RampWerks, LLC v. absoluteBLACK

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: RampWerks, LLC (Texas)
  • Defendant: absoluteBLACK and PLAYTRI FRANCHISING, LLC (Slovenia/United Kingdom and Texas, respectively)
  • Plaintiff’s Counsel: CONNOR LEE AND SHUMAKER PLLC
• Case Identification: 2:23-cv-00236, E.D. Tex., 08/07/2023
• Venue Allegations: Venue is alleged to be proper for absoluteBLACK, a foreign corporation, under 28 U.S.C. § 1391(c)(3). For Playtri, a domestic corporation, venue is alleged to be proper under 28 U.S.C. § 1400(b) based on its commission of infringing acts and its regular and established place of business within the Eastern District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s specialty bicycle chainrings infringe three patents related to ramp structures designed to improve gear-shifting performance.
• Technical Context: The technology relates to high-performance bicycle components, specifically the mechanical design of chainrings to facilitate smoother and more reliable shifting, particularly when moving the chain to a larger gear ("up-shifting") under load.
• Key Procedural History: The complaint alleges that Plaintiff provided Defendants with pre-suit notice of infringement for all three asserted patents. No other procedural events, such as prior litigation or administrative challenges to the patents, are mentioned.

Case Timeline

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 describes the difficulty of "up-shifting"—moving a bicycle chain from a smaller to a larger chainring—under extreme loads, such as during racing or climbing, which can cause stress and wear on the chain and drivetrain components (’338 Patent, col. 1:47-52). Prior art solutions using pins to lift the chain were also identified as potentially problematic, as they could create concentrated stress points on the chain (’338 Patent, col. 2:28-39).
• The Patented Solution: The invention proposes a chainring with a plurality of specially designed "ramps" integrated into its inner surface (’338 Patent, col. 5:4-8). These ramps feature a "lifting surface" designed to engage a single chain link at two or more distinct points simultaneously, initiating a "stable lift" of the chain onto the larger ring without requiring initial engagement with the chainring's teeth (’338 Patent, Abstract; FIG. 1). This method of lifting is intended to distribute the shifting force more broadly across the chain link, improving performance and reliability.
• Technical Importance: This design purports to offer faster and more reliable up-shifting, particularly under high-torque conditions, while potentially reducing wear on the bicycle chain compared to conventional shifting mechanisms. (’338 Patent, col. 1:47-52).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶36).
• The essential elements of Claim 1 are:
  • A bicycle chain ring, comprising
  • an inner edge fully circumscribing both an opening and an axis of rotation;
  • an inner surface extending between the inner edge and an outer edge where a plurality of chain ring teeth emanate; and
  • 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 of a bicycle chain at two or more distinct pivot points along the length of the chain link to initiate stable lift of the bicycle chain without assistance from any of the plurality of chain ring teeth;
  • wherein the lifting surface has a first end proximate the inner edge and a second end proximate the outer edge.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 10,711,875 - "Bicycle Chain Rings" (Issued July 14, 2020)

The Invention Explained

• Problem Addressed: This patent, part of the same family, also addresses problems with conventional shifting, specifically identifying the "see saw action" that can occur when a single pin creates an "unstable lift point" on a chain link, a problem exacerbated by chain wear and high loads (’875 Patent, col. 3:41-55; FIG. 30B).
• The Patented Solution: The invention again utilizes ramps on the chainring's inner surface. The claims focus on lifting surfaces that are "perpendicularly disposed" about the inner surface and engage the chain at load points located "below bicycle chain link pins" (’875 Patent, Claim 8). This configuration is designed to apply lifting force directly under the chain's primary load-bearing structures (the pivots and rollers), providing a more direct and stable lift compared to prior art pins that engage the chain plate between these points (’875 Patent, FIG. 31C).
• Technical Importance: By targeting the lift points directly below the chain's pivots, the invention aims to create a more mechanically efficient and stable shift, further reducing the likelihood of slippage or excessive stress during high-power up-shifts (’875 Patent, col. 4:18-21).

Key Claims at a Glance

• The complaint asserts at least independent claim 8 (Compl. ¶44).
• The essential elements of Claim 8 are:
  • A bicycle chain ring, comprising:
  • a plurality of lifting surfaces perpendicularly disposed about an inner surface of the bicycle chain ring, 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 to the bicycle chain without assistance from chain ring teeth or shift pins during an up-shift; and
  • wherein at least one of the plurality of lifting surfaces extends radially along the inner surface toward an outer edge where a plurality of chain ring teeth emanate, beginning at a first radius and ending at a second, larger radius; and
  • wherein the at least one lifting surface has a first end proximate an inner edge of the chain ring and a second end proximate the outer edge.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 11,460,099 - "Bicycle Chain Rings" (Issued October 4, 2022)

Technology Synopsis

This patent continues the theme of improving bicycle shifting performance by addressing the shortcomings of prior art systems, which can be inefficient and cause excessive chain stress, especially under load (’099 Patent, col. 1:51-54, col. 2:32-39). The patented solution is a chainring with ramps on its inner surface that have a lifting surface configured to "concurrently engage at least one link of a bicycle chain at two or more distinct pivot points" to create a stable lift without assistance from the chainring teeth (’099 Patent, Abstract).

Asserted Claims

The complaint asserts at least independent claim 1 (Compl. ¶52).

Accused Features

The complaint alleges that the accused absoluteBLACK chainrings, by incorporating shifting ramps, infringe the ’099 Patent (Compl. ¶¶18, 52-53).

III. The Accused Instrumentality

Product Identification

• The accused products are various models of absoluteBLACK-branded oval and premium bicycle chainrings, including the "OVAL Road 110/4 9000/6800," "Premium OVAL Road 110/5 BCD Chainring," and "Premium ROAD 2X Chainrings" (Compl. ¶18).

Functionality and Market Context

• The accused products are aftermarket, high-performance bicycle components sold to consumers online and through authorized dealers such as co-defendant Playtri (Compl. ¶¶4, 7). The complaint alleges these chainrings incorporate special "ramps" on their inner surfaces to improve shifting (Compl. ¶25). A marketing image included in the complaint states, "Our special ramps work in conjunction with the tooth recesses to stabilize the chain when shifting," and labels the features "Ramp" and "Recess" (Compl. p. 7). This image from the defendant's materials shows a ramp structure intended to guide the chain during a shift (Compl. p. 7).

IV. Analysis of Infringement Allegations

'338 Patent Infringement Allegations

• Identified Points of Contention:
  • Technical Questions: A key factual question will be whether the accused ramps actually function "without assistance from any of the plurality of chain ring teeth" to initiate the lift. Defendant's own marketing material, cited in the complaint, states the ramps work "in conjunction with the tooth recesses" (Compl. p. 7), which may suggest a cooperative function that could be argued as falling outside the scope of this limitation.
  • Scope Questions: The claim requires the ramp to "concurrently engage at least one link of a bicycle chain at two or more distinct pivot points." Evidence will be needed to establish whether the accused ramps make contact in this specific manner to create the claimed "stable lift," or if the interaction is of a different nature.

'875 Patent Infringement Allegations

• Identified Points of Contention:
  • Technical Questions: The complaint does not provide specific evidence mapping to the unique limitations of claim 8 of the '875 Patent. A central evidentiary question will be whether the accused ramps engage the chain at "load points...below bicycle chain link pins," a precise point of contact required by the claim. Proving this specific interaction will be critical for the plaintiff.
  • Scope Questions: The term "perpendicularly disposed about an inner surface" may raise a claim construction issue regarding the precise orientation and formation of the accused ramps relative to the main plane of the chainring body.

V. Key Claim Terms for Construction

• The Term: "stable lift" (’338 Patent, Claim 1)

  • Context and Importance: This term is fundamental to the invention's purported improvement over the prior art. Its definition will determine the standard for infringement, specifically what type of chain-and-ramp interaction qualifies. Practitioners may focus on this term because its construction will dictate whether a general lifting action suffices or if a more specific, multi-point engagement is required.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification does not provide a single, explicit definition, which could support giving the term its plain and ordinary meaning.
    • Evidence for a Narrower Interpretation: The specification contrasts "stable lift" with the "unstable lift point" and "see saw action" of prior art single-pin systems (’875 Patent, FIG. 30B). The claims themselves link "stable lift" to concurrent engagement at "two or more distinct pivot points" (’338 Patent, Claim 1) or engagement "below bicycle chain link pins" (’875 Patent, Claim 8), suggesting the term may be implicitly defined by these structural and functional requirements.

• The Term: "without assistance from any of the plurality of chain ring teeth" (’338 Patent, Claim 1)

  • Context and Importance: This negative limitation is critical for distinguishing the claimed invention from prior art where teeth perform the primary lifting function. Its interpretation is central to the dispute, especially given Defendant's marketing statement that its ramps and tooth recesses work "in conjunction" (Compl. p. 7).
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation (favors Patentee): The claim requires the initiation of lift to be without assistance. This could be argued to mean the ramp must begin the lift alone, even if teeth become involved later to guide or complete the shift.
    • Evidence for a Narrower Interpretation (favors Accused): This could be construed to require the entire lifting action to be independent of any functional help from the teeth. A defendant may argue that if tooth recesses are necessary to "stabilize the chain when shifting" (Compl. p. 7), the teeth are providing "assistance" from the moment of initiation, placing the product outside the claim scope.

VI. Other Allegations

• Indirect Infringement: The complaint does not contain formal counts for indirect infringement. However, it alleges facts that may support such a claim, stating that Defendants "teach customers how to use infringing chainrings" (Compl. ¶9) and provide instructions for use (Compl. ¶16).
• Willful Infringement: The complaint alleges that RampWerks provided pre-suit notice to both absoluteBLACK and Playtri regarding all three asserted patents (Compl. ¶¶38, 46, 54). This allegation of pre-suit knowledge of the patents and the alleged infringement forms the basis for a claim of willful infringement.

VII. Analyst’s Conclusion: Key Questions for the Case

• A key evidentiary question will be one of functional operation: do the accused ramps initiate a "stable lift...without assistance" from the chainring teeth as required by the '338 patent, or do they work "in conjunction with the tooth recesses" as described in the defendant's own marketing, potentially creating a functional mismatch with the claim language?
• A central issue for the court will be one of contact specificity: can the plaintiff produce evidence that the accused ramps engage the bicycle chain at the precise locations required by the claims—specifically "at two or more distinct pivot points" ('338 patent) and "below bicycle chain link pins" ('875 patent)—or does the actual point of contact differ in a way that avoids infringement?
• The case may also turn on a question of claim construction: how will the court define the term "assistance" in the negative limitation "without assistance from any of the plurality of chain ring teeth"? The outcome of this definition will significantly influence whether the cooperative action described in the defendant's marketing materials falls within or outside the scope of the claims.