DCT
3:25-cv-00564
Huizhou Potian Technology Co Ltd v. Kehoe
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Huizhou Potian Technology Co. Ltd. dba Iron Age, et al. (People's Republic of China)
- Defendant: Michael Kehoe (Republic of Ireland)
- Plaintiff’s Counsel: Ni, Wang & Massand, PLLC
- Case Identification: 3:25-cv-00564, N.D. Tex., 03/06/2025
- Venue Allegations: Venue is alleged to be proper as the Defendant is a foreign individual residing in the Republic of Ireland.
- Core Dispute: Plaintiffs seek a declaratory judgment that their doorway pull-up bars do not infringe U.S. Patent No. 11,484,746 and that the patent is invalid, following Defendant’s assertion of infringement through Amazon’s intellectual property enforcement program.
- Technical Context: The technology concerns doorway-mounted exercise equipment, specifically pull-up bars designed to be foldable for compact storage.
- Key Procedural History: The lawsuit was precipitated by Defendant initiating a proceeding under the Amazon Patent Evaluation Express (“APEX”) program, alleging that Plaintiffs’ products infringe the patent-in-suit. This action moves the dispute from Amazon's quasi-arbitration system, which the complaint alleges is structurally unfavorable to accused sellers, into federal court where both infringement and patent validity can be fully litigated.
Case Timeline
| Date | Event |
|---|---|
| 2018-03-01 | Plaintiffs' initial product design (Compl. ¶20) |
| 2020-08-01 | Priority Date for U.S. Patent No. 11,484,746 |
| 2022-11-01 | U.S. Patent No. 11,484,746 Issued |
| 2025-01-16 | Defendant initiated APEX procedure against Plaintiffs (approximate date) |
| 2025-03-06 | Complaint for Declaratory Judgment Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,484,746, "Foldable Exercise Device," Issued November 1, 2022
The Invention Explained:
- Problem Addressed: The patent addresses the problem of conventional doorway exercise devices being "bulky and difficult to store" and often failing to "provide parallel chin up bars for neutral grip chin-ups," which is a particular issue for users in small homes or apartments with limited space ('746 Patent, col. 1:11-18).
- The Patented Solution: The invention is a foldable exercise device featuring a chin-up apparatus with key components—a door header hook and a parallel chin-up handle—that "rotate on the connecting member from a flat configuration to an exercise configuration" ('746 Patent, Abstract). This rotational transition allows the device to be collapsed into a compact, storable form while providing the functionality of a full-size pull-up bar, including neutral-grip handles, when in use ('746 Patent, col. 3:65-4:5).
- Technical Importance: The described solution aims to combine the stability of a door-mounted exercise bar with the convenience of a device that can be stored compactly, such as under a bed or in a closet ('746 Patent, col. 3:61-64).
Key Claims at a Glance:
- The complaint focuses on independent claim 8 as the asserted claim in the underlying APEX proceeding (Compl. ¶28).
- The essential elements of independent claim 8 include:
- a top horizontal member;
- a bottom horizontal member spaced apart from the top horizontal member;
- two connecting members connecting the top and bottom horizontal members;
- where each connecting member has a door header hook and a parallel chin-up handle that transitions to an exercise configuration;
- the door header hook and the parallel chin-up handle are on opposite sides of the connecting members;
- in the exercise configuration, the hooks and handles are roughly perpendicular to the bottom horizontal member;
- the apparatus can releasably engage a door frame, with the parallel chin-up handles extending away from the door frame for neutral chin-ups.
- The complaint also asserts non-infringement of dependent claims by extension (Compl. ¶35).
III. The Accused Instrumentality
- Product Identification: The "Accused Products" are doorway pull-up bars sold by the Plaintiffs on Amazon.com under specific ASINs: B0C5XSRXCL, B0D21T7HMH, B0D1FRBR4Q, and B09HS76CBD (Compl. ¶18).
- Functionality and Market Context: The products are described as "door hook style pull up bar[s] with an ergonomically angled end and vertical grip bar" (Compl. ¶19). A marketing image depicts the "2023 ENHANCED DOORWAY PULL UP BAR" mounted in a doorway, with multiple grip positions visible (Compl. p. 5). Plaintiffs allege that the Amazon marketplace is their primary sales channel and that the potential delisting of these products as a result of the APEX proceeding would cause significant harm to their business (Compl. ¶¶21-22).
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement. The analysis below summarizes the Plaintiffs' core arguments for why their products do not meet the limitations of the asserted claim.
'746 Patent Infringement Allegations (as framed by Plaintiffs' non-infringement argument)
| Claim Element (from Independent Claim 8) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a top horizontal member; | The complaint does not contest this element. | col. 8:8 | |
| a bottom horizontal member spaced apart from the top horizontal member; and | The complaint does not contest this element. | col. 8:9-10 | |
| two connecting members connecting the top horizontal member and the bottom horizontal member, | The complaint does not contest this element. | col. 8:11-15 | |
| where each connecting member has a door header hook and a parallel chin-up handle that transitions to an exercise configuration, | Plaintiffs allege that while the Accused Product has a door header hook and parallel chin-up handle, they do not transition in the manner required by the patent, which is described as a rotational movement around the connecting member. | ¶36 | col. 8:15-17 |
| where the door header hook and the parallel chin-up handle are on opposite sides of the connecting members, | The complaint does not contest this element. | col. 8:17-19 | |
| in the exercise configuration the door header hooks and parallel chin-up handles are roughly perpendicular to the bottom horizontal member | The complaint does not contest this element. | col. 8:20-22 |
- Identified Points of Contention:
- Scope Questions: The central dispute appears to be the meaning of the phrase "transitions to an exercise configuration." The complaint argues this transition is limited by the patent's disclosure to a specific rotational mechanism ('746 Patent, col. 3:65-4:5), raising the question of whether the claim scope is constrained by the embodiments described in the specification. A court will have to determine if "transitions" is a broad functional term or if it implicitly requires the specific rotational movement detailed in the patent.
- Technical Questions: A key factual question will be how the Accused Products actually move from a stored to a use configuration. The complaint asserts that the mechanism is different from the one disclosed in the patent but does not provide a technical description of the Accused Products' own transition mechanism (Compl. ¶36). Evidence detailing the specific mechanical operation of the Accused Products will be critical.
V. Key Claim Terms for Construction
- The Term: "transitions to an exercise configuration"
- Context and Importance: This term is the lynchpin of the Plaintiffs' non-infringement argument. The definition of "transitions" will determine whether the claim covers any method of moving from a flat to a use state or is limited to the specific rotational method disclosed in the patent. Practitioners may focus on this term because its construction could be dispositive of the infringement question.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party arguing for a broader scope might contend that "transitions" should be given its plain and ordinary meaning of "to change from one state or condition to another." They may point to claim 8 itself, which does not explicitly recite the word "rotate," and argue that limitations from the specification should not be imported into the claims.
- Evidence for a Narrower Interpretation: The Plaintiffs' argument relies on evidence suggesting the patentee defined the term by its disclosure. They cite the Abstract, which states the handle "rotate[s]... from a flat configuration to an exercise configuration," and the detailed description, which states that "Transitioning between the exercise configuration and the flat configuration may be a matter of the door header hook 125 and the parallel chin-up handle 130 transitioning from being in a plane perpendicular... to being co-planer" via rotation ('746 Patent, Abstract; Compl. ¶36, citing '746 Patent, col. 3:65-4:5). This repeated linkage of "transition" with a specific rotational action may support a narrower construction.
VI. Other Allegations
- Invalidity: Plaintiffs allege that claim 8 of the '746 Patent is invalid as obvious under 35 U.S.C. § 103 in view of several prior art references (Compl. ¶¶40-45). The complaint lists multiple combinations of U.S. and foreign patents and applications, but provides only conclusory assertions that these references teach the claimed limitations. The complaint does not provide sufficient detail for a substantive analysis of these invalidity theories.
- Exceptional Case: Plaintiffs request a declaration that the case is exceptional and an award of attorney fees pursuant to 35 U.S.C § 285 (Compl. p. 11). The basis for this request is not explicitly detailed but may relate to the allegations regarding the Defendant's use of the APEX program.
VII. Analyst’s Conclusion: Key Questions for the Case
- Definitional Scope: A core issue will be one of claim construction: can the phrase "transitions to an exercise configuration," as used in Claim 8, be interpreted broadly to cover any mechanism for changing from a stored to a use state, or is it limited by the specification's disclosure to the specific rotational mechanism described therein?
- Infringement and Validity Tension: Plaintiffs argue both that their product does not have the claimed "transition" feature for non-infringement, and that this same feature is disclosed in the prior art for invalidity. A key strategic question will be how Plaintiffs navigate this tension, as a broad interpretation of the claim for invalidity purposes could weaken their non-infringement position, and vice-versa.
- Factual-Technical Mismatch: Assuming the court construes the key claim term, a central evidentiary question will remain: what is the precise mechanical operation by which the Accused Products change from a stored to a use configuration, and does that operation fall within the court’s definition of the claimed "transition"?