PatentNext Summary: In a precedential decision, the U.S. Court of Appeals for the Federal Circuit reversed a district court’s §101 dismissal of patent claims relating to an automated system for dumbbell weight selection and adjustment, finding that the claims were not abstract under Alice step one and therefore are patent-eligible. The Federal Circuit held that, contrary to the district court’s conclusion, the claims included meaningful limitations which provide enough specificity and structure to satisfy § 101 even though the limitations were allegedly found in the prior art. The Federal Circuit re-emphasized the importance of considering patent claims in their entirety as a whole, which the district court improperly failed to do.
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The U.S. Federal Circuit Court of Appeals reversed a decision of the U.S. District Court for the District of Utah, the latter of which had invalidated a set of patent claims claiming an automated system for dumbbell weight selection and adjustment, and remanded the case for further proceedings. PowerBlock Holdings, Inc. v. iFit, Inc., No. 24-1177 (Fed. Cir. 2025).
In the Utah district court, PowerBlock accused iFit of infringing U.S. Patent No. 7,578,771 (the ’771 Patent”) titled “Weight Selection and Adjustment System for Selectorized Dumbbells including Motorized Selector Positioning,” which “relates generally to exercise equipment” and more particularly “to selectorized dumbbells and to an overall, integrated system for selecting and adjusting the weight of a selectorized dumbbell or a pair of selectorized dumbbells.” ‘771 Patent at 1:15–19.
The district court held that the claims fail the two-step test and are patent ineligible because, at Alice step one, claims 1-18 and 20 of the ‘771 Patent were directed to the abstract idea of automated weight stacking and “implemented using generic components requiring performance of the same basic process”, and because, at Alice step two, claims 1-18 and 20 did “not add significantly more than the abstract idea of the end-result of an automated selectorized dumbbell.” Id. at *9.” (internal citations omitted).
PowerBlock appealed this decision to the Federal Circuit Court.
The Federal Circuit court reviewed claim 1 as a representative claim:
1. A weight selection and adjustment system for a selectorized dumbbell, which comprises:
(a) a selectorized dumbbell, which comprises:
(i) a stack of nested left weight plates and a stack of nested right weight plates;
(ii) a handle having a left end and a right end; and
(iii) a movable selector having a plurality of different adjustment positions in which the selector may be disposed, wherein the selector is configured to couple selected numbers of left weight plates to the left end of the handle and selected numbers of right weight plates to the right end of the handle with the selected numbers of coupled weight plates differing depending upon the adjustment position in which the selector is disposed, thereby allowing a user to select for use a desired exercise weight to be provided by the selectorized dumbbell; and
(b) an electric motor that is operatively connected to the selector at least whenever a weight adjustment operation takes place, wherein the electric motor when energized from a source of electric power physically moves the selector into the adjustment position corresponding to the desired exercise weight that was selected for use by the user.
Based on its Alice step one analysis, the Federal Circuit determined that the district court incorrectly concluded that claim 1 is “directed towards the general end of automated weight stacking” because claim 1 “seek[s] to claim systems comprising weight selection and adjustment systems consisting of the two or three ‘generic’ components, rather than any particular system or method of selectorized weight stacking” (Id. at *6), thereby “giv[ing] rise to a preemption problem” Id. at *7.
Specifically, the Federal Circuit court found that the district court had erroneously ignored limitations required by claim 1 when the district court did not consider the limitations reciting “an electric motor, coupled to a selector movable into different adjustment positions, and energizing the motor to physically move the selector via the coupling between the motor and the selector.” Id. at *8-9. According to the Federal Circuit, the district court was wrong to ignore such limitations “merely because [the ignored limitations] can be found in the prior art” Id. at *11.
As such, the district court did not properly consider, under Alice step one, the claims “in their entirety to ascertain whether their character as a whole is directed to excluded subject matter” Id. at *10 (internal citations omitted).
Further, the Federal Circuit warned “parties and tribunals not to conflate the separate novelty and obviousness inquiries under 35 U.S.C. § 102 and 103, respectively, with the step one inquiry under § 101.” Id. at f.3.
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This precedential Federal Circuit decision is promising for those pursuing patents directed to mechanical automation systems. Such practitioners should attempt to draft claims that provide physical structure and interaction while avoiding functional language that could be construed as abstract. Even if some of the physical components are known, their claimed combination and interaction may still yield patent-eligible subject matter. We note, though, that pure software-based automation may face tougher scrutiny.
Additionally, when reviewing office actions or during litigation, practitioners can utilize this decision to push back on §101 rejections that ignore the claim as a whole or conflate subject matter eligibility with novelty/obviousness.
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