`U.S. Patent No. 9,295,288 (“the ‘288 Patent”)
`
`NIKE’s making, using, offering to sell, and selling of Swoosh On The Run product
`infringes Claims 1, 2, 3 and 11 of the ‘288 Patent whenever an item is positioned
`in the Swoosh On The Run’s front pockets—which NIKE intentionally induces
`purchasers and users of the product to do. The Swoosh on The Run includes all the
`features embodied in those claims literally or by the doctrine of equivalents.
`
`Here are two images of the Swoosh on The Run from NIKE’s website:1
`
`References:2
`• NIKE Swoosh On The Run, NIKE.COM, https://www.NIKE.com/t/swoosh-on-
`the-run-womens-medium-support-lightly-lined-sports-bra-with-pockets-
`qQtjGS (last visited May 15, 2023).
`
`1 NIKE Swoosh On The Run, NIKE.COM, https://www.NIKE.com/t/swoosh-on-the-run-womens-medium-support-
`lightly-lined-sports-bra-with-pockets-qQtjGS (last visited May 15, 2023).
`2 All images in this chart are from this reference unless otherwise indicated.
`1
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`Nike, Inc. v. SherryWear, LLC et al. IPR2024-01125 SherryWear, LLC Exhibit 2054 Page 1
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`
`
`U.S. Patent No. 9,295,288
`(Claim 1)
`1. [pre] A bra pocket system
`combination comprising:
`
`[1.1] a strap assembly including a chest
`strap and shoulder straps; left and
`right cups, each cup having inside and
`outside surfaces, the strap assembly
`being attached to the cups whereby the
`strap assembly adheres the cups to a
`wearer, each cup having curved upper,
`lower, interior body facing and opposite
`exterior edges;
`
`Infringing NIKE Product
`(Swoosh on The Run)
`NIKE advertises the Swoosh on The
`Run as follows:
`
`“[a] women's medium-support lightly
`lined sports bra with pockets.”3
`
`and;
`
`“3 mesh-lined pockets hold your phone,
`a snack or an extra layer so you can
`explore without limits.”4
`
`The Swoosh On The Run has a chest
`strap (1), shoulder straps (2), and left
`and right cups (3). Each cup has inside
`and outside surfaces as well as upper,
`lower, interior body facing and opposite
`exterior edges:
`
`[1.2] a patch forming a pocket
`operatively associated with each cup,
`each patch having a linear upper edge
`and curved lower, interior body facing,
`
`The Swoosh On The Run has two
`patches, each associated with a cup,
`which NIKE refers to as “PKT \ 01”
`and “PKT \ 02.” Each patch has an
`
`3 See supra, note 1.
`4 See supra, note 1.
`
`2
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`Nike, Inc. v. SherryWear, LLC et al. IPR2024-01125 SherryWear, LLC Exhibit 2054 Page 2
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`
`
`and opposite exterior edges, each patch
`having inside and outside surfaces;
`stitching coupling the lower, interior
`body facing and opposite exterior edges
`of each patch to the lower, interior body
`facing, and opposite exterior edges of an
`associated cup;
`
`upper, lower, and exterior edge. Each
`patch has an inside and outside surface.
`Each patch forms a pocket:
`
`Each patch has a linear upper edge:
`
`5
`
`Each patch has a lower body facing
`edge and an opposite exterior edge:
`
`5 Inside-out photo of the physical product.
`
`3
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`Nike, Inc. v. SherryWear, LLC et al. IPR2024-01125 SherryWear, LLC Exhibit 2054 Page 3
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`
`
`6
`
`Stitching couples each patch to each
`associated cup:
`
`[1.3] a linear opening formed along the
`upper edge of each patch;
`
`A linear opening is formed along the
`upper edge of each patch:
`
`7
`
`6 See supra, note 5.
`7 See supra, note 5.
`
`4
`
`Nike, Inc. v. SherryWear, LLC et al. IPR2024-01125 SherryWear, LLC Exhibit 2054 Page 4
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`
`
`NIKE advertises that various items
`may be positioned within the Swoosh
`On The Run’s Pockets:
`
`“3 mesh-lined pockets hold your phone,
`a snack or an extra layer so you can
`explore without limits.”8
`
`The lower edges of each patch and each
`cup are aligned:
`
`[1.4] at least one of a handheld
`electronic device, keys, and pills
`removably positioned within the pocket
`of at least one of the left and right cups;
`and
`
`[1.5] wherein each patch curved lower
`interior body facing and opposite
`exterior edges are aligned with each
`curved lower interior body facing and
`opposite exterior edges, and wherein
`the stitching is along the curved lower
`interior body facing and opposite
`exterior edges of the patch, the linear
`upper edge of each patch crossing over
`a surface of the cup to form the linear
`opening.
`
`9
`
`The linear upper edge of each patch
`crosses over a surface of the cup to form
`the linear opening:
`
`10
`
`8 See supra, note 1.
`9 See supra, note 5.
`10 See supra, note 5.
`
`5
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`Nike, Inc. v. SherryWear, LLC et al. IPR2024-01125 SherryWear, LLC Exhibit 2054 Page 5
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`
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`U.S. Patent No. 9,295,288
`(Claim 2)
`2. The system as set forth in claim 1
`wherein the cups and the patches form
`pockets, the cups being fabricated of a
`resilient closed cell polyurethane foam
`with a thickness of from 2 to 4
`millimeters.
`
`Infringing NIKE Product
`(Swoosh On The Run)
`Product Details:
`
`Body: 82% polyester/18% spandex.
`Bottom hem: 73% polyester/15%
`spandex/12% nylon. Front panel lining:
`80% Polyester/20% spandex. Back
`lining/Interlining: 82% polyester/18%
`spandex.11
`
`U.S. Patent No. 9,295,288
`(Claim 3)
`3. The system as set forth in claim 1
`wherein the cups and the patches form
`pockets, the patches being fabricated of
`an elastic fabric.
`
`Infringing NIKE Product
`(Swoosh on The Run)
`Product Details:
`
`Body: 82% polyester/18% spandex.
`Bottom hem: 73% polyester/15%
`spandex/12% nylon. Front panel lining:
`80% Polyester/20% spandex. Back
`lining/Interlining: 82% polyester/18%
`spandex.12
`
`U.S. Patent No. 9,295,288
`(Claim 11)
`11. The system as set forth in claim 1
`wherein the linear opening is facing the
`upper interior edge to allow the at least
`one of the handheld electronic device,
`keys, and pills to be removably
`positioned within the pocket by entry
`adjacent to a shoulder of the user.
`
`Infringing NIKE Product
`(Swoosh On The Run)
`The linear opening faces the interior:
`
`“Lefties rejoice! 2 angled side pockets
`keep your phone in place while allowing
`easy access–no matter your dominant
`hand.”13
`
`11 See supra, note 1.
`12 See supra, note 1.
`13 See supra, note 1.
`
`6
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`Nike, Inc. v. SherryWear, LLC et al. IPR2024-01125 SherryWear, LLC Exhibit 2054 Page 6
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`
`
`14
`
`14 See supra, note 5.
`
`7
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`Nike, Inc. v. SherryWear, LLC et al. IPR2024-01125 SherryWear, LLC Exhibit 2054 Page 7
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