RampWerks LLC v. Absoluteblack

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: RampWerks, LLC (Texas)
  • Defendant: absoluteBLACK (Slovenia/United Kingdom)
  • Plaintiff’s Counsel: CONNOR LEE AND SHUMAKER PLLC
• Case Identification: 2:24-cv-00695, E.D. Tex., 08/23/2024
• Venue Allegations: Venue is alleged to be proper based on Defendant being a foreign corporation and having committed acts of infringement in the district, including sales through its website, Amazon, and a physical dealer in Tyler, Texas.
• Core Dispute: Plaintiff alleges that Defendant’s specialty oval bicycle chainrings infringe patents related to chainring ramps designed to provide faster and more stable gear shifting.
• Technical Context: The technology concerns high-performance bicycle drivetrains, where the speed and reliability of shifting gears, particularly under load, are critical performance factors.
• Key Procedural History: The complaint notes the existence of a co-pending case involving the same parties, Case No. 24-cv-245-JRG. The complaint also carves out certain absoluteBLACK chainrings sold by J&B Importers, Inc., stating they are not accused because they are licensed.

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 that conventional methods for shifting a bicycle chain between front chainrings, which involve laterally pushing the chain, are inadequate for high-load situations like sprinting or climbing (’338 Patent, col. 1:47-52). Prior art solutions, such as using pins or specially shaped teeth to lift the chain, can create high stress on single points of the chain, leading to wear and reduced longevity (’338 Patent, col. 2:25-38).
• The Patented Solution: The invention is a chainring with specially designed ramps on its inner surface. These ramps feature a "lifting surface" that is configured to engage a single link of the bicycle chain at two or more of its pivot points (i.e., its rollers) simultaneously. This multi-point contact is designed to initiate a "stable lift" of the chain from a smaller ring to a larger ring, without relying on the chainring teeth to perform the lift (’338 Patent, Abstract; col. 8:36-41).
• Technical Importance: This approach seeks to distribute the lifting forces across multiple points on a chain link, which may reduce stress and improve shifting speed and reliability compared to prior art single-point lifting mechanisms (’338 Patent, col. 13:8-15).

Key Claims at a Glance

• The complaint asserts independent claim 1 and reserves the right to assert others (Compl. ¶30).
• Claim 1 Elements:
  • 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.

U.S. Patent No. 10,711,875 - “Bicycle Chain Rings,” issued July 14, 2020

The Invention Explained

• Problem Addressed: The '875 Patent addresses the same technical problem as the '338 Patent: the need for improved up-shifting performance in bicycle drivetrains, particularly under load, without creating excessive stress on the chain (’875 Patent, col. 2:25-32).
• The Patented Solution: This patent also discloses a chainring with ramps on its inner surface that provide multi-point, stable lift. The claims in this patent further refine the geometry of the ramp and its relationship to the surrounding chainring teeth. A key feature is that the ramp's lifting surface "terminates before reaching the bottom of a trough" positioned between the teeth, which may further refine how the chain engages and disengages from the ramp during a shift (’875 Patent, Abstract; col. 21:8-24).
• Technical Importance: The specified termination point of the lifting surface suggests a design optimized to hand off the chain smoothly after lifting it, potentially preventing snags or incomplete shifts.

Key Claims at a Glance

• The complaint asserts independent claim 8 and reserves the right to assert others (Compl. ¶37).
• Claim 8 Elements:
  • A bicycle chain ring, comprising:
  • a plurality of lifting surfaces perpendicularly disposed about an inner surface of the bicycle chain ring, at least one configured to concurrently engage two or more load points of a bicycle chain below its link pins to initiate stable lift;
  • wherein at least one of the lifting surfaces extends radially along the inner surface toward an outer edge where teeth emanate;
  • the lifting surface begins at a first radius and ends at a second, larger radius; and
  • the lifting surface has a first end proximate an inner edge and a second end proximate the outer edge.

U.S. Patent No. 11,460,099 - “Bicycle Chain Rings,” issued October 4, 2022

• Technology Synopsis: As a continuation of the same patent family, the ’099 Patent covers bicycle chainrings with ramp structures designed to improve up-shifting. The invention aims to solve the problem of high-stress, single-point lifting in prior art systems by using ramps that provide a stable, multi-point lift to the chain, independent of the chainring teeth.
• Asserted Claims: Independent claim 1 is asserted (Compl. ¶44).
• Accused Features: The complaint accuses the same ramp structures on the Defendant's chainrings of infringing the '099 Patent (Compl. ¶¶ 15, 44).

III. The Accused Instrumentality

Product Identification

The accused products are various models of absoluteBLACK's oval chainrings for high-performance bicycles, including the "OVAL Road 110/4 9000/6800" and "Premium OVAL Road 110/5 BCD Chainring" (Compl. ¶13).

Functionality and Market Context

The accused products are marketed as "ultimate bicycle components" featuring non-circular, or oval, shapes intended to smooth out pedal strokes (Compl. ¶¶ 13, 21). Critically, they feature structures on their inner surface that absoluteBLACK itself refers to as "ramps" (Compl. ¶20). The complaint provides an image from the accused product's packaging which states, "Our special ramps work in conjunction with the tooth recesses to stabilize the chain when shifting," a feature alleged to improve up-shifting (Compl. p. 4; ¶21). The complaint also includes a screenshot showing the Defendant has a dealer located within the Eastern District of Texas (Compl. ¶5, p. 2).

IV. Analysis of Infringement Allegations

10,677,338 Patent Infringement Allegations

10,711,875 Patent Infringement Allegations

Identified Points of Contention

• Functional Equivalence: A primary question will be whether the accused "ramps" that "stabilize the chain" (Compl. p. 6) perform the specific function of providing a "stable lift... without assistance from any of the... teeth" as required by the claims. The defense may argue its ramps function differently, perhaps in concert with the teeth, while the plaintiff will likely use the defendant's own marketing language as an admission.
• Evidentiary Proof: A key factual dispute will center on proof of the "concurrently engage[ment] at two or more distinct pivot points" limitation. The plaintiff's static photos show potential for such contact, but demonstrating that this specific interaction occurs during a dynamic, high-load shift will likely require more extensive evidence, such as high-speed video analysis or expert testimony.

V. Key Claim Terms for Construction

"stable lift"

• Context and Importance: This term is a cornerstone of the claimed invention, distinguishing it from prior art that allegedly caused unstable lifting. Its definition will determine the standard of performance the accused products must meet to infringe. Practitioners may focus on this term because it is qualitative and its meaning is heavily informed by the patent's disparagement of prior art.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification does not provide an explicit definition, which could support an argument for a plain and ordinary meaning (e.g., any lift that is not unstable).
  • Evidence for a Narrower Interpretation: The specification of the related '875 patent explicitly contrasts the invention with the "see saw action" and "unstable lift point" of prior art pin systems (’875 Patent, FIG. 30B, col. 3:40-55). A court may find that "stable lift" must be construed as a lift that specifically avoids this "see saw" instability.

"without assistance from any of the plurality of chain ring teeth"

• Context and Importance: This limitation defines the ramps as the sole initiator of the lift, separating the invention from systems where teeth play a primary role. The infringement analysis will turn on whether the accused ramps operate independently or in concert with the teeth.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party could argue this means the ramps provide the primary or essential lifting force, even if the teeth make incidental or subsequent contact.
  • Evidence for a Narrower Interpretation: The explicit language "without assistance from any" suggests an absolutist interpretation, where the teeth can provide no functional contribution to the initiation of the stable lift. The abstract's phrasing, "initiate stable lift... without assistance from any of the... teeth," supports this focus on the initiation phase (’338 Patent, Abstract).

VI. Other Allegations

Indirect Infringement

While the formal counts plead only direct infringement, the complaint lays a factual predicate for a potential inducement claim by alleging that absoluteBLACK "instructs customers and end users how to... use the accused products" and provides instructions via its website and product packaging (Compl. ¶¶ 9, 11, 21).

Willful Infringement

The complaint alleges that absoluteBLACK will be on notice of its infringement "At least as of the service of this Complaint" (Compl. ¶¶ 31, 38, 45). This allegation establishes a basis for seeking enhanced damages for any infringement that occurs after the lawsuit was filed.

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

• A key evidentiary question will be one of demonstrated function: Can Plaintiff produce compelling evidence, beyond static photographs, to prove that the accused ramps dynamically engage a chain link at "two or more distinct pivot points" to create a "stable lift" during an up-shift, as strictly required by the claims?
• A central issue of claim construction will be the scope of independence: How will the court interpret "without assistance from any of the... teeth"? The outcome may depend on whether this requires absolute non-involvement of the teeth in the lift, or merely that the ramps are the primary and sufficient lifting structure.
• The case may also turn on a question of market language versus technical reality: To what extent can Plaintiff use Defendant’s own marketing statement that its ramps "stabilize the chain" as evidence of infringement, and to what extent can Defendant argue this is mere marketing puffery that does not describe the specific, claimed functionality?