DCT
1:23-cv-23784
RampWerks LLC v. J&B Importers Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: RampWerks, LLC (Texas)
- Defendant: J & B Importers, Inc. (Florida)
- Plaintiff’s Counsel: Jeffrey B. Shalek, Esq., P.A.; Connor Lee and Shumaker PLLC
- Case Identification: 1:23-cv-23784, S.D. Fla., 10/04/2023
- Venue Allegations: Venue is alleged to be proper because Defendant is a Florida corporation that resides in the district, where it markets, sells, delivers, and instructs customers on the use of the accused products.
- Core Dispute: Plaintiff alleges that Defendant’s importation and sale of absoluteBLACK high-performance bicycle chainrings infringes three patents related to chainring ramp technology for improving gear shifting.
- Technical Context: The technology concerns mechanical improvements to bicycle chainrings, a key component in a bicycle's drivetrain, designed to achieve faster and more reliable shifting, particularly under high-torque conditions experienced during racing or climbing.
- Key Procedural History: The complaint notes that the manufacturer of the accused products, absoluteBLACK of Slovenia, has not responded to a separate patent infringement complaint filed by the Plaintiff in the U.S. District Court for the Eastern District of Texas.
Case Timeline
| Date | Event |
|---|---|
| 2005-09-27 | '338, '875, and '099 Patents Priority Date |
| 2020-06-09 | U.S. Patent No. 10,677,338 Issue Date |
| 2020-07-14 | U.S. Patent No. 10,711,875 Issue Date |
| 2022-10-04 | U.S. Patent No. 11,460,099 Issue Date |
| 2023-10-04 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,677,338, "Bicycle Chain Rings," Issued June 9, 2020
The Invention Explained
- Problem Addressed: The patent addresses the problem of poor bicycle gear shifting performance, especially "up-shifting" to a larger chainring, under the extreme loads experienced during sprinting or climbing (’338 Patent, col. 1:49-54). Prior art solutions that use pins to assist the shift can increase stress on the chain and reduce its longevity (’338 Patent, col. 2:30-38).
- The Patented Solution: The invention is a chainring featuring a plurality of ramps on its inner surface. Each ramp has a specially configured "lifting surface" designed to concurrently engage a single link of the bicycle chain at two or more distinct pivot points. This creates a "stable lift," moving the chain onto the larger ring without assistance from the chainring teeth, which spreads the shifting load and improves performance (’338 Patent, Abstract; col. 6:5-14; Fig. 1).
- Technical Importance: This approach sought to provide more reliable and rapid up-shifting under high torque, a crucial performance characteristic for competitive and enthusiast cyclists (’338 Patent, col. 1:49-54).
Key Claims at a Glance
- The complaint asserts infringement of at least independent claim 1 (Compl. ¶28).
- The essential elements of Claim 1 include:
- A bicycle chain ring with an inner edge, an inner surface, and an outer edge with teeth.
- A plurality of ramps on the inner surface.
- At least one ramp having a lifting surface configured to "concurrently engage at least one link of a bicycle chain at two or more distinct pivot points" along the link's length.
- This engagement initiates a "stable lift" of the chain "without assistance from any of the plurality of chain ring teeth."
- The lifting surface has a first end near the inner edge and a second end near the outer edge.
- The complaint reserves the right to assert other claims (Compl. ¶28).
U.S. Patent No. 10,711,875, "Bicycle Chain Rings," Issued July 14, 2020
The Invention Explained
- Problem Addressed: As a continuation of the same inventive effort, this patent also addresses inefficient shifting under load. It specifically illustrates the unstable "see saw action" that can result from prior art single-pin lifting mechanisms, where the chain can slip off the pin (’875 Patent, col. 3:41-55, Fig. 30B).
- The Patented Solution: The invention refines the ramp-based shifting system. A key feature is a plurality of "lifting surfaces perpendicularly disposed about an inner surface" of the chainring that are configured to engage the chain directly below its load-bearing pivot points (’875 Patent, col. 22:7-13). The patent also specifies that the lifting surface terminates before reaching the bottom of the trough between adjacent teeth, a design choice intended to ensure a clean hand-off as the chain seats on the larger ring (’875 Patent, Abstract; col. 21:8-10).
- Technical Importance: This configuration aims to provide superior, stable engagement by lifting the chain directly under its multiple load points, in contrast to the single, unstable lift point provided by conventional pins (’875 Patent, col. 8:19-31, Fig. 31C).
Key Claims at a Glance
- The complaint asserts infringement of at least independent claim 8 (Compl. ¶35).
- The essential elements of Claim 8 include:
- A bicycle chain ring with a plurality of "lifting surfaces perpendicularly disposed about an inner surface."
- The lifting surfaces are configured to "concurrently engage two or more load points of a bicycle chain below bicycle chain link pins."
- This engagement initiates "stable lift" without assistance from chainring teeth or shift pins.
- The lifting surface extends radially from a first radius to a greater second radius and has a first end near the inner edge and a second end near the outer edge.
- The complaint reserves the right to assert other claims (Compl. ¶35).
U.S. Patent No. 11,460,099, "Bicycle Chain Rings," Issued October 4, 2022
- Technology Synopsis: This patent continues the subject matter of the asserted family, focusing on ramp-based shifting aids to overcome the deficiencies of prior art. The invention is directed at a chainring with ramps having a lifting surface for stable, multi-point engagement with a chain link, but specifically claims a configuration where the lifting surface includes an "inside taper" designed to receive and lift a portion of the chain link during an up-shift (’099 Patent, col. 14:35-39, Claim 3).
- Asserted Claims: Independent claim 1 (Compl. ¶42).
- Accused Features: The complaint alleges that the ramp structures on the accused absoluteBLACK chainrings infringe this patent (Compl. ¶11, ¶16, ¶42).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are "absoluteBLACK bicycle chainrings," which are imported, distributed, and sold by Defendant J & B Importers, Inc. (Compl. ¶1, ¶11). The complaint provides a non-exhaustive list of accused models, including the "Oval 110 BCD 2X" and "Oval 130 BCD 2X" (Compl. ¶11).
Functionality and Market Context
- The products are described as specialty chainrings for high-performance bicycles (Compl. p. 1). The complaint includes a screenshot from Defendant's website describing an accused product as having a "special oval shape" and a "superb quality with great 6 point shifting design" (Compl. ¶4). The core accused functionality involves structures that the manufacturer, absoluteBLACK, refers to as "ramps," which the complaint alleges are designed to improve up-shifting (Compl. ¶17-18).
IV. Analysis of Infringement Allegations
’338 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an inner edge fully circumscribing both an opening and an axis of rotation | The accused chainrings are alleged to comprise an inner edge that circumscribes a central opening and axis of rotation. The complaint provides a labeled photograph identifying this feature on an accused product (Compl. p. 6). | ¶14 | col. 6:1-3 |
| an inner surface extending between the inner edge and an outer edge where a plurality of chain ring teeth emanate | The accused chainrings are alleged to have an inner surface between their inner and outer edges from which the teeth extend. The complaint provides a labeled photograph identifying the inner surface (Compl. p. 7). | ¶15 | col. 6:3-5 |
| a plurality of ramps disposed about the inner surface, wherein at least one of the plurality of ramps has a lifting surface configured to concurrently engage at least one link...at two or more distinct pivot points...to initiate stable lift...without assistance from any...chain ring teeth | The accused chainrings are alleged to feature a plurality of structures, which the manufacturer calls "ramps." These ramps are alleged to have a lifting surface configured to engage a chain link at multiple points to initiate a stable lift. A photograph shows the chain engaging one such ramp (Compl. p. 11). | ¶16, ¶20 | col. 6:5-14 |
| wherein the lifting surface has a first end proximate the inner edge and a second end proximate the outer edge | The lifting surfaces of the ramps on the accused chainrings are alleged to have a first end near the inner edge and a second end near the outer edge of the chainring. | ¶21 | col. 6:14-16 |
- Identified Points of Contention:
- Technical Question: A primary factual dispute may concern the final limitation of Claim 1: whether the accused ramps "initiate stable lift... without assistance from any of the plurality of chain ring teeth." A defense may argue that the chainring teeth are, in fact, integral to the lifting process in the accused products, which would suggest non-infringement.
- Scope Question: The meaning of "stable lift" and "concurrently engage" will be critical. The court will need to determine if the interaction between the accused ramp and a bicycle chain meets the specific multi-point, stable lifting function described and claimed in the patent, as opposed to a different type of interaction, such as a rolling or single-point contact.
’875 Patent Infringement Allegations
| Claim Element (from Independent Claim 8) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a plurality of lifting surfaces perpendicularly disposed about an inner surface of the bicycle chain ring | The accused chainrings are alleged to have ramps with lifting surfaces on their inner surface. The complaint's photographs depict these raised structures (Compl. p. 8). | ¶16, ¶19 | col. 21:5-7 |
| at least one of the lifting surfaces being configured to concurrently engage two or more load points of a bicycle chain below bicycle chain link pins, thereby initiating stable lift...without assistance from chain ring teeth or shift pins | The complaint alleges that the ramps are configured to engage a chain link at multiple distinct points to initiate a stable lift, which is the core of the infringement theory for the entire patent family. | ¶20 | col. 21:7-13 |
| wherein at least one of the plurality of lifting surfaces extends radially along the inner surface...the at least one lifting surface has a first end proximate an inner edge...and a second end proximate the outer edge | The ramps on the accused products are shown in photographs to extend radially from an inner portion of the chainring toward the outer teeth, which the complaint alleges meets this limitation. | ¶16, ¶21 | col. 21:13-22 |
- Identified Points of Contention:
- Scope Question: The claim term "perpendicularly disposed" may be a significant point of dispute. A defense could argue for a strict geometric interpretation requiring a 90-degree angle between the lifting surface and the chainring's main plane, which the sloped or contoured ramps on the accused products may not satisfy.
- Technical Question: As with the ’338 patent, a key technical question will be whether the accused ramps function to provide "stable lift" by engaging "two or more load points... below bicycle chain link pins" as specifically described in the patent, or if they operate via a different mechanism.
V. Key Claim Terms for Construction
Term from the ’338 Patent: "stable lift"
- The Term: "stable lift"
- Context and Importance: This term is central to the invention's purported improvement over the prior art. The patent family distinguishes this "stable lift" from the unstable "see saw action" of single-pin lifters (’875 Patent, Fig. 30B). The infringement analysis for the ’338 patent will likely depend on whether the function of the accused ramps can be characterized as providing the claimed "stable lift."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the feature as providing "better support to lift a bicycle chain during up-shifts" (’338 Patent, col. 8:39-40). A plaintiff may argue that any lifting mechanism that is demonstrably more stable than a single prior art pin falls within the scope of the term.
- Evidence for a Narrower Interpretation: The claim requires this lift to be initiated by "concurrently engag[ing]" a chain link at "two or more distinct pivot points" (’338 Patent, col. 14:23-25). A defendant may argue that "stable lift" is explicitly defined by this multi-point engagement and requires a specific, simultaneous contact that its product does not achieve.
Term from the ’875 Patent: "perpendicularly disposed"
- The Term: "perpendicularly disposed"
- Context and Importance: This term describes the physical orientation of the lifting surfaces and appears to be a precise structural limitation in Claim 8 of the ’875 patent. Practitioners may focus on this term because its construction could be dispositive of infringement based on the specific geometry of the accused products' ramps.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A plaintiff may argue that in the context of the invention, the term means the lifting surfaces are generally raised from, and project away from, the inner surface plane of the chainring, rather than requiring a strict 90-degree angle.
- Evidence for a Narrower Interpretation: A defendant may argue that the plain and ordinary meaning of "perpendicularly" requires a strict 90-degree angular relationship. The patent specification uses the term but does not provide an explicit definition, potentially leaving its interpretation to depend heavily on expert testimony regarding its meaning to a person of ordinary skill in the art.
VI. Other Allegations
Indirect Infringement
- While no formal count for indirect infringement is included, the complaint lays a potential foundation by alleging that the Defendant "directs and instructs customers and end users how to use the accused products" (Compl. ¶9), which are facts often used to support a claim of induced infringement.
Willful Infringement
- The complaint alleges that Defendant is on notice of the patents and their infringement "at least as of the service of this Complaint" (Compl. ¶29, ¶36, ¶43). This pleading establishes a basis for claiming post-suit willfulness. The prayer for relief requests that the court find this to be an "exceptional case" under 35 U.S.C. § 285, which could entitle the plaintiff to attorneys' fees (Compl. p. 17).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of functional equivalence: do the ramps on the accused absoluteBLACK chainrings operate by initiating the specific "stable lift" described in the patents—engaging a chain link at multiple points simultaneously without help from the teeth—or do they achieve a similar result through a different, non-infringing technical method?
- A key dispute will center on claim construction: can the term "perpendicularly disposed" from the ’875 patent be interpreted to read on the potentially sloped or contoured geometry of the accused ramps, or does it impose a strict structural limitation that the accused products do not meet?
- A central theme of the litigation may be the defendant's role and knowledge: as the suit targets an importer/distributor rather than the foreign manufacturer, the proceedings may focus on the scope of J & B Importers' activities in the U.S. and what it knew about the patents, particularly as it relates to the claim for willful infringement.