DCT
1:24-cv-11033
Meepo Trading Ltd v. Core Home Fitness LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Meepo Trading Limited, et al. (China)
- Defendant: Core Home Fitness, L.L.C. (Nevada)
- Plaintiff’s Counsel: Venture Partner, LLC
- Case Identification: 1:24-cv-11033, N.D. Ill., 10/28/2024
- Venue Allegations: Plaintiffs allege venue is proper because Defendant targets Illinois consumers through interactive e-commerce websites, ships products to the state, and has caused substantial injury to Plaintiffs within Illinois.
- Core Dispute: Plaintiffs, a group of adjustable dumbbell sellers, seek a declaratory judgment that their products do not infringe Defendant's patent and that the patent is invalid, following Defendant's infringement complaints to Amazon.com that resulted in the delisting of Plaintiffs' products.
- Technical Context: The technology relates to adjustable dumbbells, which allow users to change weight resistance via a mechanical selection system rather than by manually adding or removing separate weight plates.
- Key Procedural History: The dispute arises from Defendant's infringement reports filed with Amazon.com between June and September 2024, which caused Plaintiffs' products to be removed from the platform. The complaint states that Plaintiffs provided Defendant with non-infringement opinions from U.S. patent counsel, which were allegedly ignored. The patent-in-suit is a continuation of an earlier application that issued as U.S. Patent No. 7,291,098.
Case Timeline
| Date | Event |
|---|---|
| 2005-05-03 | U.S. Patent No. 7,614,983 Priority Date |
| 2007-11-06 | U.S. Patent No. 7,291,098 (Parent Patent) Issue Date |
| 2009-11-10 | U.S. Patent No. 7,614,983 Issue Date |
| 2024-06-01 | Defendant's infringement reports to Amazon.com begin |
| 2024-10-28 | Complaint for Declaratory Judgment Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,614,983 - "Apparatus for Adjusting Weight Resistance to Exercise"
The Invention Explained
- Problem Addressed: The patent background acknowledges prior art in adjustable weight devices but notes that "room for continued improvement remains with respect to selecting different combinations of weight for use on exercise dumbbells" (’983 Patent, col. 1:29-34).
- The Patented Solution: The invention is an adjustable dumbbell system where a user can change the total weight by rotating a selector mechanism on the handle. This "weight selector" is a plate that rotates into and out of engagement with "upwardly closed notches" in one or more weight plates, thereby securing the desired plates to the handle for lifting (’983 Patent, Abstract; col. 5:4-14). The key concept is a single selector element that moves between positions to engage different adjacent weights.
- Technical Importance: This design provides a method for quickly adjusting the resistance of a dumbbell without the need to manually handle or secure individual weight plates, a key feature for compact home exercise equipment.
Key Claims at a Glance
- The complaint seeks a declaratory judgment of non-infringement as to independent claims 1, 9, and 11 (Compl. ¶20).
- Independent Claim 1:
- a liftable member having at least one weight supporting section;
- weights sized and configured to be supported by the at least one weight supporting section;
- a weight selector rotatably mounted on the liftable member for rotation about an axis extending lengthwise between adjacent said weights,
- wherein the weight selector is configured for rotation through a cavity defined between adjacent said weights.
- Independent Claim 9:
- a weight lifting member having at least one weight supporting section;
- weights with notches that cooperate to define a cavity having upwardly open and closed sectors; and
- a weight selector rotatably mounted for rotation inside the cavity, including a plate with a "generally semi-circular shape when viewed axially."
- Independent Claim 11:
- a weight lifting member and weights with notches cooperating to define a cavity with open and closed sectors; and
- a weight selector rotatable inside the cavity "between a first orientation underlying only one of the weights, and a second orientation underlying only another of the weights."
- The complaint argues that dependent claims 2-8 and 10 are not infringed because their respective independent claims are not infringed (Compl. ¶35, ¶40).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are various models of adjustable dumbbells sold by the Plaintiffs on Amazon.com, including those marketed under the "KEPPI" brand (Compl. ¶9, ¶14).
Functionality and Market Context
- The Plaintiffs' products are described as adjustable dumbbells featuring a rotatable handle. This handle connects to "hanging assemblies" on each end, which contain a series of "lock discs" (Compl. ¶28). The complaint provides an image of one of the accused products, showing the dumbbell with its weight plates and cradle (Compl. ¶14, p. 7).
- Each lock disc is configured to engage and lock a single corresponding dumbbell plate (Compl. ¶30). Rotating the handle causes the lock discs to engage or disengage their respective plates, thereby setting the desired weight (Compl. ¶28). An annotated image in the complaint illustrates that the quantity of lock discs corresponds to the quantity of dumbbell plates (Compl. ¶16, "Pictures 1-4").
- The complaint alleges the products were "popular due to their distinguished design and reasonable prices" prior to being delisted from Amazon.com (Compl. ¶14).
IV. Analysis of Infringement Allegations
'983 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a liftable member having at least one weight supporting section; | The accused products include a rotatable handle that functions as a liftable member (Compl. ¶28). | ¶28 | col. 2:40-42 |
| weights sized and configured to be supported by the at least one weight supporting section; | The accused products include a plurality of dumbbell plates on each side of the handle (Compl. ¶28). | ¶28 | col. 4:37-40 |
| a weight selector rotatably mounted on the liftable member for rotation about an axis extending lengthwise between adjacent said weights, | Plaintiffs allege their products do not have a "weight selector." Instead, they use multiple "lock discs," where each disc is dedicated to a single dumbbell plate and does not rotate between adjacent weights to select one of them (Compl. ¶30). The complaint includes a visual indicating the lock discs' axis of rotation is perpendicular to the dumbbell plate's lengthwise direction (Compl. ¶16). | ¶30, ¶31 | col. 2:50-54 |
| wherein the weight selector is configured for rotation through a cavity defined between adjacent said weights. | Plaintiffs allege their products lack a cavity defined between adjacent weights. Instead, each lock disc inserts into an "insertion port" located on a single dumbbell plate, not a space formed by the cooperation of two or more plates (Compl. ¶32). A visual of this single-plate insertion port is provided (Compl. ¶17, "Picture 5"). | ¶32 | col. 4:59-62 |
- Identified Points of Contention:
- Scope Questions: The dispute centers on whether the term "weight selector" can be construed to read on the accused products' system of multiple, dedicated "lock discs." A related question is whether the claimed "cavity defined between adjacent said weights" can encompass the "insertion port" located on a single dumbbell plate in the accused products.
- Technical Questions: A key factual question will be whether the accused products' selection mechanism operates as claimed. The complaint argues a fundamental mismatch: the patent claims rotation of a selector between weights on a lengthwise axis, whereas the accused products allegedly use dedicated discs that rotate on a perpendicular axis to engage a single plate (Compl. ¶31).
V. Key Claim Terms for Construction
The Term: "weight selector"
- Context and Importance: This term is central to the non-infringement dispute. Plaintiffs' core argument is that their system of multiple "lock discs," each dedicated to a single weight, is structurally and functionally different from the claimed "weight selector" (Compl. ¶30). Practitioners may focus on this term because its construction could be dispositive of infringement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The Summary of the Invention describes the selector functionally as a component "rotatably mounted on the handle member for rotation into different sectors of a cylindrical cavity defined by aligned notches in the first weights" (’983 Patent, col. 2:50-54). This less-specific language could support a broader functional definition.
- Evidence for a Narrower Interpretation: The detailed description and figures consistently depict the "weight selector" as a single "selector plate 166" that is shared among and rotates between different weight plates (180, 190) to select them for lifting (’983 Patent, col. 5:4-14; Fig. 6). This may support a narrower construction limited to a single, shared selection component.
The Term: "cavity defined between adjacent said weights"
- Context and Importance: Plaintiffs argue their products do not meet this limitation because their lock discs engage an "insertion port" on a single weight plate, not a cavity formed between two (Compl. ¶32). The interpretation of "between adjacent said weights" will be critical.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term "cavity" itself is not explicitly defined, which might allow for arguments that any receiving space, like the accused "insertion port," qualifies.
- Evidence for a Narrower Interpretation: The specification states, "The plates 180 and 190 are arranged with their respective notches opening toward one another in a manner that defines a cylindrical cavity" (’983 Patent, col. 4:59-62). This language strongly suggests that the claimed "cavity" must be formed by the cooperation of at least two adjacent weights, not a feature on a single weight.
VI. Other Allegations
- Indirect Infringement: The complaint seeks a declaration that Plaintiffs' customers do not infringe, which anticipates a potential future claim of induced or contributory infringement by the Defendant (Compl., p. 26, Prayer for Relief ¶b). However, the complaint does not provide specific factual allegations to preemptively counter a theory of indirect infringement.
- Willful Infringement: The complaint alleges that Defendant's actions in filing "fraudulent and malicious" reports with Amazon.com justify finding the case exceptional under 35 U.S.C. § 285 (Compl. ¶54; Prayer for Relief ¶e). This is an allegation of litigation misconduct against the patentee, not a claim for willful infringement of the patent.
VII. Analyst’s Conclusion: Key Questions for the Case
A core issue will be one of definitional scope: can the claim term "weight selector," described in the patent's embodiment as a single component rotating to engage one of several adjacent weights, be construed to cover the accused products' system of multiple, dedicated "lock discs," where each disc is permanently associated with only one weight plate?
A key question of technical operation will be whether the accused mechanism is fundamentally different from what is claimed. The case may turn on evidence demonstrating whether the accused lock discs rotate "through a cavity defined between adjacent said weights," as required by the claim, or if they operate via a distinct mechanism of engaging an insertion port on a single, non-adjacent plate.