20-cv-03748-L Document 1 Filed 12/30/20 Page 4 of 16 PageID 4
a substantial interest in protecting its residents from claims of patent infringement that may be
unwarranted . . . .”).
8. A screenshot from the January 23, 2013 video titled “Superdeker home version”
4
Case 3:20-cv-03748-L Document 1 Filed 12/30/20 Page 5 of 16 PageID 5
10. Later versions of the SuperDeker® only had one set of rubber bands on each end, as
shown in these pictures taken at two different hockey tournaments in 2014 where the device was
5
Case 3:20-cv-03748-L Document 1 Filed 12/30/20 Page 6 of 16 PageID 6
11. Below is a February 23, 2015 photograph of the box for the SuperDeker®, showing
12. As early as August 2014, Simon began making a hockey training device that bears
Shooting Star Hockey’s logo and includes rubber bands, allowing a player to practice hockey puck
skills such as stick handling, passing, and shooting. In fact, Simon’s wife, Sharon Simon, published
4
A picture (from left to right) of Sharon, Thomas, and Connor Simon is published on Shooting
Star Hockey’s website. See https://www.shootingstarhockey.com/about.
6
Case 3:20-cv-03748-L Document 1 Filed 12/30/20 Page 7 of 16 PageID 7
13. Several screenshots of the August 17, 2014 video titled “Shooting Star Hockey
7
Case 3:20-cv-03748-L Document 1 Filed 12/30/20 Page 8 of 16 PageID 8
8
Case 3:20-cv-03748-L Document 1 Filed 12/30/20 Page 9 of 16 PageID 9
9
Case 3:20-cv-03748-L Document 1 Filed 12/30/20 Page 10 of 16 PageID 10
14. Below is a comparison of the device in the August 17, 2014 video with Figure 1 of
the ’456 design patent (filed March 1, 2017). Figure 1 depicts two suspended rubber bands on
opposite sides of the device, four flanged vertical posts, and rounded corners.
10
Case 3:20-cv-03748-L Document 1 Filed 12/30/20 Page 11 of 16 PageID 11
15. Below is a comparison of the device in the August 17, 2014 video with Figure 11
of the ’695 patent (filed June 2, 2017). Figure 11 depicts two suspended rubber bands on opposite
sides of the device, four flanged vertical posts, and rounded corners.
11
Case 3:20-cv-03748-L Document 1 Filed 12/30/20 Page 12 of 16 PageID 12
16. During the prosecution of the Simon Patents, Simon failed to disclose the August
17, 2014 video to the United States Patent and Trademark Office. 5
17. On October 20, 2020, Simon’s litigation counsel wrote to Gambit identifying the
Simon Patents (Letter at 1), stating “[a] legal analysis has been performed to compare the [Simon]
Patents to the SuperDeker Training Device and it infringes” (Id. at 2), and inviting “a non-
18. To further Simon’s threat of patent enforcement against Gambit, Simon made clear
that “[i]n the alternative, [he] would entertain an offer to purchase all right, title, and interest to
19. Additionally, Simon demanded a “written response” from Gambit “within ten (10)
Simon’s counsel, Peter A. Nieves, about Simon’s patent infringement allegations. During the
teleconference, Mr. Joyner requested a copy of Simon’s claim charts identifying Gambit’s alleged
infringement of the ’561 and’695 patents as well as Simon’s “non-exclusive license terms for
Mr. Nieves responded that, apart from the claim chart for the ’456 design patent attached
to the October 20 letter, no other claim charts would be provided. Regarding the license terms, Mr.
Nieves stated that a license to each of the Simon Patents would be “non-exclusive,” and “seven to
eight years” of Gambit’s financial information was needed to calculate past royalties even though
5
Simon’s Information Disclosure Statements are attached hereto as Exhibit 3.
12
Case 3:20-cv-03748-L Document 1 Filed 12/30/20 Page 13 of 16 PageID 13
the patents issued on May 2, 2017 (’561 patent), October 31, 2017 (’456 design patent), and
September 18, 2018 (’695 patent). Along the way, Mr. Nieves proclaimed that Gambit could
21. During the December 7 teleconference, Mr. Joyner asked Simon’s counsel if he
would like to see pictures and videos of early versions of the SuperDeker® that antedated the filing
of the application that became the ’456 design patent by several years. Mr. Nieves declined
Gambit’s offer.
22. In sum, Simon’s conduct has caused Gambit to reasonably and legitimately
apprehend that Simon will sue Gambit for infringement of the Simon Patents on account of its
COUNT I
paragraphs 1-22 of this Complaint for Declaratory Judgment of Non-infringement as if set forth
herein.
24. The manufacture, use, sale, offer to sell, and/or importation of Gambit’s pay-at-the-
table tablet does not infringe and has not infringed any of the claims of the ’456 design patent. In
addition, the manufacture, use, sale, offer to sell, and/or importation of Gambit’s pay-at-the-table
tablet does not contribute to or induce the infringement of any of the claims of the ’456 design
patent.
25. Gambit has not infringed and does not infringe, directly or indirectly, any of the
claims of the ’456 design patent, either literally or under the doctrine of equivalents.
13
Case 3:20-cv-03748-L Document 1 Filed 12/30/20 Page 14 of 16 PageID 14
26. There is an actual and justiciable controversy between Gambit and Simon over
27. As a result of the facts described in the foregoing paragraphs, there exists a
substantial controversy of sufficient immediacy and reality to warrant the issuance of a declaratory
judgment.
Gambit may ascertain its rights regarding the ’456 design patent.
COUNT II
paragraphs 1-22 of this Complaint for Declaratory Judgment of Non-infringement as if set forth
herein.
30. The manufacture, use, sale, offer to sell, and/or importation of Gambit’s pay-at-the-
table tablet does not infringe and has not infringed any of the claims of the ’561 patent. In addition,
the manufacture, use, sale, offer to sell, and/or importation of Gambit’s pay-at-the-table tablet does
not contribute to or induce the infringement of any of the claims of the ’561 patent.
31. Gambit has not infringed and does not infringe, directly or indirectly, any of the
claims of the ’561 patent, either literally or under the doctrine of equivalents.
32. There is an actual and justiciable controversy between Gambit and Simon over
33. As a result of the facts described in the foregoing paragraphs, there exists a
substantial controversy of sufficient immediacy and reality to warrant the issuance of a declaratory
judgment.
14
Case 3:20-cv-03748-L Document 1 Filed 12/30/20 Page 15 of 16 PageID 15
COUNT III
paragraphs 1-22 of this Complaint for Declaratory Judgment of Non-infringement as if set forth
herein.
36. The manufacture, use, sale, offer to sell, and/or importation of Gambit’s hockey
training device does not infringe and has not infringed any of the claims of the ’695 patent. In
addition, the manufacture, use, sale, offer to sell, and/or importation of Gambit’s hockey training
device does not contribute to or induce the infringement of any of the claims of the ’695 patent.
37. Gambit has not infringed and does not infringe, directly or indirectly, any of the
claims of the ’695 patent, either literally or under the doctrine of equivalents.
38. There is an actual and justiciable controversy between Gambit and Simon over
39. As a result of the facts described in the foregoing paragraphs, there exists a
substantial controversy of sufficient immediacy and reality to warrant the issuance of a declaratory
judgment.
WHEREFORE, Tabletop respectfully asks this Court to enter judgment in Tabletop’s favor
15
Case 3:20-cv-03748-L Document 1 Filed 12/30/20 Page 16 of 16 PageID 16
A. A declaration that Tabletop’s pay-at-the-table tablet does not infringe and has not
B. A declaration that Tabletop’s pay-at-the-table tablet does not infringe and has not
C. A declaration that Tabletop’s pay-at-the-table tablet does not infringe and has not
D. An order declaring that this is an exceptional case and awarding Gambit its costs,
expenses, disbursements, and reasonable attorneys’ fees under 35 U.S.C. § 285 and all other
E. Any such other and further relief that this Court deems just and proper.
JURY DEMAND
Pursuant to Federal Rule of Civil Procedure 38, Gambit respectfully demands a jury trial
16
Case 3:20-cv-03748-L Document 1-1 Filed 12/30/20 Page 1 of 2 PageID 17
Exhibit 1
Filed
Date Filed : 06/17/2019 10:55:00 AM
Case 3:20-cv-03748-L Document 1-1 Filed 12/30/20 Page 2 of 2 PageID 18: 09/01/2019 12:00:00 AM
Effective Date
Filing # : 4528985 Pages : 1
Business ID : 216150
William M. Gardner
Secretary of State
State of New Hampshire
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 1 of 41 PageID 19
Exhibit 2
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 2 of 41 PageID 20
SHEEHAN PHINNEY
Manchester, NH I Concord, NH I Hanover, NH I Boston, MA
October 20,2020
Dear Sirs:
This law firm represents Mr. Thomas Chapman Simon (Mr. Simon), the President and
Founder of Plastix Graphixs and Shooting Star Hockey Training Aids. This law firm also
represents Plastix Graphixs and Shooting Start Hockey Training Aids. Plastix Graphixs is the
provider of multiple hockey training aids including, for instance, hockey shooting pad boards.
Mr. Simon is the owner of United States Patent Numbers D801,456 (Hockey Training Device),
Board), hereafter, "the Patents", copies of which are enclosed. Mr. Simon has spent significant
time and resources in obtaining the Patents and expects others to respect his government granted
parts, and accessories. SuperDeker sells SuperDeker Advanced Hockey Training System
Training Device").
800.625.SP8[ ii.'-) 1)
| wr,vw.sheehan.cont
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 3 of 41 PageID 21
SuperDeker i Gambit Training LLC
October 20,2020
-2-
A legal analysis has been perfurmed [o uurnparu the Patcttts tu the SuperDeker Training
SuperDeker Training Device and design patent D801,456. It may be that SuperDeker was not
aware of the Patents and associated legal rights. In assessing options, Mr. Simon has decided to
offer SuperDeker a non-exclusive license to each of the Patents. In the alternative, Mr. Simon
would entertain an offer to purchase all right, title, and interest to each of the Patents. Of course,
purchasing the Patents will be more costly than SuperDeker obtaining a non-exclusive license to
the Patents, although a non-exclusive license will not allow SuperDeker to stop others from
making, using, selling, offering for sale, or importing, the technology and design of the Patents,
thereby allowing for competitors. It is Mr. Simon's intent to offer non-exclusive licenses to
other parties as well, unless SuperDeker purchases the Patents from Mr. Simon.
Mr. Simon would like a written response to this letter from SuperDeker within ten (10)
business days from receipt of the current communication. Should a response not be received
within the allotted 10 days, Mr. Simon has instructed us to follow-up on this matter with
SuperDeker until such matter is resolved. Should SuperDeker express interest in the non-
exclusive license option, Mr. Simon will forward SuperDeker the non-exclusive license terms for
consideration and SuperDeker will be required to provide certain information for consideration
The information in this letter is accurate to the best of our knowledge and belief. Nothing
in this letter shall be deemed to waive any right, remedy or defense of Mr. Simon, Plastix
Graphixs, or Shooting Star Hockey Training Aids, all of which are expressly reserved. This
letter does not purport to be a complete statement of the law or facts, and is sent without
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 4 of 41 PageID 22
SuperDeker / Gambit Training LLC
October 20,2020
-3-
prejudice to Mr. Simonns, Plastix Graplfxs', and Sluroting Star Hockey Training Aids' legal and
equitable rights, claims and remedies, all of which are expressly reserved
Best regards,
BASS & GREEN PA
Nleves
Enclosures
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 5 of 41 PageID 23
ATTACHMENT A
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 6 of 41 PageID 24
lnfringement
Analysis for U.S.
Design Patent No,
DB01 ,456
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 7 of 41 PageID 25
Fig.7
Figu re 1,
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 8 of 41 PageID 26
Fig.2
Figure 2
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 9 of 41 PageID 27
Fig. 3
Figure 3
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 10 of 41 PageID 28
a
t
I
I
I
Eig,4
Figure 4
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 11 of 41 PageID 29
Fig. 5
Fig. 6
Figures 5 and 6
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 12 of 41 PageID 30
Fig. 7
Fig.8
Figures 7 and B
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 13 of 41 PageID 31
I lllll ill]il til ilil1 ilil till tilr llll lllll llll lill lllll ll lllil llll
us00D801456S
us D801,456 S
Page 2
Fig, 1
Fig.2
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 16 of 41 PageID 34
Fig.3
Fig.4
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 17 of 41 PageID 35
$t
'tr.t.
Fig,5
Fig.6
Fig,7
Fig. I
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 18 of 41 PageID 36
I l|]t tililll lil ilil ililt llilt ]il illl lil] ]ilt ]lll illll ill llll llll
us009636s61B2
42 34
42
20 34
42 L
18 34
28
t2 44
10
6--"
16
I
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 19 of 41 PageID 37
42 34
42
20 34
42
18 34
28
L2 44
10
16 6
FIG.1
46
44
18
46
28
10
20
t2
FIG.2
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 20 of 41 PageID 38
r-_j
.-42 0
30
too r42 Fg
D]
28 J 34 E Fl.
fuoo (D
I
.4 2 )Ft
I
E6
34 I
34 r42
20 hoo 7
F-
p
18 -p
o
b'J
{
26
L2
u)
10
tD
(!
bJ
o
Ut
44
46
32
co
\o
o\
(,
32 o\
rrt
FIG.3 o\
\/
b.)
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 21 of 41 PageID 39
42 42
40
B
20
1B
FIG.4 1B
28
16
10 24
42
48 t4 3B 22
50 50 38 rg J
40 28
FIG.6
1B
26
18
28
46 44
FIG.5
10
FIG.7
10
32
32 FIG. B
18
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 22 of 41 PageID 40
42 34
42
34
54 42
34
52
44
FIG.9
42 34
42
34
42
58 34
44
56
FIG. 1O
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 23 of 41 PageID 41
42
60 34
42
62
66
42
40 ,{
34 34 r42
66
60
f-oo
FIG. 1 1 42
62
40 t34
68 6B
68
66
68
66
FIG.12
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 24 of 41 PageID 42
us 9,636,561B2
1 2
HOCKEY PUCK REBOUNDING DEVICE FIG. 11 is a perspective view of an embodiment of the
present invention; and
CROSS-REFERENCE TO RELATED FIG. 12 is a perspective view of an embodiment of the
APPLICATION present invention.
5
This application claims the benefit of priority of U.S. DETAILED DESCRIPTION OF THE
provisional application No. 6 I I 980,463, fi led Apr. 1 6, 2O1 4, II.IVENTION
the contents of which are herein incorporated by reference.
The following detailed description is ofthe best currently
BACKGROLIND OF THE INVENTION 10
contenplated modes of carrying out exemplary embodi-
ments of the invention. The description is not to be taken in
The present invention relates to ice hockey and more a linriting sense, but is made merely for the purpose of
particularly, to an ice hockey trainer. illustrating the general principles of the invention, since the
Ice hockey is a contact team sport played on ice, usually scope of the invention is best defined by the appended
in a rink, in which two teams of skaters use their sticks to 15
claims.
shoot a puck into their opponent's net to score goals. Hockey The present invention includes an ice hockey training aid
training typically occurs in an ice rilk. Ice time is expensive used to promote and develop essential hockey puck skills
and is not always accessible. Stick handling, shooting and
such as shooting, passing, and stick handling. The present
passing the puck are essential skills to improve performance
20 invention eliminates the need for costly ice time to practice
while playing ice hockey.
individual puck skills. The present invention can be used all
As can be seen, there is a need for an of the ice training
year round inside or outside increasing the player's practice
device to improve puck handling skills ofa hockey player.
time to develop essential skills.
SIJMMARY OF THE INVENTION The present invention includes a uniquely designed sys-
25 tem integrated with three angled rebounding bands that
In one aspect of the present invention, a hockey training enhances real hockey situations. Engineered utilizing
device comprises: a first flat sheet comprising a smooth advanced fabricated plastic polymers improves smooth puck
upper surface; and a plurality ofelastic bands suspended to sliding performance with a secure and tight mechanism
the upper surface and each comprising a front surface increasing rebounding perfornance.
substantially perpendicular to the flat sheet, wherein the 30 Referring to FIGS. 1 through 12, the present invention
firrnt surface of each of the plwality of elastic bands is includes a hockey training device. The training device
facing towards a center portion of the flat sheet. includes a substantially flat fint sheet 18 with a smooth
ln another aspect of the present invention, a hockey upper surface 24. The present invention includes at least one
training device comprises: a first flat sheet and a second flat elastic band 34 suspended to the upper surface. A first
sheet each comprising a smooth upper surface, wherein the 35 vertical post 40 and a second vertical post 40 may be
first flat sheet and the second flat sheet are connected attached to the first flat sheet 18 so that the elastic band 34
together by a hinge; and at least one elastic band suspended is secwed about the first and second vertical posts 40. The
to the upper surface of the first flat sheet and comprising a elastic band 34 includes a front surface facing towards a
front surface substantially perpendicular to the first flat center portion ofthe first flat sheet 18. Therefore, a puck may
sheet, wherein the front surface of the at least one elastic 4Q be passed towards the elastic band 34 and the elastic band 34
band is facing towards a center portion of the hockey rebounds the puck towards the user.
training device. In certain embodiments, the present invention may
These and other features, aspects and advantages of the include a plurality ofbands 34 oriented at diferent angles in
present invention will become better understood with refer- order to rebound the puck back to the center portion of the
ence to the following drawings, description and claims. 45 first flat sheet 18. For example, the present invention may
include a first elastic band 34 suspended in between a second
BzuEF DESCRIPTION OF THE DRAWINGS elastic band 34 and a third elastic band 34. A front surface
of the second elastic band 34 and the third elastic band 34
FIG. L is a top perspective view of an embodiment of the are suspended at an angle relative to the front surface of the
present invention; 50 first elastic band 34 so that the front surfaces ofeach ofthe
FIG. 2 is a bottom perspective view of an embodiment of elastic bands 34 are facing towards the center portion ofthe
the present invention; flat sheet 18. Therefore, the user may shoot to the middle, to
FIG. 3 is an exploded view of an embodiment of the the left or to the right, and the puck may rebound to the same
present invention; center portion ofthe flat sheet 18.
FIG. 4 is a perspective view of an embodiment of the 55 The vertical posts 40 of the present invention may be
present invention in a folded state; mounted to the flat sheet 18 via apertures 26, 46 and
FIG. 5 is a section detail view of the present invention fasteners 48. In certain embodiments, the present invention
along line 5-5 in FIG. 1; may include a backer plare 44 including a plurality of
FIG. 6 is a section detail view of the present invention apertures 46. The flat sheet 18 includes apertures 26 that
along line 6-6 in FIG. 1.; 60 align with the apertures 46 of the backer plate 44. The
FIG. 7 is a section detail view of the present invention fasteners 48 may run through the aligned apernxes 26, 46
demonstrating a live hinge in operation; and inlo the vertical posts 40, thereby connecling the backer
FIG. 8 is a section detail view along line 8-8 in FIG. 4; plate 44 to a lower surface ofthe first flat sheet 18 and the
FIG. 9 is a perspective view of an embodiment of the vertical posts 40 to the upper surface ofthe first flat sheet 18.
present invention; 65 In certain embodiments, the vertical posts 40 may include
FIG. 10 is a perspective view of an ernbodiment of the post flanges 42 extending radially from the post 40 to
present invention; prevent the bands 34 from slipping otrthe posts 40.
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 25 of 41 PageID 43
us 9,636,561B2
3 4
In certain embodiments, the present invention may As stated above, Ice Hockey players have little individual
include a second flat sheet 10 with a smooth upper surface time to develop essential hockey puck skills such as stick
16 substantially the same as the first flat sheet 18. The handling, passing, and shooting. Regular practices focus on
second flat sheet 10 may be connected to the first flat sheet team play rather than individual skil1 enhancement. The
18 by a hinge 28, and may thereby fold relative to one 5 present invention claimed here solves this problem.
another into a folded position. In certain embodiments, the This training aid eliminates the need for costly ice time to
first flat sheet 18 and the second flat sheet 10 nay each practice individual puck skills. This aid can be used year
include cutout portions along an edge, fonning handles 12 round inside or outside increasing the player's practice time
and 20. A
connector may releasably connect the first flat to develop essential skills.
sheet 18 and the second flat sheet 10 in a folded position. 10 The claimed invention difers from what curently exists.
The connector may include a hook and loop fastener 32 Prior to this device, there are no other ice hockey plastic
aftached to the lower surfaces ofthe first flat sheet 18 and the puck skills training aid that fold conveniently in half. This
second flat sheet 10. Therefore, the first flat sheet 18 and the feature makes portability easy, saves on storage space, and
second flat sheet 10 may be folded about the hinge 28 and reduces shipping costs.
the lower surfaces may be attached to one another. The 15 This aid comes fully assembled and ready to use. Other
handles 12 and20 may align, and a user may easily transport devices require various assembly optious and sourcing of
the folded hockey training device. required parts causing inconsistencies and poor perfor-
The hinge 28 of the present invention may colmect mance. Needed adjustments are required to maintain per-
adjacent edges ofthe first flat sheet 1.8 and the second flat formance.
sheet 10. The hinge 28 may be a polymer hinge 28. In certain 20 Uniquely designed system, integrated with three separate
embodiments, the hinge 28 may include a first thick panel angled rebounding bands incorporated in the (Puck Sliding
attached to the first flat sheet 18, a second thick panel Surface) enhances real hockey situations. Advanced plastic
attached to the second flat sheet 10, and a thin portion polymers improve smooth puck sliding perfonnance with
connecting the first thick panel and the second thick panel. secure tight mechanism increasing rebounding power.
The first flat sheet 18 may include apertures 22 that align 25 The Version ofthe Invention Discussed Here Includes:
with apertures 30 on the first thick panel, and the second 1. Puck Sliding Surface A-Natural High Density Poly-
sheet 10 may include apertures 14 that align with apertures ethylene Plastic sheet 7re" thickx40ux40". 6 Drilled
30 on the second thick panel. Brass threaded inserts 38 may holes 3/re" in diameter in a particular pattern to match
be within apertures 14 and22. Fasteners 50 may run through up with the same pattern as a Backer Plate for attaching
the aligning apertures 30 and inserts 38, thereby connecting 30 rebounding system. 6 drilled holes 0.261 "diameter
the hinge 28 to the first flat sheet 18 and the second flat sheet used to attach poly hinge. Router hole for handle
10. The hinge 28 may fold about the thin portion, thereby l"v{t7rrt matches up exactly to routed hole on Puck
folding the fust flat sheet L8 and the second flat sheet 10 Sliding Surface B when board is folded rnaking a
together. handle.
In certain embodiments, the first flat sheet 18 and the 35 2. Puck Sliding Surface B-Natural High Density Poly-
second flat sheet 10 ofthe present invention may be made of ethylene plastic sheet 716" thickx40"x40"x%0" thick. 6
natural white high density polyethelene plastic sheeting. The drilled holes diameter 0.0261.". Drilled holes are for
plastic sheeting provides a smooth upper surface so that the attaching poly hinge.
puck may easily glide similar to gliding on ice. The dimen- 3. Backer Plate-Lexan polycarbonate plastic 7+" thickx
sions of the plastic sheeting may also vary. For example, the 40 43/q"x40" .6 drilled and counter sunk holes for attaching
plastic sheeting may be, but is not limited to, about 40"x60", rebounder system. Al1 4 corners 1" radius. 4.
40"x80" or other suitable dimensions. The thicknesses rnay 4. Post-6 Natural acetyl plastic comrnonly called Delrin.
include, but are not limited to, 0 .787" ,0.725" or the like. The l"x1.t/t" length. Drilled aud tapped on bottorn side
elastic bands 34 may be rubber bands, such as ethylene 10132" thread.
propylene diene monomer (EPDM) that may be about 1.125 45 5. Band-EPDM Ethylene Propylene Diene Monomer, 8"
includes wide, about 0.063 inches thick, and having about an flat lenglhxl.lnt' widex0.063" wall.
eight inch flat front surface. The elastic bands 34 may be UV 6. Insert-Brass Press-Fit lnsert. 10-32 inch intemal
t7ru".
resistant. The vertical posts may be made of acetyl plastic. Tbread,
As illuslrated in the Figures, the present invention may 7. Backer Screw-Machine Flat Head Screw 10-32"
come in multiple shapes and sizes. As illustrated in FIG. 9, 50 tfueadxl" length.
the flat sheet 52 may include a shorter lengtlr, and may not 8. Poly Hinge-Black Polypropylene IJV resistant 1%"
be hingedly connected to another sheet. The flat sheet 52 widex4O" longx%o" thick.
may include a cutout portion 54 for the handle. FIG. 10 may 9. Fasteners Strips-Velcro strips 7e"x3".
include a flat sheet 56 with a longer length, which is also not 10. Hinge Screw-Machine Flat Head 70/32" lhreadxLAtl
hingedly connected to another sheet. The flat sheet 56 may 55 length.
include a cutout portion 58 for the handle. The seamless flat Relationship Between the Components:
sheets 52, 56 may include, but are not limited to, the The puck sliding surface A and B connect together to
Ibllowing dimensions, about 40"x60" and about 40"x80". make up the total surface ofthe Puck Sliding Surface which
As illustrated in FIGS. 11 and 12, the present invention may folds and unfolds. They are connected on the back side
include a band 34 suspended on opposing sides ofthe sheet 60 utilizing the Insert, and the hirge screw, and the Poly Hinge.
60. Each side may include a backer plate 66 that has The Backer Plate attaches to back side of puck sliding
apertures 68 that align with apertures 64 formed through the surface A using backer screws and posts. The band stretches
sheet 60. Thereby, the backers 66 may be suspended to the arourd 2 posts in 3 separate locations creating 3 separate
sheet 60 through the aligning apertures 64, 68 via fasteners. angled rebounding bands. The Fastener Strips place in same
In certain embodiments, the sheet 60 may include, but is not 65 mirror image on back of puck sliding surface A and B
limited to, the following dimensions, 30"x60" single band meeting together holding the board folded in place until
and 30"x60" double band rebounder. ready for use.
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 26 of 41 PageID 44
us 9,636,561B.2
5 6
LIow the lnvention Works: What is claimed is:
With the use of a High Density Polyethylene Plastic sheel 1. A hockey training device comprising:
which has a low coefrcient of friction and an EPDM elastic a first flat sheet comprising a smooth upper surface;
band. The puck is passed into the rebounding bands which a pluraliy ofrubber bands each suspended at a different
makes the puck slide freely back to the player. This action 5 portion of the upper surface and each comprising a
simulates real hockey situations without using real ice. The front surface substantially perpendicular to the flat
Puck Sliding Surface prctects expensive hockey stick frorn sheet;
rough surfaces such as a driveway. wherein the front surface of each of the plurality of rubber
How to Make the Invention: bands is disposed at an angle relative to one another and
1. Using 7ro" thick Natural HDPE (High Density Poly- 10 is facing towards a center portion of the flat sheet;
ethylene) each Plastic sheet puck sliding surface A and wherein the plurality of rubber bands comprises a first
B is cut to size 40"x40". rubber band suspended in between a second rubber
2. 6 drilled thru holes with diameter of 0.261" in each band and a third rubber band, the first rubber band
puck sliding surface A and B. The pattem and position positioned adjacent to a lengthwise edge of the flat
ofthe holes are in the same place on both parts. Brass l5 sheet approximately parallel to the lengthwise edge, the
Inserts are press fitted in the 12 lroles 6 on each side. second rubber band positioned to one side ofthe first
3. Poly Hinge is cut to length 40". 12 drilled countered mbber band and angled toward the center portion, the
sunk holes 6 on each side of hinge. Using tlre Hinge third rubber band positioned to a second side of the fint
Screw to connect Poly Hinge to back side of puck rubber band and angled toward the center portion; and
sliding surface A and B connecting both parts together. 20 wherein the plurality of rubber bands are configured and
4. Puck sliding surface A Has additional 6 drilled thru aranged such that an incoming hockey puck traveling
holes diameter 0.261 " used to attached the Backer Plate on the upper surface, and upon impact ofthe incoming
which has the same hole pattern. hockey puck, the plurality rubber bands causes the
5. The Backer Plate, l,exan (Polycarbonate) Plastic sheet hockey puck to rebound towards the center portion;
Vc" thlck cut to size 4O"x4.75".6 counter sunk drilled 25 further comprising a plurality of pairs of vertical posts,
thru holes 0.196" diameter. Hole pattem the same as wherein each ofthe plurality ofrubber bands is secwed
puck sliding surface A. A11 4 corners have 1" radius. to one pair of vertical posts, each of the plurality of
6. Acetal Plastic natural 1" diameter rod. (Commonly rubber bands wrapped around two of the plurality of
called Delrin) is CNC machined into post drilled and posts such that two layers of the band material are
tapped with 10/32" screw thread. 30 parallel.
7. Using the Screws that are used to assemble the backer 2. The hockey training device ofclaim 1, wherein a front
plate to puck sliding surface A and the Post in a secure surface of the second rubber band and the third rubber band
tight fashion. are suspended at an angle relative to the front surface ofthe
8. Velcro@ Strips are applied, pressure sensitive in the fust rubber band so that the fiont surfaces are facing towards
same position on both puck sliding surface A and B 35 the center portion of the flat sheet.
below the handle ho1e. 3. The hockey training device of claim 1, further com-
The HDPE natural 7re" Plastic sheet, Elastic EPDM band prising a second flat sheet connected to the fint flat sheet by
and poly hinge are included in the present invention. The a hinge.
routed hole for carrying handle is optional. By adding elasric 4. The hockey training device of claim 3, wherein the
EPDM bands to both ends of the Training Aid the player 40 hinge is an integral polymer hinge and comprises a first thick
could pass in both direclions using forehand and back panel attached to the first flat sheet, a second thick panel
handed stick handling motious. Not able to interchange or attached to the second flat sheet, and a thin portion connect-
reconfigure to achieve same results. ing the first thick panel and the second thick panel, wherein
How to Use the Invention: the hinge folds about the thin portion.
A hockey player unfolds the training aid and stands next 45 5. The hockey training device of claim 3, further com-
to the device with a hockey stick and puck, The player prising a connector releasably connecting the first flat sheet
passes the puck into one ofthree angled rebounding bands and the second flat sheet in a folded position.
which rebounds the puck freely back to the player keeping 6. The hockey training device of claim 5, wherein the
the puck in motion, like a puck on ice. 'Ihe player then second flat sheet comprises a cutout portion aligning with
practices stick handling moves like a "Toe Drag" and then 50 the cutout portion ofthe first flat sheet in the folded position.
shoots the puck into a strect hockey goal net using diferent 7. The hockey training device of claim 1, wherein an end
types of shots, such as a slap shot, snap shot, or wrist shot. of the front surface of each of the second band and the third
The present invention includes an ice hockey training aid band are disposed behind the first band.
used to develop hockey puck skills, such as shooting, 8. The hockey training device ofclaim I wherein each of
passing and stick handling is disclosed, The present inven- 55 the plurality ofrubber bands are configured to rebound the
tion is uniquely designed device that folds in half. A hockey puck without the hockey puck hitting another ofthe
rebounding system is integrated into the puck sliding surface plurality of rubber bands.
with three separate angled rebounding bands, which 9. The hockey training device of claim 1 wherein the
enhances real hockey situations. The present invention is pluralify of elastic bands are selected to be capable of
engineered utilizing advanced plastic polymer parts, which 60 repeated impact and rebounding of a hockey puck.
improves smooth puck sliding perfonnance with a secure 1.0. The hockey training device ofclaim 1 wherein each of
and tight mechanism increasing rebounding power. the plurality of elastic bands is secured to only trvo of the
It should be understood, of course, that the foregoing plurality of posts.
relates to exemplary embodiments of the invention and that 11. The hockcy training device of claim 10 wherein two
modifications may be made without departing from tle spirit 65 of the plurality of posts are adjacent to each other with one
and scope of the invention as set forth in the following directly behind the other, and wherein the first elastic band
claims. is attached to a first of the two of the plurality of posts, and
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 27 of 41 PageID 45
us 9,636,561B2
7
wherein the second elastic band is attached to a second ofthe further comprising a plurality of pairs of vertical posts,
t'wo of the plurality of posts, thereby causing the first and wherein each ofthe pluraliy ofrubber bands is secured
second elastic bands to overlap slightly, the second and third to one pair of vertical posts, each of the plurality of
rubber band having a portion that is behind the first rubber rubber bands wrapped around two of the plurality of
band. 5 posts such that two layers of the band material are
12. Ahockey training device comprising: parallel.
a first flat sheet and a second flat sheet each comprising a 13. The hockey training device ofclaim 12, wherein the
smooth upper surface; at least one band comprises a first elastic band suspended in
aplurality ofelastic bands suspended to the upper surface between a second elastic band and a third elastic band.
ofthe first flat sheet and each of the plurality of elastic 10
1.4. The hockey training device of claim 13, wherein a
bands comprising a front surface substantially perpen-
front surface of the second elastic band and the third elastic
dicular to the first flat sheet;
band are suspended at an angle relative to the front surface
a polyrner hinge connecting the first flat sheet and the
ofthe first elastic band so that the front surfaces are facing
second flat sheet together, wherein the polymer hinge
towards the center portion of the first flat sheet.
comprises a first thick panel attached to the first flat 15
242
f.oo
60
42
62
S-
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 29 of 41 PageID 47
us 10,076,695 B1
Page 2
42 34
42
2A 34
42
1B 34
2B
L2 44
1 6\/
10
L6
FIG. 1
4
44
1B
2B
10
20
L2
FIG.2
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 31 of 41 PageID 49
\o tr'!
N(} c!
$S (9
r{
V-
if, \o tL
$
(Yl I v
$
\.
{E--*
rf
+9 (f)
v--@-
$
SF {Y)
V- r{
rv)
()
(f)
o
t\
00 @
c{ rl
r\.1
ff)
c.{
F{
O
Fl
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 32 of 41 PageID 50
42 42
40
B
20
l"B
FIG.4 IB
28
16
10 74
48 14 38 22
42
50 50 38 rg J
40 28
FIG.6
18
26
18
2B
46 44
FIG.5
10
FIG,7
10
32
3? FIG. g
18
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 33 of 41 PageID 51
42 34
42
34
54 42
34
52
44
FIG.9
42
34
47
34
42
5B 34
44
56
FIG. 1O
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 34 of 41 PageID 52
42
60 34
4Z
62
66
34
56
40 I 42
34 r42
f-oo
60
FIG.11 42
62
4A ) t34
6B 6B
68
66
68
66
FIG. 12
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 35 of 41 PageID 53
13? 1 30
130
131
132 131
42
131
130 i33
42
40
42
40
40 Fig 13
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 36 of 41 PageID 54
132
r30
131
130
131
13i
132
130
Fig 14
33
13i
131
130 131
133
33
32
Fig 15 Fig 16
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 37 of 41 PageID 55
us 10,076,695 B1
1 2
IIOCKI,Y REBOUNDER, SLIDE BOARD FIG. L3 is a perspective view of another embodiment of
the present convertible between a rebounding device and a
BACKGROLIND OF THE INVENTION slide board;
FIG, 14 is a perspective view of yet another embodiment
The present invention relales to ice hockey and, more 5 ofthe present convertible between a rebounding device and
particularly, to an ice hockey trainer. a slide board;
Ice hockey is a contact team sport played on ice, usually FIG. 15 is an elevation view of an embodiment of a block
in a rink, in which two teams of skaters use their sticks to of the present invention;
shoot a puck into their opponent's net to score goals. Hockey
FIG. 16 is an elevation view of another embodiment of a
10 block ofthe present invention.
training typically occurs in an ice rink. Ice time is expensive
and is not always accessible. Stick handling, shooting, DETAILED DESCRIPTION OF THE
passing the puck, and skating are essential skills to improve INVF,NTION
performance while playing ice hockey.
As can be seen, there is a need for an of the ice training 15 The following detailed description is ofthe best currently
device to improve puck handling skills and skating skills of contemplated rnodes of carrying out exemplary ernbodi-
a hockey player. ments of the invention. The description is not to be taken in
a limiting sense, but is made merely for the purpose of
SUMMARY OF THE INVENTION illustrating the general principles of the invention, since the
20 scope of the invention is best defined by the appended
ln one aspect of the present invention, a hockey training claims.
device comprises: a first flat sheet comprising a smooth The present invention includes an ice hockey training aid
upper surface; and a plurality ofelastic bands suspended to used to promote and develop essential hockey puck skills
the upper surface and each comprising a front surface such as shooting, passing, and stick handling, as well as
substantially perpendicular to the flat slreet, wherein the 25 training skating methods. The present invention eliminates
front surface of each of the plurality of elastic bands is the need for costly ice time to practice individual puck skills.
facirg towards a center portion ofthe flat sheet. The present invention can be used all year round inside or
In another aspect of the present invention, a hockey outside increasing the player's practice time to develop
training device comprises: a first ffat sheet and a second flat essential skills.
30 The present invention includes a uniquely desigred sys-
sheet each comprising a smooth upper surface, wherein the
tem integrated with three angled rebounding bands that
first flat sheet and the second flat sheet are connected
enhances real hockey situations. Engineered utilizing
together by a hinge; and at least one elastic band suspended
advanced fabricated plastic polymers improves smooth puck
to the upper surface ofthe first flat sheet and comprising a
sliding performance with a secure and tight mechanism
front surface substantially perpendicular to the first flat 35 increasing rebounding performance.
sheet, wherein the front surface of the at least one elastic Referring to FIGS. 1 through 12, the present invention
band is facing towards a center portion of the hockey includes a hockey training device. The training device
training device. includes a substantially flat first sheet 18 with a smooth
These and other features, aspects and advantages of the upper surface 24. The present invention includes at least one
present invention will become better understood with refer- 40 elastic band 34 suspended to the upper surface. A first
ence to the following drawings, description and claims. vertical post 40 and a second vertical post 40 may be
attached to the first flat sheet 18 so that the elastic band 34
BRIEF DESCRIPTION OF THE DRAWINGS is secured about the first and second vertical posts 40. The
elastic band 34 includes a front surface facing towards a
FIG. L is a top perspective view of an embodiment of the 45 center portion ofthe first flat sheet 18. Therefore, a puck may
present invention; be passed towards the elastic band 34 and the elastic band 34
FIG. 2 is a bottom perspective view of an embodiment of rebounds the puck towards the user.
the present invention; In certain embodiments, the present invention may
FIG. 3 is an exploded view of an embodiment of the include a plurality ofbands 34 oriented at diferenl angles in
present invention; 50 order to rebound the puck back to the center portion of the
FIG. 4 is a perspective view of an embodiment of the first flat sheet 1.8. For example, the present invention may
present invention in a folded state; include a first elastic band 34 suspended in between a second
FIG. 5 is a section detail view of the present invention elastic band 34 and a third elastic band 34. A front surface
along line 5-5 in FIG. 1; ofthe second elastic band 34 and the third elastic band 34
FIG. 6 is a section detail view of the present invention 55 are suspended at an angle relative to the front surface ofthe
along line 6-6 in FIG. 1; first elastic band 34 so that the front surfaces ofeach ofthe
FIG. 7 is a section detail view of the present invention elastic bands 34 are facing towards the center portion ofthe
demonstrating a live hinge in operation; flat sheet 18. Therefore, the user may shoot to the middle, to
FIG. 8 is a section detail view along line 8-8 in FIG. 4; the left or to the right, and the puck may rebound to the same
FIG. 9 is a perspective view of au embodiment of the 60 center portion of the flat sheet L8.
present invention; The vertical posts 40 of the present invention may be
FIG. 10 is a perspective view of an embodiment of the mounted to the flat sheet 18 via apertures 26, 46 and
present invention; fasteners 48. In certain embodiments, the present invention
FIG. 11 is a perspective view of an embodiment of the may include a backer plate 44 including a plurality of
present invention; 65 apertures 46. T\e flat sheet 18 includes apertures 26 that
FIG. 12 is a perspective view of an embodiment of the align with the apertures 46 of the backer plate 44. The
present invention; fasteners 48 may run through the aligned apertures 26, 46
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 38 of 41 PageID 56
us 10,076,695 81
3 4
and into the venical posts 40, thereby cotnecting the backer following dimensions, about 40"x60" and about 40"x80",
plate 44 to a lower surface ofthe first flat sheet 18 and the about 30"x96", or other suitable dimensions. As illustrated
vertical posts 40 to the upper surface ofthe first flat sheet 18. in FIGS. 11 and 12, the present invention may include a band
In certain embodiments, the vertical posts 40 may include 34 suspended on opposing sides ofthe sheet 60. Each side
post flanges 42 extending radially from the post 40 to 5 may include a backer plate 66 that has apertures 68 that alip
prevent the bands 34 from slipping of the posts 40. with apertures 64 formed tfuough the sheet 60. Thereby, the
In certain embodiments, the present invention rnay backers 66 may be suspended to the sheet 60 tfuough the
include a second flat sheet L0 with a smooth upper surface aligning apertures 64, 68 via fasteners. In certain embodi-
16 substantially the same as the first flat sheet 18. The ments, the sheet 60 may include, but is not limited to, the
second flat sheet 10 may be connected to the first flat sheet 10 following dimensions, about 40"x60", 40"x80", 40"x96",
1.8 by a hinge 28, and may thereby fold relative to one about 30"x96", or other suitable dimensions. It should be
another into a folded position. In certain embodiments, the understood that the board may have bands at one or both
first flat sheet 18 and the second flat sheet 10 may each ends.
include cutout portions along an edge, forming handles 12 Tuming now to FIGS. 13 and 14, a view of another
and 20. A connector may releasably connect the first flat 15 embodiment of the present invention that is convertible
sheet 18 and the second flat sheet 10 in a folded position. between a hockey rebounding device to a hockey slide
The connector may include a hook and loop fastener 32 training device is shown. In this view, a sheet 60, similar to
attached to the lower surfaces ofthe first ffat sheet 18 and the sheets in other embodiments, has vertical posts 40 extending
second flat sheet 10. at each lengthwise end. Elastic bands 34 can be aftached to
Therefore, the first flat sheet 18 and the second flat sheet 20 these posts 40, and flange 42 limits their sliding ofl unin-
10 may be folded about the hinge 28 and the lower surfaces tentionally. The elastic bands 34 may be removed by stretch-
nray be attached to one another. The handles 12 and 20 may ing them away and over the posts 40. Once removed, slide
align, and a user may easily transport the folded hockey blocks 132 may be attached to the posts 40. Once attached,
training dwice. as seen in FIG. 14, the device may allow a user to practice
The hinge 28 of the present inventiou rnay connect 25 a sliding skating motion side to side, sliding one foot until
adjacent edges ofthe first flat sheet 18 and the second flat it contacts block L32, and then may push against this block
sheet 1.0. The hinge 28 may be a polymer hinge 28. In certain to slide across the board 60 to the other block 132, and
embodiments, the hinge 28 may include a first thick panel repeating until the training is completed. This sliding train-
attached to the first flat sheet 18, a second thick panel ing mimics the motion used by a skater when ice (or inline,
attached to the second flat sheet 10, and a thin portion 30 etc.) skating. As such, the device can be converted between
connecting the first thick panel and the second thick panel. a skating training device in the slide board mode (having the
The first flat sheet 18 may include apertures 22 that align slide blocks 132 attached, and a puck ski1l training device
with apertures 30 on the first thick panel, and the second (when the elastic bands are attached) when in the hockey
sheet 10 may include apertures 1.4 lhat align with apertures puck training rnode. In one embodiment, the sheet 60 may
30 on the second thick panel. Brass threaded inserts 38 may 35 be folded about a hinge. In another embodiments, the sheet
be within apertures 14 and22. Fasteners 50 may run through may be rollable. Arubber mat may be positioned on a bottom
the aligning apertures 30 and inserts 38, thereby connecting of the sheet 60 to limit sliding.
the hinge 28 to the fust flat sheet 18 and the second flat sheet Slide block 132 is attachable to the posts 40 by a key slot
10. The hinge 28 may fold about the thin portior4 thereby configuration having a wide circular region 130 which is
folding the fust flat sheet 18 and the second flat sheet 10 40 large enough for flanges 42 lo frl through. The key slot
together. further has a narrow region 131 which is wide enough to fit
In certain embodirnents, the first flat sheet 18 and the posts 40, but not wide enough for flanges 42 to pass tluough.
second flat sheet When connecting, a user passes the ffanges and posts
10 of the present invention may be made of natural white through wide circular region 130 and then slides the block
high density 45 towards a lengthwise end of the sheet 60 causing the posts
polyethelene plastic sheeting. The plastic sheeting provides 40 to be over the narrow region 131, which prevents upward
a smooth upper surface so that the puck may easily glide movement of the block 132 because the flanges 42 are
similar to gliding on ice. The dimensions of the plastic locked over the top surface ofthe block 132. In FIGS. 13 and
sheeting may also vary. For example, the plastic sheeting 14, the slots 130, 131 are shown aligned in a lengthwise
may be, but is not limited to, about 40"x60", 40"x80", 50 direction of the block 132. Other embodiments may include
40"x96", about 30"x96", or other suitable dimensions. those included in FIGS. 15 and 16. For example, FIG. 15, the
The thicknesses may include, but are not limited to, block 132 has key slots aligned in a lengthwise direction on
0.093u, 0.187", 0.125" or the like. The elastic bands 34 the block 132, and an angled face 133 such that the block has
may be rubber bands, such as ethylene propylene diene a more narrow width at a first end than a second end. This
monomer @PDM) that may be about 1.125 includes 55 width tapers outward to a wider width at a second end. As
wide, about 0.063 inches thick, and having about sixteen such, the block 132 provides an angled foot receiving area
inch flat front surface. The elastic bands 34 may be IJV so that a toe is pointed outwardly from the user's body.
resistant. The vertical posts may be made ofacetyl plastic. Similarly, in FIG. 16, the key slots 130, 131 are offset from
As illustrated in the Figures, the present invention may each other so tlat a first key slot is positioned closer to a
come in multiple shapes and sizes. As illustrated in FIG. 9, 60 right side edge of the block 132, while a second key slot is
the flat sheet 52 may include a shorter lengtl1 and may not positioned closer to a 1eft side edge of the block L32. When
be hingedly connected to another sheet. The flat sheet 52 attached to the posts 40, the bock will be angled on the sheet,
may include a cutout portion 54 for the handle. FIG. 10 may providing an angled foot receiving area so that a toe is
include a flat sheet 56 with a longer length, which is also not pointed outwardly from the user's body.
hingedly connected to another sheet. The flat sheet 56 may 65 In some embodiments, such as the embodiment shown in
include a cutout portion 58 for the handle. The seamless flat FIGS. 13 and 14, the slide block 132 may have an angled
sheets 52, 56 may include, but are not limited to, the portion 133, which slopes downward in a wedge shape. This
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 39 of 41 PageID 57
us 10,076,695 B1
5 6
may provide a better surface for the side ofthe user's foot. angled rebounding bands. The Fastener Strips place in same
In other embodiments, however, the sl'ide block 132 may mirror image on back of puck sliding surface A and B
have a flat leading edge. meeting together holding the board folded in place until
As stated above, Ice Hockey players have little individual ready for use.
time to develop essential hockey puck skills such as stick 5 How the Invention Works:
handling, passing, skating and shooting techniques. Regular With the use of a High Density Polyethylene Plastic sheet
practices focus on team play rather than individual skill which has a low coeffcient of friction and an EPDM elastic
enhancement. The present invention claimed here solves this band. The puck is passed into the rebounding bands which
problem. makes the puck slide freely back to the player. This action
This training aid eliminates the need for costly ice time to 10 simulates real hockey situations without using real ice. The
practice individual puck skills and train on skating methods. Puck Sliding surface protects expensive hockey stick from
This aid can be used year round inside or outside increasing rough surfaces such as a driveway. Further, when in a
the player's practice time to develop essential skills. skating motion training mode, a user may use the slide
The claimed invention difers from what currently exists. blocks to push off and slide across the sheet until the
Prior to this device, there are no other ice hockey plastic 15 opposite foot reaches the opposite slide block, and again
puck skills training aid that fold conveniently in half. This push off, repeating this motion during the training.
feature makes portability slsy, saves on storage space, and How to Make the Invention:
reduces shipping costs. 1. Using 7re" thick Natural HDPE (High Density Poly-
This aid comes fully assembled and ready to use. Other ethylene) each Plastic sheet puck sliding surface A and
devices require various assembly options and sourcing of 20 B is cut to size 40"x40".
required parts causing inconsistencies and poor perfor- 2. 6 drilled thru holes with diameter of 0.26i" in each
mance. Needed adjustments are required to maintain per- puck sliding surface A and
fonnance. B. The pattern and position of the holes are in the same
The uniquely designed system, integrated with tluee place on both parts. Brass Inserts are press fitted in
separate angled rebounding bands incorporated in the (Puck 25 the 12 holes 6 on each side.
Sliding Surface) enhances real hockey situations. Advanced 3. Poly Hinge is cut to length 40". 12 drilled countered
plastic polymers improve smooth puck sliding performance sunk holes 6 on each side of hinge. Using the Hinge
with sectre tight mechanism increasing rebounding power. Screw to connect Poly Hinge to back side of puck
The Version ofthe Invention Discussed Here Includes: sliding surface A and B connecting both parts together.
1. Puck Sliding Surface A-Natural High Density Poly- 30 4. Puck sliding surface A Has additional 6 drilled thnt
ethylene Plastic sheet 3/re" thickx40"x40". 6 Drilled holes diameter 0.261 " used to attached the Backer Plate
holes 7re" in diameter in a particular pattern to match which has the same hole pattern.
up with the same pattern as a Backer Plate for attaching 5. The Backer Plate, Lexan (Polycarbonate) Plastic sheet
rebounding system. 6 drilled holes 0.261" diarneter Vq" thick cut to size
used to attach poly hinge. Router hole for handle 35 40"x4.75".6 counter sunk drilled thru holes 0.196"
1"x4Vz" matches up exactly to routed hole on Puck diameter. Ilole pattem the same as puck sliding
Sliding Surface B when board is folded making a swface A. AI1 4 corners have 1" radius.
handle. 6. Acetal Plastic natural 1" diameter rod. (Commonly
2. Puck Sliding Surface B- Natural High Density Poly- called Delrin) isCNC machined into post drilled and
ethylene plastic sheet 7rc" thickx40"x40"x3Ae" thick.6 40 tapped with 10/32" screwthread.
drilled holes diameter 0.0261". Drillecl holes are for 7. Using the Screws ihat are used 1o assemble the backer
attaching poly hinge. plate to puck sliding surface A and the Post in a secure
3. Backer Plate-I-exan polycarbonate plastic 7a" thickx tight fashion.
43/q"x40".6 drilled and counter sunkholes for attaching 8. Velcro@ Strips are applied, pressure sensitive in the
rebounder system. All 4 corners 1" radius. 4. 45 same position on both puck sliding surface A and B
4. Post-6 Natural acetyl plastic commonly called Delrin. below the handle hole.
7"xlt/e" length. Drilled and tapped on bottom side The HDPE natural 7rs" Plastic sheet, Elastic EPDM band
l0l32" thread. and poly hinge are included in the present invention. The
5. Band-EPDM Ethylene Propylene Diene Monomer, 8" routed hole for carrying handle is optional. By adding elastic
flx lengthxl Va" widex0.063 " wall. 50 EPDM bands to both ends of the Training Aid the piayer
6. Insert-Brass Press-Fit Insert. 10-32 inch internal could pass in both directions using forehand and back
Tlnead, 3/t6tt. handed stick handling motions. Not able to interchange or
7. Backer Screw-Machine Flat Head Screw 10-32" reconfigure to achieve same results.
threadxl" length. How to Use the Invention:
8. Poly Hinge-Black Polypropylene UV resistant 1%" 55 A hockey player unfolds the training aid and stands next
widex4O" longx%0" thick. to the device with a hockey stick and puck. The player
9. Fasteners Strips-Velcro strips 7a"x3". passes the puck into one ofthree angled rebounding bands
10. Hinge Screw-Machine Flat Head 1U32" tbrcadxVc" which rebounds the puck freely back to the player keeping
length. the puck in motion, like a puck on ice. The player then
Relationship Between the Conponents: 60 practices stick handling moves like a "Toe Drag" and then
The puck sliding surface A and B connect together to shoots the puck into a street hockey goal net using diferent
make up the total surface ofthe Puck Sliding Surface which types of shots, such as a slap shot, snap shot, or wrist shot.
folds and unfolds. They are connected on the back side The present invention includes an ice hockey training aid
utilizing the Insert, and the hinge screw, and the Poly Hinge. used to develop hockey puck skills, such as shooting,
The backer Plate attaches to back side of puck sliding 65 passing and stick handling is disclosed. The present inven-
surface A using backer screws and posts. The band stretches tion is uniquely designed device that folds in half. A
around 2 posts in 3 separate locations creating 3 separate rebounding syslem is integrated into the puck sliding surface
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 40 of 41 PageID 58
us 10,076,695 B1
7 8
with tlree separate angled rebounding bands, which 8. The hockey training device ofclaim 1 wherein the slide
enhances real hockey sitnations. The present invention is block has a first width at a first end that is less than a second
engineered utilizing advanced plastic polymer parts, which width at a second end.
improves smooth puck sliding perforrnance with a s€cure 9. The hockey training device ofclaim I wherein the first
and tight mechanism increasing rebounding power. s elastic band is removably connected about the first pair of
It should be understood, of course, that the foregoing posts, and wherein the second elastic band is removably
relates to exemplary embodiments of the invention and that connected about the second pair ofposts.
modifications may be made without departing from the spirit 10. The hockey training device ofclaim 1. wherein the first
of the invention as set forth in the followine side block is removably connected to the first pair of posts,
,o
:ill#:* and wherein the second slide block is removably connected
to the second pair of posts.
What is claimed is: 11. The hockey training device ofclaim I wherein a front
1. A hockey training device for training a puck handling lengthwise edge ofeach ofthe slide blocks is at a right angle
in a first mode and for training a skating motion in a second 15
from a bottom surface of the slide block.
mode comprising: 12. The hockey training device of claim 1 wherein the
a substantially flat sheet; slide block has a first width at a first end that is less than a
a first pair of posts extending from the substantially flat second width at a second end.
sheet at a first end, each ofthe first pair ofposts having 13. A hockey training device for training a plurality of
a flange extending radially outwardly at a top of the 20 hockey skills having a fust mode for training a puck han-
post; d1ing, and a second mode for training a skating motion, the
a second pair ofposts extending frorr the substantially flat device further comprising:
sheet at a second end, each ofthe second pair ofposts a sheetl
having a flange extending radially outwardly at a top of a first pair ofposts extending frorn the sheet at a first end,
the post; 25 each ofthe first pair ofposts having a flange extending
a first elastic band connectable about the fust pair ofposts, radially outwardly at a top of the post;
and a second elastic band secured about the second pair a second pair ofposts extending from the sheet at a second
ofposts when the hockey training device is in the first end, each of the second pair of posts having a flange
mode; extending radially ounvardly at a top ofthe post;
afirst slide block connectable to the first pair ofposts, and 30 a first elastic band removably connectable to the first pair
a second slide block connectable to the second pair of ofposts, and a second elastic band removably connect-
posts when the hockey training device is in a slide able to the second pair ofposts;
board the second mode; and a first slide block removably connectable to the first pair
each ofthe slide blocks comprising a block base, aud two of posts, and a second slide block removably connect-
key hole slots defined in the base, each key hole slot 35 able to the second pair ofposts;
having a circular region sized to allow passage ofthe wherein each of the slide blocks comprises a block base,
flange ofeach post, and having a narrow region sized and two key hole slots defined in the base, each key
to allow passage ofthe post, but to prevent passage of hole slot having a circular region sized to allow passage
the flange ofeach posl. of the flange of each post, and having a narrow region
2. The hockey training device ofclaim L wherein the key 40 sized to allow passage of the post, but to prevent
slots ofeach slide block are aligned in a lengthwise direction passage of the flange of each post;
ofthe block. wherein in the first mode, the first elastic band is con-
3, The hockey training device ofclaim 1 wherein the key nected to the first pair of posts, and the second elastic
slots of each slide block are linearly offset in a lengthwise band is connected to the second pair ofposts; and
direction of the block. 45 wherein in the second mode, the fint slide block is
4. The hockey training device ofclaim I wherein the flat connected to the first pair ofposts, and the second slide
sheet further comprises a hinge, the hinge connecting a first block is connected to the second pair of posts.
and second portion of the flat sheet, wherein the hinge is 14. The hockey training device of claim 10 wherein the
formed having a first thick panel attached to a boflom key slots of each slide block are aligned in a lenglhwise
surface of the first sheet portion, a second thick panel 50 direction of the block.
attached to a bottom surface ofthe second sheet portion, and L5. The hockey training device of claim 10 wherein the
a thin portion connecting the first thick panel and second key slots ofeach slide block are linearly offset in a length-
thick panel, the thin portion having a thickness less than a wise direction of the block.
thickness of the first thick panel and a thickness of the 16. The hockey training device of claim 10 wherein the
second thick panel, wherein the first thick panel and second 55 sheet further comprises a hinge, the hinge connecting a first
thick panel are movable about the thin portion. and second portion ofthe sheet, wherein the hinge is formed
5. The hockey training device of claim 4 wherein the first having a first thick panel attached to a bottom surface ofthe
sheet portion further defines a plurality of apertures aligned flrst sheet portion, a second thick panel attached to a botlom
with a plurality of apertures of the first thick panel, a surface of the second sheet portion, and a thin portion
threaded insert positioned within each of the plurality of 60 connecting the first thick panel and second thick panel, the
apertures ofthe first sheet portion and fust thick panel. thin portion having a thickness less than a thickness ofthe
6. The hockey training device of claim 1 wherein a front first thick panel and a thickness of the second thick panel,
lengthwise edge of each of the slide blocks has a down- wherein the first thick panel and second thick panel are
wardly angled face. movable about the thin portion.
7. The hockey training device of claim 1 wherein a front 65 17. The hockey training device of claim 15 wherein the
lengthwise edge ofeach ofthe slide blocks is at a right angle first sheet portion further defines a plurality of apertures
from a bottom surface of the slide block. aligned with a plurality of apertures of the first thick panel,
Case 3:20-cv-03748-L Document 1-2 Filed 12/30/20 Page 41 of 41 PageID 59
us 10,076,695 B1
9 10
a threaded insert positioned within each of the plwality of
apertures ofthe fust sheet portion and first thick panel.
18. The hockey training device of claim 10 wherein a
front lengthwise edge of each of the slide blocks has a
downwardly angled face. 5
*{.***
Case 3:20-cv-03748-L Document 1-3 Filed 12/30/20 Page 1 of 9 PageID 60
Exhibit 3
Case 3:20-cv-03748-L Document 1-3 Filed 12/30/20 Page 2 of 9 PageID 61
Case 3:20-cv-03748-L Document 1-3 Filed 12/30/20 Page 3 of 9 PageID 62
Case 3:20-cv-03748-L Document 1-3 Filed 12/30/20 Page 4 of 9 PageID 63
Case 3:20-cv-03748-L Document 1-3 Filed 12/30/20 Page 5 of 9 PageID 64
Case 3:20-cv-03748-L Document 1-3 Filed 12/30/20 Page 6 of 9 PageID 65
Case 3:20-cv-03748-L Document 1-3 Filed 12/30/20 Page 7 of 9 PageID 66
Case 3:20-cv-03748-L Document 1-3 Filed 12/30/20 Page 8 of 9 PageID 67
Case 3:20-cv-03748-L Document 1-3 Filed 12/30/20 Page 9 of 9 PageID 68
JS 44 (Rev. 10/20)7;1'5HY CIVIL COVER SHEET
Case 3:20-cv-03748-L Document 1-4 Filed 12/30/20 Page 1 of 2 PageID 69
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS DEFENDANTS
Gambit Training Technologies, LLC Thomas C. Simon
(b) County of Residence of First Listed Plaintiff Tarrant County of Residence of First Listed Defendant Hillsborough
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.
(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
Samuel E. Joyner, Shore Chan DePumpo LLP, 901 Main
Peter A. Nieves, Sheehan Phinney Bass & Green PA, 1000
Street, Suite 3300, Dallas, TX 75201 (214) 593-9110
Elm Street, PO Box 3701, Manchester, NH 03105
II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
1 U.S. Government ✖ 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4 4
of Business In This State
2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State
The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as
required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is
required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of
Court for each civil complaint filed. The attorney filing a case should complete the form as follows:
I.(a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and then
the official, giving both name and title.
(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land
condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)
(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
in this section "(see attachment)".
,, Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X"
in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment
to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes
precedence, and box 1 or 2 should be marked.
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the
citizenship of the different parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversity
cases.)
,,, Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this
section for each principal party.
,9 Nature of Suit. Place an "X" in the appropriate box. If there are multiple nature of suit codes associated with the case, pick the nature of suit code
that is most applicable. Click here for: Nature of Suit Code Descriptions.
9, Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional
statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service.
9,, Requested in Complaint. Class Action. Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.
9,,, Related Cases. This section of the JS 44 is used to reference related cases, if any.,IDUHODWHGFDVHH[LVWVZKHWKHUSHQGLQJRUFORVHGLQVHUWWKH
GRFNHWQXPEHUVDQGWKHFRUUHVSRQGLQJMXGJHQDPHVIRUVXFKFDVHV$FDVHLVUHODWHGWRWKLVILOLQJLIWKHFDVHLQYROYHVVRPHRUDOORIWKHVDPH
SDUWLHVDQGLVEDVHGRQWKHVDPHRUVLPLODUFODLPLQYROYHVWKHVDPHSURSHUW\WUDQVDFWLRQRUHYHQWLQYROYHVVXEVWDQWLDOO\VLPLODULVVXHVRIODZ
DQGIDFWDQGRULQYROYHVWKHVDPHHVWDWHLQDEDQNUXSWF\DSSHDO
Date and Attorney Signature. Date and sign the civil cover sheet.