DCT
2:24-cv-00177
v. MOJCO, Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: BowFlex Inc. (Washington)
- Defendant: Mojco, Inc. (California) and Eliyahu Mojdehiazad (California)
- Plaintiff’s Counsel: Husch Blackwell LLP
- Case Identification: 2:24-cv-00177, C.D. Cal., 01/08/2024
- Venue Allegations: Venue is alleged to be proper based on Defendant Mojco, Inc. being a California corporation and Defendant Eliyahu Mojdehiazad residing within the judicial district.
- Core Dispute: Plaintiff alleges that Defendants’ adjustable dumbbell products infringe three U.S. patents related to the mechanical systems and safety features of adjustable dumbbells.
- Technical Context: The technology concerns adjustable dumbbells, a category of fitness equipment that allows users to select varying amounts of weight on a single dumbbell handle, mitigating the need for a large set of fixed-weight dumbbells.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendants with notice of its patent rights and infringement concerns via letters sent in April 2022 and October 2023. Plaintiff further alleges that after the first notice, Defendant Mojdehiazad claimed to have ceased sales, but that infringing activities resumed or continued, which may form a basis for allegations of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2002-06-07 | Earliest Priority Date for ’678, ’982, and ’680 Patents |
| 2003-08-01 | Alleged First Use in Commerce of BowFlex Trade Dress |
| 2007-08-28 | ’678 Patent Issue Date |
| 2009-11-10 | ’982 Patent Issue Date |
| 2011-08-23 | ’680 Patent Issue Date |
| 2020-09-01 | Alleged Start of Infringing Sales by Defendants |
| 2022-04-01 | Plaintiff Allegedly Sent First Notice Letter to Defendants |
| 2023-10-09 | Plaintiff Allegedly Sent Second Cease and Desist Letter |
| 2024-01-08 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,261,678 - "Adjustable Dumbbell System"
- Patent Identification: U.S. Patent No. 7,261,678, "Adjustable Dumbbell System," issued August 28, 2007. (Compl. ¶16).
The Invention Explained
- Problem Addressed: The patent addresses the inconvenience and potential safety issues of adjustable dumbbells, noting that users need a secure way to change weights without the risk of inadvertent disengagement during exercise. (’678 Patent, col. 1:35-44, col. 2:5-8).
- The Patented Solution: The invention is an adjustable dumbbell system featuring a handle, a series of weight plates, and rotating selector collars to engage a desired amount of weight. A central feature is an automatic safety lock; a "rotational interference device" (such as a spring-loaded pin) prevents the selector mechanism from turning when the dumbbell is lifted from its support base. An "actuator" on the base releases this lock only when the dumbbell is properly seated, allowing the user to safely adjust the weight. (’678 Patent, col. 2:5-10, col. 6:53-65).
- Technical Importance: This design introduced an integrated safety interlock that automatically prevents weight adjustment during use, addressing a key safety concern in the adjustable dumbbell market. (’678 Patent, col. 2:5-8).
Key Claims at a Glance
- The complaint asserts independent claim 1. (Compl. ¶32).
- Claim 1 of the ’678 Patent recites:
- (a) a dumbbell comprising: (i) a handle; (ii) a fixed inner support; (iii) a rotatable inner disc; (iv) intercoupled collars also intercoupled with the inner disc; (v) a rotational interference device to couple the inner disc to the inner support; and (vi) a selector device.
- (b) a base support comprising: (i) weights with tabs; (ii) positioning walls; and (iii) an actuator that releases the rotational interference device, allowing collar flanges to engage the weight tabs.
U.S. Patent No. 8,002,680 - "Adjustable Dumbbell System"
- Patent Identification: U.S. Patent No. 8,002,680, "Adjustable Dumbbell System," issued August 23, 2011. (Compl. p. 6).
The Invention Explained
- Problem Addressed: This patent, part of the same family as the ’678 patent, also addresses the need for a safe and reliable method for selecting weights on an adjustable dumbbell. (’680 Patent, col. 1:44-59).
- The Patented Solution: The invention focuses on the functional relationship between the dumbbell and its base. It claims a system where an "engagement member" on the base interacts with an "engagement portion" on the dumbbell's selector disc. This interaction is configured to perform two functions: it "secures the dumbbell to the base" while simultaneously unlocking the weight selection mechanism. This prevents a user from lifting the dumbbell until a valid weight configuration is selected, at which point the dumbbell is "unsecured from the base" and can be removed. (’680 Patent, Abstract; col. 14:7-21).
- Technical Importance: The claimed solution frames the safety mechanism in terms of physically securing the dumbbell to its base during adjustment, preventing the removal of an improperly configured or potentially unsafe dumbbell. (’680 Patent, col. 2:4-10).
Key Claims at a Glance
- The complaint asserts independent claim 1. (Compl. ¶46).
- Claim 1 of the ’680 Patent recites:
- An apparatus with a dumbbell (comprising at least one weight plate and a selector with a disc having an engagement portion) and a base (including an engagement member).
- The engagement member and engagement portion are configured to secure the dumbbell to the base when engaged and unsecure it when disengaged.
- A user is unable to readily remove the dumbbell from the base when it is secured.
- A user may readily remove the dumbbell from the base when it is unsecured.
U.S. Patent No. 7,614,982 - "Adjustable Dumbbell System"
- Patent Identification: U.S. Patent No. 7,614,982, "Adjustable Dumbbell System," issued November 10, 2009. (Compl. ¶18).
- Technology Synopsis: This patent claims an adjustable dumbbell apparatus with a locking mechanism that prevents the weight selector from moving relative to the bar when the dumbbell is not in its base. An actuator within the base releases the locking mechanism when the dumbbell is received, thereby allowing the selector to move and the weight to be changed. (’982 Patent, Abstract).
- Asserted Claims: Independent claim 8. (Compl. ¶60).
- Accused Features: The complaint accuses the product’s use of "metal protrusions on the base that move a button component" to engage and disengage a pin, which in turn locks or unlocks the selection dial. (Compl. ¶62.g).
III. The Accused Instrumentality
Product Identification
The "Mojco AbleAdjust," "Mojco Smartbell," and "Mojco Adjustable Dumbbell 52.5 lbs" products. (Compl. ¶23).
Functionality and Market Context
The complaint describes the Accused Product as an adjustable dumbbell system that, like Plaintiff's products, uses a selection dial to engage and disengage various weight plates stored in a base. (Compl. ¶62.c, ¶62.e). A photograph of the Accused Product shows opposing sets of segmented, frusto-conical weight plates and a selection dial at the end of the dumbbell. (Compl. p. 23, ¶75). The complaint alleges that the Accused Product was developed by copying BowFlex's technology and directly competes with BowFlex's SelectTech dumbbells in the same markets. (Compl. ¶24, ¶25).
IV. Analysis of Infringement Allegations
U.S. Patent No. 7,261,678 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| (a) a dumbbell comprising: (i) a handle; | The Accused Product has a dumbbell with a handle. | ¶34.c | col. 6:7-8 |
| (ii) an inner support mounted on the handle and substantially fixed relative to the handle; | The Accused Product has inner supports near the handle. | ¶34.d | col. 6:9-12 |
| (iii) an inner disc rotatably mounted on the handle; | The Accused Product has an inner metal disc between an inner support and the innermost weight plate. | ¶34.e | col. 6:12-14 |
| (iv) a plurality of intercoupled collars ... further intercoupled with the inner disc; | The Accused Product has a plurality of intercoupled collars intercoupled with an inner disc. | ¶34.f | col. 6:14-18 |
| (v) a rotational interference device for coupling the inner disc to the inner support; | The Accused Product has a rotational interference device for coupling the inner disc to the inner support. | ¶34.g | col. 6:60-65 |
| (vi) a selector device intercoupled with the plurality of intercoupled collars and the inner disc; | The Accused Product has a selection dial at the end of each dumbbell. | ¶34.h | col. 6:20-23 |
| (b) a base support comprising: (i) a plurality of weights, each weight having a tab; | The Accused Product has a base support with multiple weight plates, each with a tab for engagement. | ¶34.j | col. 6:27-29 |
| (iii) an actuator for releasing the rotational interference device... | The Accused Product has a base support with an actuator for releasing the rotational interference device to allow weight selection. | ¶34.l | col. 6:53-59 |
Identified Points of Contention: The complaint's allegations for the '678 patent frequently assert that the Accused Product's features are arranged in a manner "similar, substantially similar, and/or identical" to Plaintiff's products, which it alleges are copies. (Compl. ¶34.f, ¶34.g). A central technical question will be whether the specific mechanical components of the Accused Product, once revealed in discovery, meet the structural limitations of the "rotational interference device" and "actuator" as claimed, or if they operate via a distinct mechanism.
U.S. Patent No. 8,002,680 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a dumbbell comprising ... a selector ... including a disc with at least one engagement portion; | The Accused Product has a dumbbell with a selection dial interconnected with an inner disc that has numerous teeth. | ¶48.c | col. 7:4-9 |
| a base configured to receive the dumbbell and including an engagement member | The Accused Product has a base with a tab that protrudes to engage and disengage with the teeth of the inner disc. | ¶48.d | col. 7:1-9 |
| wherein ... engagement ... secures the dumbbell to the base and disengagement ... unsecures the dumbbell from the base; | The arrangement of the tab and teeth provides a feature to lock and unlock the dumbbell from the base. | ¶48.e | col. 14:7-14 |
| when the dumbbell is secured ... a user is unable to readily remove the dumbbell from the base; | When the tab is engaged with a tooth, a user is unable to readily remove the dumbbell from the base. | ¶48.e | col. 7:1-9 |
| when the dumbbell is unsecured ... the user may readily remove the dumbbell from the base. | When the tab is disengaged from a tooth, the user may readily remove the dumbbell from the base. | ¶48.e | col. 7:9-14 |
Identified Points of Contention: Claim 1 of the ’680 Patent is highly functional. A potential point of contention may be the meaning of "secures the dumbbell to the base." Defendants may argue that their mechanism only locks the selector dial and does not physically secure the entire dumbbell apparatus to the base structure, raising the question of whether this functional limitation is met.
V. Key Claim Terms for Construction
The Term: "rotational interference device" (’678 Patent, Claim 1)
- Context and Importance: This term defines the core safety lock mechanism. The scope of this term will be critical to determining infringement, as it dictates what types of locking structures are covered by the patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent abstract describes the mechanism functionally as a "means for selectively securing the support plate to the inner plate to resist the rotation," which may support a construction covering any device that achieves this function. (’678 Patent, Abstract).
- Evidence for a Narrower Interpretation: The specification discloses a specific embodiment of this device as a "spring-loaded pin 34" that engages an "aperture 40" in the inner disc. (’678 Patent, col. 6:60-65, Fig. 4). This may support a narrower construction limited to a pin-based mechanism or its structural equivalents.
The Term: "secures the dumbbell to the base" (’680 Patent, Claim 1)
- Context and Importance: This functional language is central to the infringement theory for the '680 patent. The dispute will likely turn on the degree of connection required to meet this limitation.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim links this term to the functional outcome that "a user is unable to readily remove the dumbbell from the base," suggesting the term could be interpreted from the user's perspective to mean any configuration that prevents removal for use. (’680 Patent, col. 14:15-17).
- Evidence for a Narrower Interpretation: The specification describes a mechanism where a protrusion on the base engages teeth on the dumbbell's inner disc, which prevents the dumbbell from being lifted out. (’680 Patent, incorporating by reference the specification of the ’678 patent, e.g., col. 7:1-9). This could support an interpretation requiring a direct mechanical interlock that prevents the dumbbell from being lifted from the base.
VI. Other Allegations
- Indirect Infringement: The complaint alleges indirect infringement against the individual defendant, Eliyahu Mojdehiazad, based on his alleged "high level of personal participation and control" over Mojco, Inc. and his alleged knowledge of the asserted patents. (Compl. ¶40, ¶54, ¶68).
- Willful Infringement: Willfulness is alleged for all asserted patents. The complaint provides a factual basis for this allegation by citing a pre-suit notice letter sent in April 2022, an alleged promise by Defendant Mojdehiazad to cease sales, and alleged subsequent continued infringing activity, followed by another cease and desist letter in October 2023. (Compl. ¶27, ¶29, ¶37).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of technical equivalence: The infringement case may depend on whether the Accused Product's locking mechanism—allegedly a base-mounted "tab" or "protrusion" that interacts with a "button component" and "inner disc teeth"—is structurally and functionally equivalent to the claimed "rotational interference device" and "actuator" of the '678 patent and the "engagement member" of the '680 patent.
- A key factual dispute will concern willful infringement: Given the complaint’s specific allegations of pre-suit notice, a promise to cease sales, and subsequent continued sales, the defendants' state of mind and the objective reasonableness of their actions after being notified of the patents will likely be a primary focus of the litigation.
- The case may turn on a question of definitional scope: The construction of the functional term "secures the dumbbell to the base" in the '680 patent will be critical. The court will need to determine if this requires a rigid physical lock between the dumbbell and base structures, or if it is satisfied by any mechanism that functionally prevents a user from readily removing the dumbbell.