2:25-cv-00792
Liu v. Unincorp Associations
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Case Identification: 2:25-cv-02296, E.D. Va., 12/09/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendants are not residents of the United States and are subject to personal jurisdiction in the district, or alternatively, because Defendants are aliens engaged in infringing acts causing harm within the district.
- Core Dispute: Plaintiff alleges that numerous unidentified e-commerce operators are selling multifunctional fitness frames that infringe a patent related to a reversible pedal structure.
- Technical Context: The technology concerns home and commercial fitness equipment, specifically multi-purpose exercise frames or "power racks" that combine multiple workout functions into a single apparatus.
- Key Procedural History: The complaint does not mention prior litigation, licensing history, or post-grant proceedings concerning the patent-in-suit. The case is structured as an enforcement action against 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 (Filing 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.
The Invention Explained
- Problem Addressed: The patent's background section describes a problem with prior art multifunctional fitness frames where fixed pedals, used for exercises like simulated paddling, interfere with other movements, such as standing stretching exercises. This interference can make the user's exercise process "not smooth and reduce it." (’650 Patent, col. 1:40-49).
- The Patented Solution: The invention is a pedal assembly for a fitness frame that is "arranged on the main frame in a reversible manner" (’650 Patent, Abstract). The pedal can be rotated around a shaft into two distinct positions: (1) turned over to lean against a support tube, creating an angled platform for a user's feet during paddling exercises, and (2) turned over further to lean against the ground, effectively storing it out of the way to create space for other standing exercises (’650 Patent, col. 2:1-4; col. 3:32-40; col. 3:49-54). This dual-position functionality is the core of the claimed solution.
- Technical Importance: The design purports to enhance the utility of multi-purpose fitness equipment by allowing a single component—the pedal—to be easily reconfigured between an active-use position and a stored position without removal, thereby improving the user experience for different types of workouts (’650 Patent, col. 1:50-55).
Key Claims at a Glance
- The complaint asserts infringement of at least independent claim 1 (Compl. ¶¶34, 38).
- Independent Claim 1:
- A multifunctional fitness frame with a reversible pedal structure, comprising: a main frame, a pull ring arranged on the main frame, and a pedal arranged on the main frame;
- wherein the pedal is arranged on the main frame in a reversible manner, and a support tube and a rotating shaft are penetrated on the main frame;
- the pedal is rotated around the rotating shaft and leans against the support tube so as to facilitate a user to practice paddling;
- the pedal is also rotated around the rotating shaft and leaned against the ground through the rotating shaft to realize storage, so as to facilitate the user to practice other actions.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are referred to as "Unauthorized Products," specifically multifunctional fitness frames sold by the unidentified Defendants through e-commerce storefronts on platforms including Amazon.com and Walmart (Compl. ¶¶6, 22).
Functionality and Market Context
The complaint alleges the Unauthorized Products are "virtually identical in appearance" to one another and "share the same claimed features of the Patent-in-Suit" (Compl. ¶34). The functionality at issue is a "multifunctional fitness frame with reversible pedal structure" (Compl. ¶40). The complaint includes "screenshot printouts showing the active e-commerce stores' ordering pages" as Exhibit 2, which allegedly depict the accused products for sale in the district (Compl. ¶¶22, 26). Plaintiff alleges that the popularity of its own commercial embodiment led to a "flood of infringing products on the Amazon.com marketplace" (Compl. ¶12).
IV. Analysis of Infringement Allegations
The complaint references a claim chart in its Exhibit 6, which was not publicly available for review (Compl. ¶38). The narrative infringement theory presented is that Defendants make, import, offer for sale, and sell products that "incorporate each of the elements claimed in claim 1 of the Patent-in-Suit" (Compl. ¶38). The complaint alleges that the accused products are "substantially the same" and sourced from a common manufacturer, thereby infringing the ’650 Patent directly or under the doctrine of equivalents (Compl. ¶¶34, 40). The complaint's visual evidence, referenced as "screenshot printouts" in Exhibit 2, allegedly shows the accused products being offered for sale (Compl. ¶22).
Identified Points of Contention
- Technical Questions: The complaint's allegations are conclusory and lack specific technical detail about how the accused products operate. A primary question will be whether the accused products actually perform the dual-position function required by claim 1: can their pedals both (1) lean against a support tube for paddling and (2) lean against the ground for storage? The complaint does not provide evidence, such as diagrams or user manuals for the accused products, to substantiate this specific functionality.
- Scope Questions: The infringement analysis will depend on the construction of "reversible manner." The dispute may question whether any pedal that moves is "reversible," or if the term requires the specific dual-purpose functionality of being positionable for both active use (paddling) and storage, as described in the specification.
V. Key Claim Terms for Construction
The Term
"arranged on the main frame in a reversible manner"
Context and Importance
This term is central to the invention's novelty. Its definition will determine whether the claim covers any pivoting pedal or is limited to one that can be specifically reconfigured between the paddling and storage positions. The infringement case hinges on whether the accused products' pedal mechanisms fall within the scope of this term.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The plain meaning of "reversible" could suggest any structure capable of being turned back and forth. An argument for a broader scope might focus on the general concept of a movable pedal without being tied to its specific resting positions.
- Evidence for a Narrower Interpretation: The specification repeatedly and explicitly defines the "reversible manner" by its function: "the pedal is turned over by the rotating shaft and leans against the support tube to facilitate the user to practice paddling; and the pedal can also be turned over and leaned against the ground by the rotating shaft to realize storage" (’650 Patent, Abstract; col. 2:1-4). This language, which is mirrored in claim 1 itself, provides strong evidence that the term is not merely structural but is defined by these two distinct functional outcomes.
VI. Other Allegations
Indirect Infringement
The complaint does not plead specific facts to support claims of induced or contributory infringement, such as knowledge of the patent combined with specific acts encouraging infringement by others. The prayer for relief includes a request to enjoin "aiding, abetting, contributing to, or otherwise assisting anyone in infringing" (Compl. Prayer ¶1(b)).
Willful Infringement
The complaint alleges that Defendants' infringement "has been and continues to be willful" and that they have "knowingly and willfully infringed the Patent-in-Suit" (Compl. ¶¶33, 42). The basis for this allegation appears to be the assertion that Defendants are part of a coordinated, ongoing scheme to sell infringing products sourced from a common manufacturer (Compl. ¶¶33-34, 39).
VII. Analyst’s Conclusion: Key Questions for the Case
A core issue will be one of definitional scope: Will the term "reversible manner" be construed narrowly to require the specific dual-position functionality of resting against a support tube for use and resting against the ground for storage, as detailed in the patent's specification and recited in claim 1? Or could it be interpreted more broadly to cover any pivoting pedal on a fitness frame?
A key evidentiary question will be one of technical proof: Can the Plaintiff produce sufficient evidence to demonstrate that the accused products, sold by a diffuse network of anonymous online sellers, actually operate in the specific manner required by the asserted claim? The case may depend on whether discovery can link the products shown in e-commerce screenshots to a design that practices the claimed two-position reversible pedal mechanism.