DCT

2:23-cv-00298

JFXD TRX ACQ LLC v. CrankIt Intl Pty Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:23-cv-00298, W.D. Wash., 03/03/2023
  • Venue Allegations: Venue is based on Defendant’s sales of the accused product into the judicial district through Amazon.com and other websites, and its alleged consent to jurisdiction by contracting with customers in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s "CrankIt Home Straps" suspension trainer infringes one design patent and two utility patents related to modular, strap-based exercise equipment.
  • Technical Context: The technology resides in the field of suspension training, a form of resistance exercise where an individual's body weight is used to perform various strength-training movements via a system of straps and handles.
  • Key Procedural History: The complaint alleges that the patents' previous owner, Fitness Anywhere LLC, notified Defendant of infringement around 2017 and engaged in unsuccessful redesign discussions. Plaintiff JFXD TRX ACQ LLC acquired the patents in August 2022 and alleges that Defendant's infringement is ongoing and willful.

Case Timeline

Date Event
2016-11-22 Priority Date for '413 and '334 Patents
2016-12-09 Filing Date for '764 Design Patent
In or about 2017 Previous patent owner notified CrankIt of infringement
2018-10-23 U.S. Design Patent No. D831,764 Issued
2020-12-08 U.S. Patent No. 10,857,413 Issued
2022-08-02 U.S. Patent No. 11,400,334 Issued
2022-08-26 Asserted Patents assigned to Plaintiff
January 2023 Alleged infringement continued despite notice
2023-03-03 Complaint Filed

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

U.S. Design Patent No. D831,764 - Flexible Strap with a Dual Stitch Pattern

Issued October 23, 2018

The Invention Explained

  • Problem Addressed: Design patents do not solve technical problems; they protect the ornamental, non-functional appearance of an article of manufacture.
  • The Patented Solution: The patent protects the specific visual appearance of a section of a flexible strap. The claimed design consists of the ornamental features of the strap being folded back on itself to form a loop, which is then secured by two prominent, parallel lines of stitching (D'764 Patent, FIG. 1-3). The design is defined by the combination and interrelationship of these visual elements.
  • Technical Importance: Not applicable; the value is in the distinctiveness of the aesthetic design.

Key Claims at a Glance

  • The patent asserts a single claim for "The ornamental design for a flexible strap with a dual stitch pattern, as shown and described" (D'764 Patent, Claim).
  • The complaint alleges infringement of at least one claim (Compl. ¶27).

U.S. Patent No. 10,857,413 - Apparatus, Kit, and Method for Performing Strap-Based Exercises

Issued December 8, 2020

The Invention Explained

  • Problem Addressed: The patent's background section identifies a need for a single resistance exercise device that is highly versatile, modular, strong, and reliable, addressing the limitations of prior art devices that were often usable for only a limited number of exercises or with specific types of support structures ( '413 Patent, col. 1:36-54).
  • The Patented Solution: The invention is a modular strap-based exercise system centered around an "infinity loop," which is a connector component formed by folding a single elongated member into a stack of three distinct loops ('413 Patent, FIG. 5-6). This multi-loop structure allows for various components, such as handgrips or anchor straps, to be attached in different configurations, thereby increasing the system's versatility ('413 Patent, Abstract; col. 7:4-15).
  • Technical Importance: This modular design using a specific multi-loop connector offers users greater flexibility to adapt the equipment for a wider range of exercises and anchor points compared to more static, single-configuration designs ('413 Patent, col. 9:4-10).

Key Claims at a Glance

  • The complaint asserts at least one claim, and independent apparatus claim 4 is representative ('413 Patent, col. 11:46-col. 12:5; Compl. ¶32).
  • The essential elements of independent claim 4 include:
    • An elongated member with a pair of ends.
    • A first loop and a second loop formed by folding first and third portions of the elongated member against a second portion.
    • A third loop formed by folding a fourth portion of the elongated member against the third portion.
    • An attachment mechanism secured to the first loop.
    • A grip secured to the second loop by a supporting member.
  • The complaint does not specify if it will assert dependent claims.

U.S. Patent No. 11,400,334 - Exercise Device with a Pair of Handgrip Assemblies

Issued August 2, 2022

  • Patent Identification: U.S. Patent No. 11,400,334, "EXERCISE DEVICE WITH A PAIR OF HANDGRIP ASSEMBLIES," issued August 2, 2022 (Compl. ¶17).
  • Technology Synopsis: This patent describes an exercise device comprising a pair of distinct handgrip assemblies. Each assembly is designed to attach to a support structure via its own separate anchor, enabling exercises like pull-ups or dips where the hands are positioned apart. Each assembly features a combination grip (for hands and feet) connected to a strap with multiple loops for connection and adjustment ('334 Patent, Abstract; col. 10:9-25).
  • Asserted Claims: The complaint asserts "at least one claim," with Claim 1 being the sole independent claim ('334 Patent, col. 10:11-25; Compl. ¶37).
  • Accused Features: The complaint accuses the "CrankIt Home Straps" product, which is alleged to function as a pair of handgrip assemblies that can be jointly used as an exercise device (Compl. ¶¶2, 37).

III. The Accused Instrumentality

Product Identification

The "CrankIt Home Straps" product, described as a bodyweight resistance training system (Compl. ¶¶2, 5).

Functionality and Market Context

The Accused Product is a suspension training system sold in the United States via online channels, including Amazon.com (Compl. ¶¶2, 9). It is alleged to provide functionality similar to Plaintiff's TRX® brand products, allowing users to perform exercises using their own body weight for resistance (Compl. ¶¶13-14, 23). The complaint alleges that the Accused Product directly competes with Plaintiff's own exercise systems (Compl. ¶23). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references preliminary claim charts in Exhibits E and F, which were not included in the provided filing. The infringement analysis is therefore based on the narrative allegations.

D'764 Patent Infringement Allegations

The complaint alleges that the Accused Product infringes the '764 design patent because its overall ornamental appearance is substantially the same as the claimed design, such that it would deceive an ordinary observer (Compl. ¶27). The infringement theory centers on the visual similarity between the Accused Product's strap-and-stitching configuration and the design claimed in the '764 Patent, which is characterized by a folded-over loop secured with a prominent dual stitch pattern (D'764 Patent, FIG. 1).

'413 Patent Infringement Allegations

The complaint alleges that the Accused Product includes each element of at least one claim of the '413 Patent (Compl. ¶32). The narrative infringement theory suggests that the Accused Product is a modular exercise apparatus that incorporates a connector component structurally and functionally equivalent to the patent's "infinity loop." This allegedly infringing connector is used to link the system's handgrips and anchor straps in a manner that reads on the specific multi-loop geometry described in an independent claim such as Claim 4 ('413 Patent, col. 11:46-col. 12:5).

Identified Points of Contention

  • Scope Questions (Design): The infringement analysis for the D'764 patent will turn on the "ordinary observer" test. A key question will be whether the overall visual impression of the Accused Product's strap is substantially the same as the patented design, or if differences in proportion, stitch appearance, or other features are sufficient to distinguish them.
  • Technical Questions (Utility): For the '413 Patent, a primary question will be one of structural correspondence. What evidence demonstrates that the accused connector is formed from a "single elongated member" that is folded to create the specific first, second, and third loops as recited in Claim 4? The court will need to examine if the accused device meets this precise geometric and topological definition.

V. Key Claim Terms for Construction

Analysis based on independent claim 4 of the ’413 Patent.

Term: "elongated member"

  • Context and Importance: The claim requires the entire multi-loop structure to be formed from a single "elongated member." The construction of this term is critical because it will determine whether a connector made from multiple pieces of material that are stitched or glued together can literally infringe the claim.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification states, "It is to be understood that a single length of flexible material can alternatively comprise two or more pieces that are stitched, glued, or otherwise attached to one another" ('413 Patent, col. 6:21-25). This passage may support a construction where "elongated member" includes composite structures.
    • Evidence for a Narrower Interpretation: The figures illustrating the embodiment, particularly FIG. 6, depict the "infinity loop" (502) as being formed from what appears to be a single, continuous, unitary piece of webbing (510). This could support an argument that the term should be limited to a monolithic component.

Term: "a second loop formed by folding a third portion of said elongated member against said second portion of said elongated member"

  • Context and Importance: This term defines the specific geometric creation of the central loop in the claimed three-loop connector. Infringement will depend on whether the accused product's connector loop is formed with this exact topological relationship between its constituent strap sections.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The language could be interpreted functionally, focusing on the end result of a folded-against configuration rather than the precise method of achieving it.
    • Evidence for a Narrower Interpretation: The language is highly specific, defining a relationship between a "third portion" and a "second portion." A defendant could argue its product avoids infringement if its loop is formed differently—for example, if a third portion is folded against a distinct fourth portion, or if the layers of the strap are stacked in an order different from that shown in Figure 6 ('413 Patent, FIG. 6).

VI. Other Allegations

Indirect Infringement

The complaint includes allegations of induced and contributory infringement for all asserted patents (Compl. ¶¶ 27, 32, 37). However, it does not plead specific facts to support these claims, such as referencing user manuals or other instructions that would encourage infringing use, beyond the general acts of marketing and selling the Accused Product.

Willful Infringement

The complaint makes a detailed allegation of willfulness. It asserts that Defendant had actual notice of infringement from the patents' predecessor-in-interest as early as 2017, engaged in discussions about the infringing products, and yet continued to sell them (Compl. ¶¶ 19-20, 30). This alleged pre-suit knowledge forms the primary basis for the willfulness claim and the associated request for enhanced damages.

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

  • A core issue will be one of willfulness based on prior notice: a central question for trial will be whether the alleged 2017 notification from Plaintiff's predecessor put Defendant on notice of infringement, and whether its subsequent conduct rises to the level of willful infringement, potentially exposing it to treble damages.
  • A key evidentiary question will be one of structural correspondence: for the utility patents, the outcome will depend heavily on a factual comparison of whether the accused "CrankIt Home Straps" contains a multi-loop connector and handgrip assemblies that meet the precise geometric and relational limitations recited in the asserted claims.
  • For the design patent, the case will turn on a question of ornamental similarity: does the overall visual appearance of the accused strap's stitch pattern create an impression on the ordinary observer that is substantially the same as the patented design, or are the designs plainly dissimilar?