EXHIBIT B

APP004

Case 3:22-cv-00686-X Document 20-2 Filed 05/18/22 Page 1 of 3 PageID 463
Scuf Gaming International LLC • 3970 Johns Creek Ct., Suite 325 • Suwanee, GA 30024

November 5, 2019 

Via Email and First Class Mail 

Chris Bailey 

Battle Beavers Customs 

3708 Olsen Blvd 

Amarillo, TX 79109 

Chris@battlebeavercustoms.com 

 Re: On-going Patent Infringement by Battle Beaver Customs 

Dear Mr. Bailey:

I previously wrote to you in June 2019 regarding your company’s infringement of United 

State Patent Number 10,188,940 (“the ‘940 Patent”) owned by Scuf Gaming’s affiliate Ironburg 

Inventions Limited (collectively with Scuf Gaming referred to as “SCUF”). In your June 13, 

2019 response, you stated that all products that violate the ‘940 Patent claims have been removed 

from Battle Beaver Customs’ (“Battle Beaver”) website when in fact this is not the case and you 

have additional features that infringe. Contrary to your June 13 response, Battle Beaver 

continues to advertise, manufacture, and sell game controllers with the “Smart Trigger” feature 

identified as infringing in my June 2019 letter, as well as game controllers with the separate 

“Racer Trigger” feature. 

Battle Beaver’s Smart Triggers are advertised as triggers that “remove the travel time 

necessary for the button to register an input” and that prevent the trigger from “having to travel 

all the way down.” See https://battlebeavercustoms.com/blogs/news/smart-triggers-and-bumpers. 

Such mechanisms contained within an internal volume of the controller body that adjust and/or 

reduce the travel of the trigger, like the Smart Trigger, would infringe at least claims 1 and 5 of 

the ‘940 Patent. 

Similarly, Battle Beaver’s Racer Triggers are advertised as “a hybrid between Stock and 

Smart triggers” with a reduced trigger travel such that the “trigger will move freely from 0-50%” 

and then stop with an activation. See https://battlebeavercustoms.com/tools/builder/45. Like the 

Smart Trigger, the Racer Trigger mechanism contained within the internal volume of the 

controller body that adjusts and/or reduces the trigger travel would also infringe at least claims 1 

and 5 of the ‘940 Patent. 

Additionally, to the extent that you are selling controllers with either above listed feature 

in Europe, please be advised of the recent grant of the European counterpart of the ‘940 Patent, 

EP3074101, which will be validated shortly in various European countries including the UK, 

Spain, Germany, and France. Battle Beaver’s European sales of products with the Smart Trigger 

and/or Racer Trigger features will likewise infringe the claims of EP2074101 once validated. 

 

APP005

Case 3:22-cv-00686-X Document 20-2 Filed 05/18/22 Page 2 of 3 PageID 464
November 5, 2019 

Page 2 

In light of the above, SCUF reiterates its demand that Battle Beaver cease advertising, 

promoting, manufacturing, selling products that infringe the ‘940 Patent, including products with 

the Smart Trigger and/or Racer Trigger features immediately. Additionally, since Battle Beaver 

seems determined to add features to its products that infringe SCUF’s intellectual property, we 

invite you to review SCUF’s patent portfolio listed at https://scufgaming.com/s/patents before 

implementing any additional features on Battle Beaver’s products. 

As you are no doubt aware, other manufacturers have acknowledged the strength of 

SCUF’s patent portfolio by taking a license. SCUF will not stand by idly in the face of Battle 

Beaver’s on-going, and at this point willful, infringement of our intellectual property. I am 

available over the next week for a discussion to see if this matter may be resolved. Absent such 

resolution, SCUF expects Battle Beaver to cease all advertising, manufacturing, and sales of 

products with the above-identified features by November 13, 2019. After that date, SCUF will 

be forced to turn this matter over to outside counsel for further action. 

 Sincerely, 

          Robert B. Dulaney III | General Counsel 

 

 

APP006

Case 3:22-cv-00686-X Document 20-2 Filed 05/18/22 Page 3 of 3 PageID 465