DCT
1:25-cv-00870
Zhejiang Qili Health Technology Co Ltd v. Core Home Fitness LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Zhejiang Qili Health Technology Co., Ltd. (China)
- Defendant: Core Home Fitness, L.L.C. (Nevada)
- Plaintiff’s Counsel: Venture Partner, LLC
- Case Identification: 1:25-cv-00870, N.D. Ill., 01/25/2025
- Venue Allegations: Venue is based on Defendant's operation of interactive e-commerce stores that target and ship products to consumers in Illinois, allegedly causing substantial injury to the Plaintiff within the state.
- Core Dispute: Plaintiff seeks a declaratory judgment that its adjustable dumbbell products do not infringe Defendant's patent and that the patent is invalid, following Defendant’s patent infringement reports to e-commerce platforms that resulted in the delisting of Plaintiff's products.
- Technical Context: The dispute centers on the mechanical design of adjustable dumbbells, which allow users to select varying amounts of weight for exercise using a single piece of equipment.
- Key Procedural History: The action was precipitated by Defendant's infringement reports filed with Amazon, eBay, and Walmart against Plaintiff's products. Plaintiff alleges it provided Defendant with a formal non-infringement opinion from U.S. patent counsel, which was allegedly ignored. The patent-in-suit is subject to a terminal disclaimer and is a continuation of an earlier application that issued as U.S. Patent No. 7,291,098.
Case Timeline
| Date | Event |
|---|---|
| 2005-05-03 | '983 Patent Priority Date (Provisional App. 60/677,150) |
| 2009-11-10 | '983 Patent Issued |
| 2025-01-25 | 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," issued November 10, 2009
The Invention Explained
- Problem Addressed: The patent background identifies a need for continued improvement in the field of adjustable weight lifting equipment with respect to the mechanisms for selecting different combinations of weight plates ('983 Patent, col. 1:27-31).
- The Patented Solution: The invention describes an adjustable dumbbell system where a "weight selector" is mounted on the handle for rotation. This selector rotates about an axis that runs parallel to the handle and is located in the space between adjacent weight plates. By rotating the selector, it moves through specially designed notches, or a "cavity," in the weight plates to engage or disengage them, thereby adjusting the total weight to be lifted ('983 Patent, Abstract; col. 2:30-35). Figure 1 of the patent illustrates the overall system, showing the handle member (110) with weight plates (180, 190) at each end ('983 Patent, Fig. 1).
- Technical Importance: The design provides a specific rotational mechanism for weight selection where the engaging element moves through a cavity defined between weights, distinct from other adjustment methods.
Key Claims at a Glance
- The complaint identifies independent claims 1, 9, and 11 as relevant to the dispute (Compl. ¶20).
- Independent Claim 1 requires:
- 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.
- The complaint notes that dependent claims 2-8, and 10 are also at issue, contingent on the scope of their respective independent claims (Compl. ¶¶36, 48, 54).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are Plaintiff’s adjustable dumbbells, referred to as "Product 1" and "Product 2" (Compl. ¶¶14, 30, 37). The complaint provides a list of specific product identifiers from Amazon, eBay, and Walmart (Compl. ¶9).
Functionality and Market Context
- The complaint alleges that Plaintiff's products feature distinct weight selection mechanisms. In "Product 1," rotating the handle drives sliders that move telescopically to engage central holes in the weight plates (Compl. ¶30). An annotated diagram from Plaintiff's own patent illustrates this slider mechanism for telescopic movement. (Compl. p. 9, Fig. 3 of U.S. Pat. No. 11,167,167). In "Product 2," rotating the handle causes a limiting member to translate, which in turn inserts a protrusion into clamping slots on the weight plates (Compl. ¶37). The complaint provides an exploded diagram showing how the rotating member drives a protrusion to engage the weight plate. (Compl. p. 10).
- Plaintiff alleges its products were popular due to their design and price, positioning them as significant competitors to Defendant’s products before being delisted (Compl. ¶14).
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement. The analysis below summarizes Plaintiff's arguments for why its products do not meet the limitations of Claim 1 of the '983 Patent.
'983 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality (Plaintiff's Position) | Complaint Citation | Patent Citation |
|---|---|---|---|
| a weight selector rotatably mounted on the liftable member | Plaintiff's products do not have a "weight selector" separate from the handle. Instead, the handle itself rotates to drive a different component (a telescoping slider in Product 1; a translating protrusion in Product 2) that engages the weights. This engagement is through linear motion, not rotation of the selector itself (Compl. ¶¶32, 39). | ¶¶32, 39 | col. 1:46-52 |
| for rotation about an axis extending lengthwise between adjacent said weights | The axis of rotation for Plaintiff's handle is alleged to extend through the central hole of the dumbbell plates, not in the space "between adjacent said weights" as required by the claim and as depicted in the patent's figures (Compl. ¶28). The complaint includes an annotated version of the patent's Figure 1 to emphasize this distinction. (Compl. p. 15). | ¶¶33, 40 | col. 6:49-54 |
| wherein the weight selector is configured for rotation through a cavity defined between adjacent said weights | Plaintiff's products are alleged to lack a "cavity defined between adjacent said weights." Product 1 uses a slider that moves through a central fixing hole in each plate. Product 2 uses protrusions that insert into clamping holes in each plate. Neither involves a selector rotating through a cavity formed between plates (Compl. ¶¶35, 42). | ¶¶35, 42 | col. 6:55-60 |
- Identified Points of Contention:
- Technical Questions: A primary factual dispute will concern the mechanism of action. Does the rotation of Plaintiff's handle, which causes a separate part to translate or telescope, constitute a "rotatably mounted" weight selector? Or is this a fundamentally different mechanical operation from the rotating semi-circular plate (166) described in the '983 Patent? ('983 Patent, Fig. 6).
- Scope Questions: The case raises a significant claim construction question regarding the required location of the rotational axis. The resolution may depend on whether "between adjacent said weights" is interpreted strictly to mean the physical space separating two weight plates, as Plaintiff argues, or if it can be construed more broadly to cover an axis that passes through the weights along the handle's length.
V. Key Claim Terms for Construction
The Term: "a weight selector rotatably mounted...for rotation about an axis extending lengthwise between adjacent said weights"
- Context and Importance: This composite phrase is the crux of the non-infringement argument. Its construction will determine whether Plaintiff's mechanism—where a rotating handle causes linear motion in a separate part—falls within the claim scope. Practitioners may focus on this term because Plaintiff's non-infringement theory rests almost entirely on a narrow interpretation of both the "weight selector" element and its spatial relationship to the weights.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that any component system initiated by rotation of a part on the handle to select weights meets the general purpose of a "weight selector." The term is not explicitly defined, potentially allowing for a functional interpretation.
- Evidence for a Narrower Interpretation: The specification consistently describes and illustrates a specific embodiment where a semi-circular selector plate (166) itself rotates on a shaft (165) ('983 Patent, col. 4:38-48, Fig. 6). Furthermore, Figure 1, which the complaint reproduces and annotates, explicitly depicts the rotational "Axis" in the physical space between weight plates 180 and 190, supporting a spatially limited interpretation (Compl. p. 15; '983 Patent, Fig. 1).
The Term: "a cavity defined between adjacent said weights"
- Context and Importance: This term defines the space through which the selector must operate. Plaintiff's products allegedly use holes within each plate, not a cavity between them. The interpretation of "cavity" and its location is therefore critical.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue that any opening that allows the selector to function could be considered a "cavity," regardless of whether it is formed by the interaction of two plates or exists within one.
- Evidence for a Narrower Interpretation: The patent states that the plates are arranged with "notches opening toward one another in a manner that defines a cylindrical cavity" ('983 Patent, col. 4:60-62). This language suggests the "cavity" is a composite structure created by the alignment of multiple weights, not an aperture within a single weight. Figures 8 and 9 show how notches (183, 184, 193, 194) in the weights (180, 190) cooperate to form this cavity (Compl. pp. 17-18).
VI. Other Allegations
- Indirect Infringement: The complaint seeks a declaration of non-infringement under all subsections of 35 U.S.C. § 271, which would include indirect infringement (Compl. p. 29, ¶a). However, the complaint does not provide specific facts regarding any potential theories of induced or contributory infringement asserted by the Defendant.
- Willful Infringement: The complaint does not allege willful infringement by the Plaintiff. Instead, it alleges that the Defendant's conduct was "fraudulent," "malicious," and "willful" in filing infringement reports with e-commerce platforms and ignoring Plaintiff's non-infringement opinion (Compl. ¶¶18, 61-63). This allegation forms the basis for Plaintiff's request that the case be adjudged "exceptional" under 35 U.S.C. § 285, which could lead to an award of attorneys' fees (Compl. p. 29, ¶e).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction and technical operation: Can the '983 Patent's "weight selector," which is described and shown as a single rotating plate, be construed to read on Plaintiff's two-part system where a rotating handle causes a separate component to engage weights via linear (telescoping or translating) motion?
- A second key issue will be one of spatial definition: Does the claim phrase "axis extending lengthwise between adjacent said weights" require the rotational axis to be located in the physical gap separating the weight plates, as the patent figures suggest, or can it be read more broadly to cover an axis passing through the centers of the weights themselves?
- A significant parallel question concerns Defendant's pre-suit conduct: Did Defendant's filing of infringement reports with e-commerce platforms, particularly after allegedly receiving Plaintiff's non-infringement opinion, constitute improper conduct sufficient to render the case "exceptional" under 35 U.S.C. § 285?