DCT

2:24-cv-00594

JFXD TRX ACQ LLC v. East River JW Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:24-cv-00594, W.D. Wash., 04/30/2024
  • Venue Allegations: Plaintiff alleges venue is proper in the Western District of Washington because Defendant sells the accused products in the district through Amazon.com and has entered into contracts with customers there.
  • Core Dispute: Plaintiff alleges that Defendant’s "Resistance Trainer Exercise Strap" products infringe a design patent covering an ornamental stitch pattern and a utility patent related to an inelastic exercise device with a limited range of motion.
  • Technical Context: The technology relates to bodyweight resistance training equipment, a significant segment of the consumer fitness market characterized by portable, strap-based systems.
  • Key Procedural History: The complaint alleges that Defendant is a "chronic and continued repetitive infringer" that has continued to sell the accused product despite receiving actual notice of the alleged infringement.

Case Timeline

Date Event
2007-09-17 U.S. Patent No. 7,762,932 Priority Date
2010-07-27 U.S. Patent No. 7,762,932 Issue Date
2016-12-09 U.S. Design Patent No. D831,764 Priority Date (Filing Date)
2018-10-23 U.S. Design Patent No. D831,764 Issue Date
2023-12-24 Accused Product (ASIN B0CQW53M4Z) First Available Date
2024-04-30 Complaint Filing Date

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

U.S. Patent No. 7,762,932: Inelastic Exercise Device Having a Limited Range

  • Patent Identification: U.S. Patent No. 7762932, titled "Inelastic Exercise Device Having a Limited Range," issued July 27, 2010.
  • The Invention Explained:
    • Problem Addressed: The patent background section describes issues with prior art exercise devices. It notes that devices using elastic bands provide inconsistent resistance and can "snap back," while devices with simple inelastic straps are "generally usable for a limited number of exercises." (’932 Patent, col. 1:26-40).
    • The Patented Solution: The invention is an inelastic, strap-based exercise device that allows for a controlled, limited range of longitudinal motion. The device features an elongated member with grips that passes through an anchor; a key component is a "limiter" that restricts how far the member can slide through the anchor. (’932 Patent, Abstract; col. 2:1-11). This design intends to provide the user with stability and support while preventing the excessive motion that could lead to imbalance. (’932 Patent, col. 14:48-54).
    • Technical Importance: This approach seeks to provide a safer and more versatile bodyweight training tool by combining the stability of a fixed inelastic strap with a degree of controlled movement, allowing a user to balance during exercise without risk of the strap sliding completely to one side. (Compl. ¶23).
  • Key Claims at a Glance:
    • The complaint asserts at least Claim 1. (Compl. ¶51; Compl., Ex. G).
    • Independent Claim 1 includes the following essential elements:
      • An exercise device attachable to a structure.
      • An inelastic elongated member having a length between a pair of grips.
      • An anchor attachable to the structure and having a support for the elongated member, wherein the member is movable through the anchor.
      • A limiter including at least one loop attached to the elongated member.
      • The limiter limits the movement of the position at which the elongated member contacts the support to a distance less than the total length between the grips.

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

  • Patent Identification: U.S. Design Patent No. D831764, titled "Flexible Strap with a Dual Stitch Pattern," issued October 23, 2018.
  • The Invention Explained:
    • Problem Addressed: Design patents protect ornamental appearance rather than function. The implicit problem is creating a visually distinct and non-obvious appearance for a component of an exercise product.
    • The Patented Solution: The patent claims the specific ornamental design of two parallel lines of stitching on a flexible strap, as depicted in the patent's figures. (’764 Design Patent, Claim; Figs. 1-3). The complaint notes this two-stitch design is distinctive compared to more common stitching patterns, such as a square with an "X" inside. (Compl. ¶22).
    • Technical Importance: The claimed design provides a specific aesthetic feature intended to be a source-identifying and distinctive visual element on the product.
  • Key Claims at a Glance:
    • The complaint asserts the single claim of the design patent. (Compl. ¶46; Compl., Ex. F).
    • The claim is for "The ornamental design for a flexible strap with a dual stitch pattrn [sic], as shown and described." (’764 Design Patent, Claim).

III. The Accused Instrumentality

Product Identification

  • The accused products are strap-based exercise devices sold by Defendant East River, primarily identified as the "Resistance Trainer Exercise Strap" available on Amazon.com. (Compl. ¶2). The complaint identifies a lead product by ASIN B0CQW53M4Z and alleges other similar products are sold under different ASINs. (Compl. ¶3, ¶13).

Functionality and Market Context

  • The Accused Product is a "bodyweight resistance training kit" that includes a main training strap, extension straps, handles with foot cradles, a door anchor, and a travel bag. (Compl., Ex. G, p. 124). It is marketed for full-body strength training and functions by allowing users to leverage their own body weight against the strap system, which can be anchored to a structure like a door. The complaint alleges it is a "directly competitive substitute product" for Plaintiff's own TRX® systems. (Compl. ¶33).

IV. Analysis of Infringement Allegations

D831,764 Infringement Allegations

The complaint alleges that the Accused Product incorporates the claimed ornamental design of the ’764 Design Patent. The infringement theory relies on a visual comparison between the patent figures and the Accused Product. A claim chart provided as Exhibit F in the complaint presents a side-by-side visual comparison of the patented dual stitch pattern and a photograph of the Accused Product. (Compl., Ex. F, p. 122). The chart highlights that the Accused Product features stitches of a different color (black) than the main strap (yellow) to "highlight the designs selected." (Compl., Ex. F, p. 122).

7,762,932 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
An exercise device attachable to a structure, said exercise device comprising: The Accused Product is an exercise device that includes a door anchor and extension straps for attachment to a structure like a door or ceiling. ¶51; Ex. G, p. 124 col. 1:53-56
an inelastic elongated member having a length between a pair of grips; The product includes an inelastic, strap-based elongated member with a pair of grips at the ends. ¶51; Ex. G, p. 125 col. 5:4-6
an anchor attachable to the structure and having a support for said inelastic elongated member... where, when said anchor is attached to the structure said support extends away from the structure... The product includes a door anchor (E) and a fixed anchor (F) that attaches to a structure and extends away from it to support the elongated member. ¶51; Ex. G, p. 126 col. 6:1-12
said elongated member is movable through said anchor such that the distance between each of said pair of grips and said support is adjustable by pulling one...of said pair of grips away from said anchor; The system includes an opening ("slice" G) at the connection point with a loop (I) that allows the strap to move left and right, adjusting the distance from the anchor. ¶51; Ex. G, p. 127 col. 5:30-36
a limiter including at least one loop attached to said elongated member...where said limiter limits the movement...to a distance less than said length between said pair of grips The portion [H] at the central connection point is alleged to be limited on both sides, restricting the movement of the loop [I] to a distance of a "couple of inches." ¶51; Ex. G, p. 128 col. 14:36-47
  • Identified Points of Contention:
    • ’764 Design Patent: The central dispute will likely be the application of the "ordinary observer" test. A court will need to determine if an ordinary observer, familiar with prior art designs, would be deceived into believing the Accused Product's design is the same as the patented design. The analysis may focus on whether the overall visual impression of the stitch pattern on the product is substantially the same, despite any minor differences or the context of the larger product.
    • ’932 Patent: A primary technical question will be whether the central connection point of the Accused Product, identified as portion [H] and loop [I] in the claim chart, functions as a "limiter" as required by the claim. (Compl., Ex. G, p. 128). The analysis will question whether this structure is specifically designed to limit the range of motion for safety and balance, as described in the patent, or if any restriction of movement is merely an incidental property of a standard strap junction.

V. Key Claim Terms for Construction

For U.S. Patent No. 7,762,932:

  • The Term: "limiter"
  • Context and Importance: This term is the central technical feature of Claim 1 that distinguishes the invention from a simple strap passing through an anchor. The infringement determination for the ’932 Patent will likely depend entirely on whether the Accused Product is found to have a "limiter."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party could argue for the plain and ordinary meaning, suggesting that any component that limits the sliding movement of the elongated member qualifies. The claim itself broadly recites "a limiter including at least one loop attached to said elongated member." (’932 Patent, col. 24:40-42).
    • Evidence for a Narrower Interpretation: A party could argue that the specification defines "limiter" by its function and specific embodiments. The patent describes the limiter as a feature that "permits a limited range of longitudinal motion" for user support and to "prevent further movement of the grips." (’932 Patent, col. 13:51-61). The detailed description of embodiment 3621 shows a distinct loop (3622) stitched onto the main strap (429) for this purpose, which a court may see as defining the scope of the term. (’932 Patent, col. 14:36-47).

VI. Other Allegations

  • Indirect Infringement: The complaint makes general allegations of induced and contributory infringement for both patents, stating East River "has induced others to infringe" and "has committed acts of contributory infringement." (Compl. ¶46, ¶51).
  • Willful Infringement: Willfulness is alleged for both patents. The complaint bases this on the assertion that East River knew of TRX as a "market leader" and had "actual and/or constructive notice of TRX's patents." (Compl. ¶49, ¶54).

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

This dispute presents two distinct infringement questions, one turning on visual appearance and the other on technical function and claim construction.

  • A central issue for the ’764 design patent will be one of ornamental identity: would an ordinary observer, taking into account the prior art, find the dual-stitch pattern on the Accused Product to be substantially the same as the claimed design, or do differences in the overall product and context create a distinct visual impression?
  • A key question for the ’932 utility patent will be one of definitional scope: does the term "limiter," as used in Claim 1, cover any structure that incidentally restricts a strap's movement at a central anchor point, or is it limited by the patent's specification to a distinct component added specifically to provide a controlled and limited range of motion for safety and balance?