POWERbahn, LLC v. Foundation Fitness, LLC et al, 3-15-cv-00327 (NVD August 11, 2016, Order) (Du, USDJ)
Tuesday, August 16, 2016
Exercise Equipment Patents Not Invalid Under 35 U.S.C. § 101
The court denied defendants' motion for judgment on the pleadings that plaintiff's exercise equipment patents encompassed unpatentable subject matter and found that the claims were not directed toward a law of nature or abstract idea. "Defendants argue that claim 16, and [one patent-in-suit] as a whole, are drawn to laws of nature, specifically focusing on the haptic equation mentioned in the last line of claim 16. This argument either grossly misreads the claims in the patent or stretches the rule in [Alice Corp. Pty. v. CLS Bank Int'l, 134 S. Ct. 2347 (2014)] beyond recognition. While it is true that the claim includes a formula, the claim is clearly directed at a piece of exercise equipment, and the formula is simply one part of the overall scheme. Including a law of nature as one part of a claim does not transform the entire scheme into an abstract idea. . . . The method claim in [another patent-in-suit] is a closer call. . . . However . . . the nature of the method claim is the operation of a piece of exercise equipment, like a treadmill, elliptical, or stationary bike, in order to simulate the conditions of running or biking outdoors. Unlike other patents which were determined to be directed at abstract concepts, the [patent] is aimed at a 'particular concrete or tangible form.'. . . It describes a way of running a specific type of machine in order to achieve a particular type of training. This is not the type of broad idea that threatens to monopolize 'basic tools of scientific and technological work' or 'the building blocks of human ingenuity.'"