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Federal Circuit Finds Claims Of Selectorized Dumbbell Weight Patent Not Directed To An Abstract Idea
08/26/2025On August 11, 2025, the U.S. Court of Appeals for the Federal Circuit (“CAFC”) issued an opinion reversing the decision of the U.S. District Court for the District of Utah that found certain claims of a selectorized dumbbell patent ineligible under 35 U.S.C. § 101. PowerBlock Holdings, Inc. v. iFit, Inc., __ F.4th __ (Fed. Cir. Aug. 11, 2025).
PowerBlock Holdings, Inc. (“PowerBlock”) owns U.S. Patent No. 7,578,771, which is directed to a system for selecting and adjusting the weight of selectorized dumbbells used for exercising and weightlifting. PowerBlock sued iFit, Inc. (“iFit”) for patent infringement (and for violating Utah’s Unfair Competition Act). iFit moved to dismiss for failure to state a claim, arguing that the claims of the ’771 patent are ineligible under § 101.
The district court applied the two-step Alice framework for determining patent eligibility and determined that all but one claim of the ’771 patent are ineligible under § 101. Under step one, the district court held that claims 1–18 and 20 of the ’771 patent are directed to the abstract idea of automated selectorized dumbbell weight stacking and that that idea is implemented using generic components. Under step two, the district court concluded that, because claims 1–18 and 20 “do not add significantly more than the abstract idea of the end-result of an automated selectorized dumbbell,” the claims fail the two-step test and are ineligible. In light of the district court’s finding that claims 1–18 and 20 of the ’771 are invalid as ineligible, and PowerBlock’s desire to appeal that finding, the parties stipulated to dismiss PowerBlock’s remaining claim for infringement of claim 19 (the only patent claim that survived the § 101 challenge) and its related cause of action under Utah’s Unfair Competition Act.
On appeal, the CAFC analyzed, as representative, claim 1 of the ’771 patent, seeking to determine whether the claims focus on a specific means or method that improves the relevant technology or whether they are directed to a result or effect that itself is the abstract idea and merely invoke generic processes and machinery.
At step one of the Alice inquiry, the CAFC disagreed with the district court’s conclusion that the patent seeks to claim systems comprising weight selection and adjustment systems consisting of two or three generic components rather than any particular system or method of selectorized weight stacking. While recognizing that claim 1 is broad, the CAFC found that it is, however, limited to a particular type of dumbbell: “a selectorized dumbbell with a stack of nested left weight plates, a stack of nested right weight plates, a handle, and a movable selector with different adjustment positions, where moving the selector to different adjustment positions changes the number of left and right weight plates coupled to the dumbbell.” The CAFC further noted that an electric motor is what physically moves the selector into the different adjustment positions that correspond to the desired weight. Thus, the CAFC held that the limitations of claim 1 provide enough specificity and structure to satisfy § 101.
In its analysis, the CAFC also distinguished PowerBlock’s patent claims from the patent claims in two other cases in which claims were found patent ineligible. The first case, University of Florida Research Foundation, Inc. v. General Electric Co., which the district court referenced, involved a patent directed to a method and system for integrating physiologic data from at least one bedside machine for the purpose of automating the recordation of those data to conserve human resources and minimize errors. The CAFC contrasted that purported invention—which was a quintessential “do it on a computer” patent—with the claims of the ’771 patent—which is directed to a mechanical invention, an improved machine. The second case, Chamberlain Grp., Inc. v. Techtronic Indus. Co., which iFit referenced at oral argument on appeal, involved a patent directed to a system for wirelessly controlling a moveable barrier, such as a garage door. The claims of that patent recited a moveable barrier operator with a controller, an interface, and a wireless transmitter that sends status information (but the claims did not recite the moveable barrier itself). The CAFC explained that, in that case, the claims were generically “directed to wirelessly communicating status information about a system” and were “not limited to a specific implementation of a technological improvement to a communications system.” By contrast, claim 1 of the ’771 patent recites elements of a mechanical device, including an electric motor that physically moves a selector in a specific manner that is a purported improvement to selectorized dumbbell weight stacking.
The CAFC’s opinion addressed another of iFit’s arguments on appeal—namely, that the claim limitations involving conventional selectorized dumbbell components should be ignored when assessing whether claim 1 is directed to a specific structure or an abstract idea. Specifically, iFit argued that “[r]epeating elements of prior art selectorized dumbbells does not imbue claim 1 with any specific means or method” and that “the structure that is identified … is nothing more than conventional components that have existed” in the selectorized dumbbell prior art. In response, the CAFC explained that the Alice step one inquiry involves consideration of the claims in their entirety in order to ascertain whether the character of the claims as a whole is directed to excluded subject matter, and cautioned both against oversimplifying the claims and against conflating the separate novelty and obviousness inquiries with step one of the Alice § 101 inquiry. The CAFC found that claim 1 is directed to a sufficiently specific mechanical invention that, as a whole, advantageously automates selectorized dumbbell weight stacking.
In light of its conclusion that claim 1 of the ’771 patent is not directed to an abstract idea, the CAFC reversed and remanded the district court’s patent-ineligibility finding.
