DCT
1:23-cv-01390
Coulter Ventures LLC v. Bells Of Steel USA Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Coulter Ventures, LLC, d/b/a Rogue Fitness (Ohio)
- Defendant: Bells of Steel USA Inc. (Nevada); Bells of Steel Inc. (Canada)
- Plaintiff’s Counsel: Lewis Wagner, LLP; Banner & Witcoff, Ltd.
- Case Identification: 1:23-cv-01390, S.D. Ind., 08/08/2023
- Venue Allegations: Venue is alleged to be proper in the Southern District of Indiana because Defendant Bells of Steel USA Inc. maintains a "regular and established place of business" in the district, specifically an "Indianapolis Showroom" and warehouse, and has allegedly committed acts of infringement there. Venue over the Canadian parent company, Bells of Steel Inc., is asserted on the basis that it is a foreign entity and may be sued in any judicial district.
- Core Dispute: Plaintiff alleges that Defendant’s line of "Hydra" weightlifting equipment, including lever arms, folding power racks, weight plates, and barbells, infringes five of its utility and design patents.
- Technical Context: The lawsuit concerns the competitive market for high-performance strength and fitness equipment, where innovation often focuses on versatility, space efficiency for home gyms, and distinct product aesthetics.
- Key Procedural History: The complaint alleges that Defendants intentionally copied Plaintiff's product designs, citing public statements by the Defendant's founder that suggest a business model of selling less-expensive versions of competitors' products and a challenge to "enforce your IP and get a patent on it." The complaint also notes that Plaintiff provides notice to the public of its patent rights via a virtual marking website.
Case Timeline
| Date | Event |
|---|---|
| 2014-10-06 | D'’513 Patent Priority Date |
| 2017-11-02 | '’661 Patent Priority Date |
| 2018-06-05 | D'’063 Patent Priority Date |
| 2018-10-25 | '’337 Patent Priority Date |
| 2019-03-12 | '661 Patent Issue Date |
| 2019 | Defendant's US Expansion |
| 2020-07-28 | D'’020 Patent Priority Date |
| 2021-11-16 | '337 Patent Issue Date |
| 2022-08-16 | D'020 Patent Issue Date |
| 2023-05-02 | D'513 Patent (Reissue) Issue Date |
| 2023-07-11 | D'063 Patent Issue Date |
| 2023-08-08 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,173,337 - "Weightlifting Assembly and Weight Rack Including Weightlifting Assembly," Issued November 16, 2021
The Invention Explained
- Problem Addressed: The patent describes weight racks used for various exercises and notes that additional structures can be coupled to them, implying a need for versatile and adjustable attachment systems for such accessories (’337 Patent, col. 1:33-39).
- The Patented Solution: The invention is an adjustable carriage assembly designed to move vertically along a structural frame member of a weight rack. The assembly uses rollers to slide along the frame and features a locking structure, such as a retractable pin, to securely fix the carriage at various heights, allowing accessories like lever arms to be quickly repositioned. (’337 Patent, Abstract; col. 2:49-59).
- Technical Importance: This technology allows for the rapid vertical adjustment and secure locking of heavy-duty accessories on standard power racks, which increases the functional versatility of a single piece of equipment. (’337 Patent, col. 1:49-60).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶28).
- Independent claim 1 requires, in part:
- An adjustable carriage assembly comprising a carriage with a passage to receive a frame member.
- At least one handle mount connected to the carriage.
- A first handle and a second handle connected to the handle mount.
- A lock structure for engaging the frame member to fix the carriage in position, which includes a movable pin.
- The complaint reserves the right to assert additional claims (Compl. ¶30).
U.S. Patent No. 10,226,661 - "Weightlifting Rack Assembly and Wall Mount Bracket for a Weightlifting Rack Assembly," Issued March 12, 2019
The Invention Explained
- Problem Addressed: The patent background identifies the growing trend of home gyms in multi-use spaces like garages, where bulky, traditional weightlifting racks are impractical. While foldable racks exist, securely mounting them to wall studs can be challenging, especially with non-standard stud spacing, and can increase the rack's footprint. (’661 Patent, col. 1:21-48).
- The Patented Solution: The patent discloses a foldable, wall-mountable weightlifting rack system. The core of the solution lies in specialized upper and lower wall mount brackets that feature an offset, multi-panel design. This design allows the brackets to span between and securely fasten to vertical wall studs while providing the necessary clearance and pivot points for the rack's side assemblies to fold compactly against the wall. (’661 Patent, Abstract; col. 2:1-20).
- Technical Importance: The invention provides a robust, space-saving power rack solution for home gyms by enabling a secure installation that accommodates variable wall stud spacing and allows the rack to fold nearly flat against the wall. (’661 Patent, col. 1:29-37).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶37).
- Independent claim 1, as corrected by a Certificate of Correction, requires, in part:
- A first wall mount bracket with a specific geometry including a central panel, top and bottom wall mount panels, and angled offset panels.
- A second wall mount bracket located below the first.
- A foldable weightlifting rack assembly connected to the brackets via first, second, third, and fourth pivot brackets.
- The rack assembly includes a first side rack assembly and a second side rack assembly, each being foldable by pivoting at their respective pivot brackets.
- The complaint reserves the right to assert additional claims (Compl. ¶39).
Multi-Patent Capsule: U.S. Design Patent No. D992,063
- Patent Identification: D992,063, "Wall Mounted Exercise Rack," Issued July 11, 2023.
- Technology Synopsis: This patent protects the specific ornamental, non-functional, visual appearance of a wall-mounted exercise rack. The protected design encompasses the overall configuration, proportions, and surface details of the rack's components.
- Asserted Claims: The single claim of the D'063 patent (Compl. ¶46).
- Accused Features: The overall design of the "Hydra 3 X 3 Inch Wall Mounted Power Rack" is accused of being substantially the same as the patented design (Compl. ¶¶21, 47).
Multi-Patent Capsule: U.S. Design Patent No. D961,020
- Patent Identification: D961,020, "Weight Plate," Issued August 16, 2022.
- Technology Synopsis: This patent protects the ornamental design of a weight plate. The design is characterized by its "deep dish" profile, the configuration of its spokes, and the particular aesthetic of the lettering and markings on its face.
- Asserted Claims: The single claim of the D'020 patent (Compl. ¶54).
- Accused Features: The overall appearance of the "45lb 'Deep Dish Plate'" is alleged to be substantially the same as the patented design (Compl. ¶¶22, 55).
Multi-Patent Capsule: U.S. Design Patent Reissue No. RE49,513
- Patent Identification: RE49,513, "Barbell," Issued May 2, 2023.
- Technology Synopsis: This reissue patent protects the ornamental design for a barbell, focusing on the visual appearance of the barbell's sleeves. The protected features include the specific pattern, placement, and configuration of grooves and rings on the sleeves.
- Asserted Claims: The single claim of the D'513 patent (Compl. ¶62).
- Accused Features: The overall design of the "Women's Barbell 2.0 – Olympic Weightlifting" barbell is alleged to be substantially the same as the patented design (Compl. ¶¶23, 63).
III. The Accused Instrumentality
- Product Identification: The complaint targets a range of Defendant's "Hydra" brand fitness equipment, including the "Hydra Sliding Lever Arms," various folding power and half racks (collectively, the "Infringing Folding Racks"), the "Hydra 3 X 3 Inch Wall Mounted Power Rack," the "45lb 'Deep Dish Plate'," and the "Women's Barbell 2.0 – Olympic Weightlifting" barbell (Compl. ¶¶19-23).
- Functionality and Market Context: The accused products constitute a system of interoperable strength training equipment. The "Hydra Sliding Lever Arms" are adjustable attachments for power racks that facilitate various pressing and pulling movements (Compl. ¶19, Table 1). The "Infringing Folding Racks" are space-saving, wall-mounted squat racks intended for home or commercial gym use (Compl. ¶20, Table 2). The complaint alleges these products directly compete with Plaintiff's own offerings and were designed by copying Plaintiff's products (Compl. ¶24). The complaint provides a side-by-side visual comparison showing the accused "Hydra Sliding Lever Arms" next to an excerpt from the '337 Patent to illustrate the alleged similarity (Compl. ¶24, Table 6, p. 11).
IV. Analysis of Infringement Allegations
'337 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| An adjustable carriage assembly comprising a carriage defining a passage configured to receive a frame member therethrough such that the carriage is movable along the frame member... | The body of the "Hydra Sliding Lever Arms" product allegedly forms a carriage with a passage that slides vertically on a power rack upright. | ¶19; ¶29; Table 6 (p. 11) | col. 39:40-45 |
| at least one handle mount connected to the carriage and extending outward from the carriage... | The lever arm itself allegedly serves as the handle mount, extending outward from the sliding carriage. | ¶19; ¶29; Table 1 | col. 39:46-48 |
| a first handle connected to and supported by the at least one handle mount... and a second handle connected to and supported by the at least one handle mount... | The accused product features D-shaped grips at the end of the lever arms for the user to hold. | ¶19; ¶29; Table 1 | col. 40:1-6 |
| a lock structure configured for engaging the frame member... comprising a pin... that is movable by an axial translation... | The accused product’s mechanism for attaching to the rack upright is alleged to function as the claimed lock structure. | ¶19; ¶29; Table 6 (p. 11) | col. 40:7-14 |
Identified Points of Contention
- Technical Questions: A primary question will be whether the mechanism that secures the accused "Hydra Sliding Lever Arms" to a rack upright meets all the specific structural and functional limitations of the "lock structure" as recited in claim 1. The analysis may focus on the precise nature of the "pin" and whether its movement constitutes "axial translation" as understood in the context of the patent.
- Scope Questions: The case may explore the scope of the term "handle," questioning whether the accused product's D-grips are distinct from the "handle mount" (the lever arm) in the manner required by the claim language.
'661 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first wall mount bracket configured for mounting to a wall surface, comprising: a first central panel..., a first top wall mount panel..., a first bottom wall mount panel..., first offset panels... angled to each of the first central panel and the first top and bottom wall mount panels... | The accused "Infringing Folding Racks" allegedly include upper and lower wall mounting components with the specific offset and angled geometry claimed. The side-by-side image of a component from the accused rack is presented as evidence. | ¶20; ¶38; Table 6 (p. 13, 15) | col. 15:39-16:2 |
| a second wall mount bracket... | The accused racks allegedly include a second, lower wall mount bracket as part of the system. | ¶20; ¶38; Table 2 | col. 17:5-24 |
| a weightlifting rack assembly... foldable and comprises a first side rack assembly... and a second side rack assembly... foldable by pivoting at the first and third brackets, and the second side rack assembly is foldable by pivoting at the second and fourth brackets. | The accused "Infringing Folding Racks" allegedly comprise two side assemblies that connect to the wall brackets via pivots and are capable of folding. The complaint provides a visual comparison of the accused rack in a folded position next to Plaintiff's product. | ¶20; ¶38; Table 6 (p. 14) | col. 17:60-18:4 |
Identified Points of Contention
- Technical Questions: The infringement analysis will likely center on the precise geometry of the accused racks' wall mounting hardware. A key question is whether the brackets on the Bells of Steel products possess "offset panels" that are "angled" relative to the central and top/bottom panels in the specific manner described and claimed in the '661 Patent.
- Scope Questions: Practitioners may examine whether the term "pivot brackets" as used in the claim reads on the hinge mechanisms of the accused products. The defense could argue for a narrow construction of this term based on the specific embodiments shown in the patent's figures.
V. Key Claim Terms for Construction
For the '337 Patent:
- The Term: "lock structure"
- Context and Importance: This term is critical because the mechanism for securing the carriage to the rack is a core functional aspect of the invention. The infringement dispute may turn on whether the accused product's attachment mechanism, which appears to be a form of pin, is encompassed by the full definition of the "lock structure" in the patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent summary describes the element functionally as "a lock structure configured for engaging the frame member" (’337 Patent, col. 2:57-59), which could support a construction covering any mechanism that performs this function.
- Evidence for a Narrower Interpretation: The detailed description and figures illustrate a specific embodiment of the lock structure that includes a collar, a biasing member (spring), and a pin that moves via axial translation (’337 Patent, col. 17:59-18:21; Fig. 8-10). This detailed depiction could be used to argue that the term should be limited to structures with these specific components.
For the '661 Patent:
- The Term: "offset panels... being respectively angled to each of the first central panel and the first top and bottom wall mount panels"
- Context and Importance: This term defines the specific three-dimensional shape of the wall mount bracket, which the patent presents as a key feature for enabling a secure and versatile installation. The infringement question for the '661 patent will likely depend heavily on whether the accused product's brackets have this specific "angled" or "oblique" geometry.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim uses the general term "angled," which could be argued to cover any non-parallel, non-perpendicular relationship between the panels.
- Evidence for a Narrower Interpretation: Figure 7 of the patent shows a specific cross-sectional profile where the offset panels create a distinct trapezoidal shape (’661 Patent, Fig. 7). The abstract and summary also use the term "oblique" (’661 Patent, col. 2:37-41), which a party might argue imparts a more specific angular requirement than just "angled."
VI. Other Allegations
- Indirect Infringement: While the formal counts are for infringement under 35 U.S.C. § 271 generally, the factual allegations primarily focus on direct infringement by making, using, and selling the accused products. However, the complaint alleges that Defendants sell these products to customers in the United States (Compl. ¶6), which could form the basis for later claims of induced infringement, as Defendants are providing the means (the infringing products) for customers to assemble and use the patented inventions.
- Willful Infringement: The complaint makes strong allegations of willful infringement. It claims Defendants had knowledge of Plaintiff's patents through at least constructive notice via a virtual marking website (Compl. ¶17). More significantly, it alleges a deliberate "cavalier business model" of copying, supported by purported statements from the Defendant's founder challenging patent holders to "enforce your IP" and acknowledgments from third-party reviewers that the products appear to be copies (Compl. ¶¶24-26). These allegations suggest pre-suit knowledge and an objective likelihood of infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A key evidentiary question will be one of intent and willfulness: What weight will be given to the alleged public statements by the Defendant's founder and third-party product reviewers, which Plaintiff presents as evidence of a deliberate strategy to copy products and disregard intellectual property rights until challenged?
- For the utility patents, a core issue will be one of claim scope versus technical implementation: Does the accused folding rack's wall-mount hardware embody the specific "angled offset panel" geometry required by the '661 patent, and does the accused lever arm's locking pin meet all structural and functional limitations of the "lock structure" claimed in the '337 patent?
- For the design patents, the central question will be the application of the ordinary observer test: Factoring in the prior art, would an ordinary consumer be deceived into believing Defendant's accused racks, weight plates, and barbells are Plaintiff's products based on the substantial similarity of their overall ornamental appearance?