Liu v. Unincorp Associations

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Bin Liu (China)
  • Defendant: The Unincorporated Associations Identified on Schedule A (Jurisdiction(s) Unknown)
  • Plaintiff’s Counsel: DNL Zito
• Case Identification: 1:25-cv-02296, E.D. Va., 12/09/2025
• Venue Allegations: Plaintiff alleges venue is proper because the Defendants are not U.S. residents and are subject to personal jurisdiction, or alternatively, because they are aliens engaged in infringing acts within the district.
• Core Dispute: Plaintiff alleges that numerous unidentified e-commerce operators, operating under various aliases, are selling multifunctional fitness frames that infringe a patent related to a reversible pedal structure.
• Technical Context: The technology concerns all-in-one home fitness equipment, specifically addressing the mechanical design of components to maximize versatility and user convenience in a compact space.
• Key Procedural History: The complaint states that the patent-in-suit has never been challenged in court or at the United States Patent and Trademark Office. The litigation targets a large group of unidentified online sellers alleged to be operating in concert.

Case Timeline

Date	Event
2023-06-22	U.S. Patent No. 11,911,650 Priority Date
2024-02-27	U.S. Patent No. 11,911,650 Issues
2025-12-09	Complaint Filed

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

U.S. Patent No. 11,911,650 - "Multifunctional Fitness Frame with Reversible Pedal Structure"

• Patent Identification: U.S. Patent No. 11,911,650, “Multifunctional Fitness Frame with Reversible Pedal Structure,” issued February 27, 2024 (’650 Patent).

The Invention Explained

• Problem Addressed: The patent’s background section identifies a problem with prior art multifunctional fitness frames where fixed pedals, used for exercises like seated rowing, interfere with other movements, such as standing stretching exercises, thereby reducing the equipment’s utility and making the user’s experience less smooth (’650 Patent, col. 1:37-48).
• The Patented Solution: The invention is a pedal assembly for a fitness frame that is "reversible." The pedal is mounted on a rotating shaft and can be positioned in two distinct functional modes. For a seated paddling exercise, the pedal is turned over to lean against a support tube for foot placement. To clear space for other exercises, the pedal can be rotated further to lean against the ground, effectively storing it out of the user's way (’650 Patent, Abstract; col. 2:63-col. 3:10).
• Technical Importance: This design aims to enhance the versatility of a single piece of fitness equipment by providing a simple mechanical solution to the problem of component interference between different exercise types (’650 Patent, col. 1:49-56).

Key Claims at a Glance

• The complaint asserts independent claim 1 (’650 Patent, col. 4:14-26; Compl. ¶34, 38).
• Claim 1 requires:
  • A main frame
  • A pull ring arranged on the main frame
  • A pedal arranged on the main frame in a reversible manner
  • A support tube and a rotating shaft penetrated on the main frame
  • Wherein the pedal is rotated around the rotating shaft and leans against the support tube to facilitate paddling
  • Wherein the pedal is also rotated around the rotating shaft and leaned against the ground to realize storage

III. The Accused Instrumentality

Product Identification

• The complaint identifies the accused instrumentalities as the “Unauthorized Products,” which are described as multifunctional fitness frames sold by the Defendants through various e-commerce storefronts on platforms including Amazon and Walmart (Compl. ¶¶ 6, 22).

Functionality and Market Context

• The complaint alleges that the Unauthorized Products are “virtually identical in appearance and share the same claimed features of the Patent-in-Suit” (Compl. ¶34). It further alleges that the Defendants target consumers throughout the United States, including in Virginia, through online storefronts that are designed to appear as if they are authorized retailers (Compl. ¶¶ 16, 27). The complaint asserts that a “flood of infringing products” appeared on the market due to the popularity of the Plaintiff’s own patented products (Compl. ¶12). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references a claim chart attached as Exhibit 6, but this exhibit was not provided with the filing (Compl. ¶38). The infringement theory articulated in the complaint is that the Unauthorized Products are "virtually identical" to the plaintiff's commercial embodiment and embody all features of claim 1 of the ’650 Patent (Compl. ¶34). The complaint alleges infringement both directly and under the doctrine of equivalents, stating that the accused products incorporate each element of claim 1 (Compl. ¶¶ 34, 38, 40). Without the claim chart or specific details on the accused products' mechanics, a detailed element-by-element analysis is not possible based on the complaint alone.

• Identified Points of Contention:
  • Scope Questions: A central question may be whether the phrase "leans against the support tube" requires direct, stable contact for the purpose of supporting a user's feet during paddling, and whether the accused products meet this limitation. Similarly, the meaning of "leaned against the ground ... to realize storage" may be disputed.
  • Technical Questions: An evidentiary question will be whether the plaintiff can demonstrate that the products sold by the numerous, disparate defendant storefronts are, in fact, "virtually identical" and all practice the claimed two-mode reversible pedal functionality (Compl. ¶34). The complaint's infringement theory rests heavily on this assertion of uniformity across different sellers.

V. Key Claim Terms for Construction

• The Term: "reversible manner"
• Context and Importance: This term is central to the patent's novelty, distinguishing it from prior art with fixed pedals. The definition of this term will likely determine the scope of the claim and whether a pedal that can simply be moved, but not necessarily into the two specific functional positions recited in the claim, would infringe.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party could argue that the plain and ordinary meaning of "reversible" simply means capable of being turned over or moved between positions.
  • Evidence for a Narrower Interpretation: The claim itself appears to define the "reversible manner" by its specific functions: the pedal must be capable of being "rotated around the rotating shaft and lean[] against the support tube...to practice paddling" AND "also rotated...and leaned against the ground...to realize storage" (’650 Patent, col. 4:20-26). This functional language provides strong intrinsic evidence that the term is not merely directional but requires the capability of achieving these two distinct, claimed operational modes.

VI. Other Allegations

• Indirect Infringement: The complaint does not contain specific factual allegations to support claims of induced or contributory infringement, such as knowledge of the patent combined with specific actions intended to cause infringement by others. The prayer for relief includes a request to enjoin "aiding, abetting, contributing to, or otherwise assisting anyone" in infringing (Compl. p. 12, ¶1(b)).
• Willful Infringement: The complaint alleges that Defendants’ infringement "has been and continues to be willful" (Compl. ¶42). This allegation is based on the assertion that Defendants are working in "active concert to knowingly and willfully manufacture, import, distribute, offer for sale, and sell Unauthorized Products" (Compl. ¶33). The complaint does not allege specific facts demonstrating pre-suit knowledge of the ’650 Patent itself.

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

• A core issue will be one of evidentiary linkage: given the defendants are a collection of unidentified online sellers, can the plaintiff establish that the products sold across these numerous storefronts are sufficiently uniform to prove that each one practices every limitation of the asserted claim, as alleged?
• The central legal question will be one of claim scope: will the term "reversible manner" be construed narrowly to require the specific, dual-mode functionality of leaning against a support tube for paddling and leaning against the ground for storage, as detailed in the claim body, or can it be read more broadly? The outcome of this construction will likely be determinative of infringement for any given accused product.