Jayflex LLC v. Zhuhai Ai shan Electronic Technology Co

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Jayflex, LLC (Utah)
  • Defendant: Zhuhai Ai Shan Electronic Technology Co. Ltd. (People's Republic of China)
  • Plaintiff’s Counsel: Parr Brown Gee & Loveless
• Case Identification: 2:24-cv-00743, D. Utah, 10/04/2024
• Venue Allegations: Plaintiff alleges venue is proper in the District of Utah because Defendant has marketed and sold the accused products within the state and derived substantial revenue from those sales.
• Core Dispute: Plaintiff alleges that Defendant’s "Dumbbell Barbell Converter Set" infringes a patent related to a clamp system that adapts standard dumbbells for use with alternative exercise handles.
• Technical Context: The technology addresses the home fitness market, where users seek to perform a variety of exercises (e.g., kettlebell swings, barbell presses) without purchasing multiple, expensive, and space-consuming sets of weights.
• Key Procedural History: The complaint alleges that Defendant was on notice of the patent and its infringement at least by September 30, 2023, through a complaint made via Amazon by the patent's previous owner. It further alleges that despite a subsequent product redesign, Defendant continued to sell the accused products.

Case Timeline

Date	Event
2021-05-05	Priority Date for U.S. Patent No. 11,752,385
2023-09-12	U.S. Patent No. 11,752,385 Issues
2023-09-30	Alleged date of Defendant’s knowledge of patent and infringement
2024-10-04	Complaint Filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 11,752,385 - "Exercise Equipment Clamp and Handles"

• Patent Identification: U.S. Patent No. 11,752,385, "Exercise Equipment Clamp and Handles," issued September 12, 2023.

The Invention Explained

• Problem Addressed: The patent's background describes the high cost and large storage space required for consumers who wish to own various types of resistance exercise equipment, such as dumbbells, kettlebells, and barbells, to perform different exercises. (’385 Patent, col. 1:13-33).
• The Patented Solution: The invention is a clamp system designed to solve this problem by enabling a single set of weights (e.g., dumbbells) to be used with different types of handles. The device features a hinged body that clamps around a dumbbell handle and a "neck" structure that allows for the attachment of an external handle, such as a kettlebell handle or a barbell. (’385 Patent, Abstract; col. 3:34-40). A collar slides over and secures the two halves of the neck, locking the external handle in place. (’385 Patent, col. 4:56-64).
• Technical Importance: The technology provides a modular apparatus that allows users to convert a standard dumbbell into a kettlebell or attach it to a barbell, thereby increasing exercise versatility without the need to purchase entirely separate equipment. (’385 Patent, col. 1:30-33).

Key Claims at a Glance

• The complaint alleges infringement of "one or more claims" without specifying which ones (Compl. ¶10). Independent claim 1 is representative of the core invention.
• Independent Claim 1 recites:
  • A body configured to receive a portion of a piece of exercise equipment, the body including a first portion, a second portion, and a hinge connecting them.
  • A neck that is cylindrical in shape, with a first portion attached to the body's first portion and a second portion attached to the body's second portion.
  • A collar configured to engage over the outer parts of the neck's first and second portions to secure them together.
  • The neck is configured to secure to an external handle once the collar has secured the neck portions.
• The complaint’s general allegations preserve the right to assert other independent claims (e.g., 22, 29) and any dependent claims.

III. The Accused Instrumentality

Product Identification

The "Dumbbell Barbell Converter Set" (ASIN: B0C65Z9MGN), sold under the trade name "AltitudeCraft" on online marketplaces. (Compl. ¶1).

Functionality and Market Context

• The complaint alleges the product is a "clamp for exercise equipment" that enables a user to "switch between using exercise equipment as barbells, dumbbells, and kettlebells." (Compl. ¶8).
• It is alleged to incorporate a clamp that embodies the elements of the claims of the ’385 Patent. (Compl. ¶10). The complaint does not provide further technical details, diagrams, or descriptions of how the accused product operates.
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not provide a claim chart or sufficient detail to conduct a side-by-side comparison of the claim elements against the features of the accused product. The infringement theory is articulated in general terms, stating that the Accused Products "embody or use the inventions claimed in the ’385 Patent" and "incorporate a clamp with each of the elements of one or more claims of the ’385 Patent" (Compl. ¶10). The central allegation is that the Defendant's "Dumbbell Barbell Converter Set" is structurally and functionally equivalent to the apparatus described in the asserted patent.

Identified Points of Contention

• Structural Questions: A central factual question will be whether the accused product's physical construction maps onto the specific elements of Claim 1. This includes whether it possesses a two-part hinged body, a two-part cylindrical "neck" that receives an external handle, and a separate "collar" that slides over the neck to lock it, as opposed to an alternative locking or attachment mechanism.
• Scope Questions: The dispute may center on whether the components of the accused product fall within the scope of the patent's claim terms. For instance, if the accused product uses a latch, clasp, or screw mechanism that does not "engage over outer parts of the...neck," it raises the question of whether that mechanism can be considered a "collar" as claimed.

V. Key Claim Terms for Construction

Claim Term: "collar"

• Context and Importance: This term defines the locking mechanism that secures the two halves of the neck. Its construction is critical because if the accused product's locking feature does not meet the definition of a "collar", a finding of non-infringement could result. Practitioners may focus on this term to determine if the defendant's product, which may use a different type of fastener, falls within the claim's literal scope.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests flexibility in the attachment method, stating the collar can attach "by threading onto the neck 110, snapping onto the neck 110 or through any other desired attachment method." (’385 Patent, col. 4:61-64).
  • Evidence for a Narrower Interpretation: The primary embodiment illustrated and described is a threaded ring that engages with threads on the neck. (’385 Patent, Fig. 1B; col. 2:2-6). A party could argue the term should be construed as a ring-like structure consistent with the figures and the common meaning of the word in a mechanical context.

Claim Term: "neck that is cylindrical in shape"

• Context and Importance: This term defines the geometry of the interface that connects to the external handle. A defendant whose product uses a non-cylindrical or differently shaped interface could argue it does not infringe.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A plaintiff might argue that "cylindrical" should not be interpreted with undue rigidity and could encompass shapes that are functionally cylindrical for the purpose of mating with a handle.
  • Evidence for a Narrower Interpretation: The patent repeatedly uses the phrase "cylindrical in shape" to describe the neck, and all corresponding figures depict a distinctly cylindrical structure (110). (’385 Patent, Abstract; col. 4:50). This consistency may support a narrower construction limited to the specific geometry.

VI. Other Allegations

Indirect Infringement

The complaint makes a conclusory allegation of induced infringement, stating Defendant has "actively and knowingly" induced others. (Compl. ¶11, 16). It does not, however, plead specific facts to support this claim, such as referencing user manuals or advertising that instruct customers on how to perform an infringing use.

Willful Infringement

Willfulness is alleged based on Defendant’s purported pre-suit knowledge of the ’385 Patent. (Compl. ¶12, 17). The complaint specifically alleges that Defendant was made aware of the patent and its infringement "at least by September 30, 2023" via a complaint filed on Amazon by the patent's prior owner. (Compl. ¶12). It further alleges that a subsequent redesign failed to make the product non-infringing, which may suggest an objective recklessness. (Compl. ¶12).

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

1. A primary issue will be one of evidentiary mapping: As a notice-pleading complaint, it leaves open the fundamental question of what the accused product’s design actually is. Discovery will be required to determine if the "Dumbbell Barbell Converter Set" possesses the specific structural elements recited in the claims, including the hinged body, two-part cylindrical neck, and distinct locking collar.

2. The case may also hinge on claim construction: Can the term "collar", as used in the patent, be construed broadly to cover any mechanism that fastens the neck portions together, or will it be limited to a ring-like structure that slides over the neck, as depicted in the patent’s figures? The outcome of this definitional dispute could be dispositive.

3. A significant question will concern the defendant’s state of mind: Can the plaintiff substantiate its allegation that the defendant had pre-suit notice of the patent via an Amazon complaint and proceeded to infringe despite this knowledge? If proven, this fact pattern would substantially strengthen the claim for willful infringement and potential enhanced damages.