DCT
4:25-cv-00286
Bruno Intellectual Reserve LLC v. Meepo Trading Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Bruno Intellectual Reserve LLC (Nevada)
- Defendant: MEEPO TRADING LIMITED, et al. (China)
- Plaintiff’s Counsel: Roetzel & Andress LPA
- Case Identification: 4:25-cv-00286, N.D. Ohio, 02/13/2025
- Venue Allegations: Venue is alleged to be proper because Defendants are aliens not resident in the United States, and are therefore subject to suit in any judicial district.
- Core Dispute: Plaintiff alleges that numerous foreign entities are selling adjustable dumbbells on e-commerce platforms that infringe a U.S. patent related to a mechanism for selecting weight plates.
- Technical Context: The technology concerns adjustable dumbbells, a segment of the home fitness market where a single dumbbell can be quickly adjusted to various weights, saving space and cost compared to a full rack of fixed-weight dumbbells.
- Key Procedural History: The complaint alleges that Plaintiff previously prevailed in an Amazon Patent Evaluation Express (APEX) proceeding, where a neutral evaluator found that products similar to those sold by the Defendants were "likely able to prove" infringement of the patent-in-suit. Plaintiff asserts this proceeding provides a basis for Defendants' knowledge of the patent.
Case Timeline
| Date | Event |
|---|---|
| 2005-05-03 | Priority Date for U.S. Patent No. 7,614,983 |
| 2009-11-10 | Issue Date for U.S. Patent No. 7,614,983 |
| 2025-02-13 | Complaint Filing Date |
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 section suggests a continuing need for improvement in the field of adjustable weight exercise devices, specifically regarding methods for selecting different combinations of weights on a dumbbell (’983 Patent, col. 1:30-34).
- The Patented Solution: The invention describes an exercise dumbbell with a handle and weight plates at each end. A rotatable "weight selector" is mounted on the handle and passes through a cavity formed by aligned notches in the stacked weight plates. By rotating the selector (e.g., via a knob), the user can engage or disengage different weight plates, thereby changing the total liftable mass without manually removing or adding the plates (’983 Patent, Abstract; col. 2:47-59).
- Technical Importance: This mechanism provides a means for rapid and convenient weight adjustment, a key feature for the consumer-grade fitness equipment market where space and ease of use are significant factors (’983 Patent, col. 1:20-34).
Key Claims at a Glance
- The complaint asserts independent claims 1, 9, and 11 (Compl. ¶¶101-103).
- 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 sized and configured to be supported by the at least one weight supporting section, wherein notches in the weights cooperate to define a cavity having upwardly open sectors and upwardly closed sectors; and
- a weight selector rotatably mounted on the weight lifting member for rotation inside the cavity, wherein the weight selector defines a rotational axis, and includes a plate having a generally semi-circular shape when viewed axially.
- Independent Claim 11:
- a weight lifting member having at least one weight supporting section;
- weights sized and configured to be supported by the at least one weight supporting section, wherein notches in the weights cooperate to define a cavity having upwardly open sectors and upwardly closed sectors; and
- a weight selector, rotatably mounted on the weight lifting member for rotation inside the cavity, wherein the weight selector is rotatable between a first orientation underlying only one of the weights, and a second orientation underlying only another of the weights.
- The complaint also states an intent to assert dependent claims 2-8 and 10 (Compl. ¶¶108, 111).
III. The Accused Instrumentality
Product Identification
The Accused Products are adjustable dumbbells sold by the numerous defendants through e-commerce storefronts on platforms including Amazon.com, Walmart.com, and eBay.com (Compl. ¶¶2, 6, 54). The complaint identifies specific products via Amazon Standard Identification Numbers (ASINs) and other item numbers (Compl. ¶13).
Functionality and Market Context
The complaint describes the Accused Products as "adjustable dumbbell[s]" that infringe the ’983 Patent (Compl. ¶101). It characterizes them as "foreign knockoffs" and "counterfeit goods" that compete directly with Plaintiff's products and are sold through a "systematic approach of establishing online storefronts" (Compl. ¶¶46, 64, 81). Table 1 in the complaint lists numerous defendants, their associated online store names, and the identification numbers for the accused adjustable dumbbell products (Compl. ¶13).
IV. Analysis of Infringement Allegations
The complaint alleges that the Accused Products contain every element of the asserted claims but does not provide a detailed, element-by-element mapping of specific product features to claim limitations (Compl. ¶¶105, 109, 112). The following chart summarizes the infringement theory for Claim 1 based on the complaint's broad assertions.
’983 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a liftable member having at least one weight supporting section | The dumbbell handle assembly, including the end portions that are configured to support the weight plates. | ¶101, ¶105 | col. 2:37-41 |
| weights sized and configured to be supported by the at least one weight supporting section | The individual weight plates that are part of the adjustable dumbbell set. | ¶101, ¶105 | col. 2:33-35 |
| 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 | A rotating mechanism, such as a dial or knob, that interacts with the weight plates to select the desired weight for lifting. | ¶101, ¶105 | col. 2:51-55 |
Identified Points of Contention
- Evidentiary Questions: The complaint makes sweeping allegations against a large number of products identified only by online listing numbers. A central question will be whether Plaintiff can produce sufficient evidence to demonstrate that each of the dozens of distinct Accused Products, sold by different foreign entities, actually practices every limitation of the asserted claims. The complaint's reliance on a prior APEX proceeding against "similar" products may not be dispositive for these specific Defendants and products (Compl. ¶53).
- Technical Questions: For Claim 9, a technical question may arise as to whether the accused selectors have a "generally semi-circular shape when viewed axially" as required by the claim (’983 Patent, col. 8:17-18). The degree of similarity required to meet this limitation could be debated.
V. Key Claim Terms for Construction
"weight selector"
- Context and Importance: This term defines the core component of the claimed invention. Its construction will determine the range of accused mechanisms that fall within the patent's scope. Practitioners may focus on this term because its interpretation—whether it is limited to the specific embodiments shown or covers any functionally equivalent rotating mechanism—is central to the infringement analysis.
- Intrinsic Evidence for a Broader Interpretation: The patent abstract describes the component functionally as "Weight selectors... rotatable into and out of engagement with different combinations of the weight plates" (’983 Patent, Abstract). Claim 1 also uses broad, functional language, describing it as a component "rotatably mounted... for rotation through a cavity" (’983 Patent, col. 6:47-51).
- Intrinsic Evidence for a Narrower Interpretation: The detailed description discloses a specific embodiment: a "selector plate 166" made of steel with a "semi-circular portion 167" (’983 Patent, col. 4:38-49; Fig. 6). A party could argue the term should be construed more narrowly in light of these specific examples.
"cavity defined between adjacent said weights" (Claim 1)
- Context and Importance: This term defines the space through which the selector operates. Its scope is critical because if the accused products achieve weight selection without a structure that meets this definition, they may not infringe Claim 1.
- Intrinsic Evidence for a Broader Interpretation: The claim language itself is general and does not specify how the cavity is formed, suggesting it could be any space between weights that permits the selector's rotation.
- Intrinsic Evidence for a Narrower Interpretation: The Summary of the Invention describes "a cylindrical cavity defined by aligned notches in the first weights" (’983 Patent, col. 2:53-54). This language could be used to argue that the term requires the presence of specific, aligned notches, rather than just a general gap.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, asserting that Defendants encourage their customers to directly infringe by selling them the Accused Products for their intended use (Compl. ¶¶119-121). It also alleges contributory infringement, claiming the Accused Products are not staple articles of commerce with substantial non-infringing uses (Compl. ¶¶133-134).
- Willful Infringement: Willfulness is alleged based on Defendants acting "knowingly and intentionally or with reckless disregard or willful blindness" (Compl. ¶92). The complaint grounds this allegation in pre-suit knowledge, stemming from a prior APEX proceeding where similar products were found likely to infringe and subsequent requests to Amazon to remove similarly infringing products (Compl. ¶¶51-53).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of proof and procedure: Can the Plaintiff, facing dozens of foreign defendants identified primarily by online storefront names, obtain the discovery necessary to prove that each distinct accused product meets every limitation of the asserted claims? The precedential value of a prior APEX proceeding against different parties will likely be a significant point of contention.
- A key legal question will be one of claim scope: How will the term "weight selector" be construed? Will its meaning be limited to the specific plate-like embodiment detailed in the patent's specification, or will it be interpreted more broadly to cover any rotating mechanism that performs the claimed function, potentially capturing a wider variety of accused designs?
- A central factual question will be one of knowledge for willfulness: Does the complaint's reference to a prior APEX proceeding and general takedown requests constitute sufficient evidence of pre-suit knowledge for this large and disparate group of defendants, or will Plaintiff be required to establish specific knowledge for each defendant individually to sustain a claim for enhanced damages?