Maxrep Inc v. Unincorp Associations

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Maxrep, Inc. (Delaware)
  • Defendant: The Unincorporated Associations Identified on Schedule A (Jurisdiction Undisclosed)
  • Plaintiff’s Counsel: DNL Zito
• Case Identification: 1:25-cv-02343, E.D. Va., 12/12/2025
• Venue Allegations: Plaintiff alleges venue is proper because the defendants are aliens not resident in the United States and have targeted sales of accused products to consumers in Virginia.
• Core Dispute: Plaintiff alleges that Defendants’ e-commerce sales of multifunctional fitness frames infringe a patent related to a reversible pedal structure.
• Technical Context: The technology relates to multi-purpose exercise equipment, often used in home gyms, which combines features like a squat rack with other exercise stations.
• Key Procedural History: The complaint notes that the validity of the patent-in-suit has never been challenged in court or at the United States Patent and Trademark Office.

Case Timeline

Date	Event
2023-06-22	’650 Patent Priority Date
2024-02-27	’650 Patent Issue Date
2025-12-12	Complaint Filing Date

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 (the "’650 Patent").

The Invention Explained

• Problem Addressed: The patent’s background section notes that on prior art multi-function fitness frames, fixed pedals used for certain exercises (like seated paddling) can interfere with other movements, such as standing stretching exercises, making the user experience "not smooth." (’650 Patent, col. 1:43-48).
• The Patented Solution: The invention is a pedal structure that can be moved between two distinct positions. The pedal rotates on a shaft, allowing it to be flipped up to lean against a support tube for use in paddling exercises or flipped down to lean against the ground for storage, thereby clearing space for other activities. (’650 Patent, Abstract; col. 2:63-65). This dual-functionality is intended to enhance the versatility of the fitness frame. (’650 Patent, col. 1:51-55).
• Technical Importance: The claimed solution seeks to improve the usability of all-in-one fitness equipment by allowing a component to serve its function when needed and be stowed unobtrusively when not in use. (’650 Patent, col. 2:1-4).

Key Claims at a Glance

• The complaint asserts independent claim 1. (Compl. ¶34, 38).
• The essential elements of independent claim 1 include:
  • A main frame, a pull ring, and a pedal arranged on the main frame "in a reversible manner."
  • A support tube and a rotating shaft that are penetrated on the main frame.
  • The pedal is configured to rotate around the rotating shaft to lean against the support tube to facilitate paddling.
  • The pedal is also configured to be rotated around the rotating shaft to lean against the ground to realize storage.

III. The Accused Instrumentality

Product Identification

• The complaint identifies the accused instrumentalities as "Unauthorized Products," which are multifunctional fitness frames sold by Defendants through e-commerce storefronts on platforms such as Amazon. (Compl. ¶4, 15, 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). The functionality is not described in detail, but the complaint asserts that the products incorporate the elements of claim 1 of the ’650 Patent. (Compl. ¶38). The complaint provides screenshot printouts from e-commerce stores as Exhibit 2, which it alleges show the accused products being offered for sale. (Compl. ¶22). Plaintiff alleges that the "flood of infringing products on the Amazon.com marketplace" has caused a drop in sales of its own patented commercial embodiment. (Compl. ¶12).

IV. Analysis of Infringement Allegations

The complaint references a claim chart in Exhibit 6, which was not attached to the filed complaint. (Compl. ¶34, 38). In lieu of a chart, the complaint’s narrative infringement theory alleges that the "Unauthorized Products" sold by the various defendants incorporate each element of claim 1 of the ’650 Patent, either literally or under the doctrine of equivalents. (Compl. ¶34, 40). The core of the allegation rests on the assertion that the accused products are "virtually identical" to one another and sourced from a common manufacturer, and that they possess the same features claimed in the patent. (Compl. ¶34). As evidentiary support for the sale of these products, the complaint references "screenshot printouts showing the active e-commerce stores' ordering pages." (Compl. ¶22).

Identified Points of Contention

• Scope Questions: A primary question may be whether the accused products, depicted in online listings, actually perform the specific two-mode function required by the claim (i.e., rotating to lean against a support tube for use and rotating to lean against the ground for storage). The infringement analysis may depend on whether the accused products’ pedal mechanisms operate in the claimed manner.
• Technical Questions: What evidence does the complaint provide that the accused products contain the specific internal components required by the claim, such as a "support tube" and a "rotating shaft" that enable the pedal's dual-position functionality? The allegations appear to be based on the external appearance of the products as shown in online marketplaces. (Compl. ¶34).

V. Key Claim Terms for Construction

• The Term: "in a reversible manner"
• Context and Importance: This term appears in claim 1 and describes the fundamental nature of the pedal arrangement. The construction of this term is central to the dispute, as it defines the core inventive concept. Practitioners may focus on this term because its scope will determine whether infringement requires the specific dual-position rotational mechanism disclosed in the patent or could cover a broader range of stowable pedal designs.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party could argue that the plain meaning of "reversible" is broad and could encompass any mechanism that allows the pedal to be moved from a use position to a stowed position and back. The patent's summary describes the pedal as simply "arranged on the main frame in a reversible manner." (’650 Patent, col. 2:62-63).
  • Evidence for a Narrower Interpretation: A party could argue that the claim itself gives "reversible manner" a more specific meaning. The claim proceeds to define this manner by requiring that the pedal rotates around a shaft to lean against two different structures (the support tube for use, the ground for storage). (’650 Patent, Claim 1). This suggests that "reversible manner" is not a general term but is explicitly defined by the specific functional limitations that follow it in the claim language.

VI. Other Allegations

Indirect Infringement

• The complaint alleges that Defendants are "working in active concert to knowingly and willfully manufacture, import, distribute, offer for sale, and sell infringing products." (Compl. ¶37). The prayer for relief also seeks to enjoin Defendants from "aiding, abetting, contributing to, or otherwise assisting anyone in infringing." (Compl., Prayer for Relief ¶1(b)). The factual basis alleged is a coordinated scheme wherein defendants source visually identical products from a common manufacturer. (Compl. ¶34, 39).

Willful Infringement

• The complaint alleges that "Defendants' infringement has been and continues to be willful." (Compl. ¶42). The complaint alleges that e-commerce operators like the defendants use tactics such as operating under multiple aliases and using websites like "sellerdefense.cn" to evade detection by intellectual property owners, which may be used to suggest knowledge of infringement risk. (Compl. ¶29, 31).

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

• A core issue will be one of claim scope: can the phrase "in a reversible manner," as defined by the subsequent limitations of Claim 1, be met by fitness frames with generally stowable pedals, or does it strictly require the specific disclosed mechanism of rotating on a shaft to lean against a support tube for use and against the ground for storage?
• A key evidentiary question will be one of proof of infringement: beyond visual similarity from e-commerce listings, what technical evidence will Plaintiff need to establish that the products sold by numerous distinct, anonymous online sellers each contain the specific internal structure (e.g., rotating shaft, support tube) and perform the precise dual-position functionality required by the asserted claim?