A claim reciting a motor that physically moves a dumbbell's weight selector is a machine, not an abstract idea

2025-08-11Fed. Cir.

PowerBlock Holdings, Inc. v. iFit, Inc., No. 2024-1177 (Fed. Cir. Aug. 11, 2025) (precedential) (Stoll, J., joined by Taranto, J., and Scarsi, District Judge, sitting by designation), reversing PowerBlock Holdings, Inc. v. iFit, Inc., No. 1:22-cv-00132-JNP-CMR (D. Utah Sept. 29, 2023) (Parrish, J.)

United States Patent No. 7,578,771 claims a weight selection and adjustment system. Claim 1 recites a selectorized dumbbell with nested left and right stacks of weight plates, a handle, and a movable selector whose adjustment positions couple selected numbers of plates to each end, together with an electric motor "operatively connected to the selector" that "physically moves the selector into the adjustment position corresponding to the desired exercise weight." Claim 20 adds a data entry device through which the user inputs a weight selection that controls the motor. Judge Jill Parrish of the District of Utah dismissed claims 1 through 18 and 20 under Rule 12(b)(6) as directed to the abstract idea of automated weight stacking under Section 101 of Title 35 of the United States Code. The Federal Circuit reversed at step one. Claim 1 is "limited to a specific implementation of a technological improvement" to selectorized dumbbells and is "directed to an eligible mechanical invention," unlike the "do it on a computer" claims in University of Florida Research Foundation v. General Electric and the Chamberlain v. Techtronic claims, which did not recite the barrier they controlled. Citing Diamond v. Diehr, the panel declined to ignore limitations found in the prior art, and it cautioned against conflating novelty and obviousness with step one. Claims 2 through 18 and 20, not argued separately, stood with claim 1.

What it changesMachine learning in a physical product, in robotics, vehicles, medical devices or industrial control, is claimable at step one when the claim recites the machine the model acts on and the actuator that does the acting. A claim that says a controller issues a command based on a model's output, without the structure that receives it, reads like Chamberlain; a claim that names the mechanism, its coupling and the physical movement reads like this one. Draft the independent claim to include the plant, the actuator, the coupling and the physical result, and put the model's role in the step that selects the movement. In prosecution and litigation, Diehr is now applied in a precedential opinion against the argument that conventional components can be stripped out before asking what a claim is directed to, and that argument belongs under novelty and obviousness. The panel noted that this was a simple mechanical invention, decided on a motion to dismiss.

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Burbage Law is the practice of Jon Burbage, a registered patent attorney. 342 United States patents have issued from applications he wrote; the full list is on the Patents page. More about Jon Burbage.

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