By Robert E. Freeman, with Gabriella G. Joaquim, Leah S. Taylor and Bertrand D. Li, of Proskauer
In late May, a workout equipment patent holder, PowerBlock Holdings, Inc. (“PowerBlock”), got a lift after it reached a settlement with fitness hardware maker iFIT, Inc. (“iFIT”), resolving their adjustable dumbbell patent infringement dispute. The settlement follows the Federal Circuit’s 2025 decision in PowerBlock Holdings, Inc. v. iFIT, Inc., 146 F.4th 1366 (Fed. Cir. 2025), which reversed a district court ruling that had invalidated most asserted claims as abstract under the Supreme Court’s Alice standard.
PowerBlock sells home fitness equipment, with a focus on adjustable dumbbells built for home gyms that let users save space by owning a compact modular set with selector pins to increase weight for different exercises instead of having to maintain a rack of separate dumbbells or plates. iFIT is a health and wellness platform known for connected fitness hardware and software, including products sold under brands such as NordicTrack. The dispute centered on PowerBlock’s U.S. Patent No. 7,578,771 (the “‘771 patent”), titled “Weight Selection and Adjustment System for Selectorized Dumbbells Including Motorized Selector Positioning.” The ‘771 patent claims a system in which an electric motor physically adjusts how many weight plates are coupled to a dumbbell handle. Defendant iFIT is a competitor of PowerBlock in the adjustable dumbbell product space and, at the time of the suit filing, sold the NordicTrack iSelect Adjustable Dumbbells. According to PowerBlock, the NordicTrack adjustable dumbbells at issue also contained a “selectorized dumbbell” with a handle, plates, and an electric motor that causes the plates to be coupled. [See images below from the complaint: an example of PowerBlock’s adjustable dumbbells on the left, iFIT’s on the right].
In February 2022, PowerBlock sent a cease-and-desist letter to iFIT claiming infringement of at least Claim 20 of its ‘771 patent. Thereafter, in October 2022 PowerBlock sued iFIT in the District of Utah, alleging infringement of the ‘771 patent and violation of Utah’s Unfair Competition Act. iFIT responded with an early eligibility challenge under 35 U.S.C. § 101, arguing that the asserted claims were invalid for claiming the abstract idea of automated weight stacking under the Alice standard.iFIT argued that the ‘771 patent is merely a “simple combination of conventional, generic, off-the-shelf components that are merged to automate a practice that, for many years, has been performed manually” and that “the idea of performing an electronic weight adjustment action on a selectorized dumbbell is an abstract idea.”
In September 2023 the district court mostly agreed on the patent issue, holding that claims 1-18 and 20 were patent-ineligible subject matter because “those claims do not add significantly more than the abstract idea of the end-result of an automated selectorized dumbbell.”
During the second set, the Federal Circuit reversed. The key issue on appeal was whether the ‘771 patent merely claimed the abstract idea of automating weight selection or instead claimed a concrete mechanical implementation of that abstract idea.
35 U.S.C. § 101 permits patents for any new and useful “process, machine, manufacture, or composition of matter,” as well as improvements to those categories. But courts have long recognized implicit exceptions for laws of nature, natural phenomena, and abstract ideas. Whether Plaintiff states a viable claim is a matter of whether the claims of the ‘771 patent are patent eligible under 35 U.S.C. §101 as interpreted by the two-step test established by the Supreme Court in Alice. At step one, courts ask whether the claims are “directed to a patent-ineligible concept.” If not, the claims satisfy § 101 and the second step is not necessary. If so, step two asks whether the remaining claim elements add an “inventive concept” sufficient to transform the claim into a patent-eligible application, such as a specific means or method that improves the relevant technology rather than simply being directed to a result or effect that itself is the abstract idea.
The policy concern underlying the Alice framework is preemption: a patent should not lock up the basic tools of scientific and technological work by claiming an abstract idea, law of nature, or natural phenomenon itself. At the same time, the Supreme Court has stated that patents may protect concrete, inventive applications of those basic building blocks.
That distinction drove the Federal Circuit’s decision. The court held that Claim 1 (concerning the basic plates and motorized parts of a selectorized dumbbell) was not directed to an abstract idea because it was limited to a specific implementation of a technological improvement to a mechanical system: a selectorized dumbbell with nested left and right weight plates, a handle, a movable selector with different adjustment positions, and an electric motor operatively connected to the selector.
In determining that the ‘771 patent cleared step one of Alice, the Federal Circuit concluded that the claims contained enough structure and specificity to claim a particular technological improvement to selectorized dumbbells. In the court’s words, this “rather simple mechanical invention” went beyond the broad concept of automating a known technique and described a sufficiently specific manner of performing automated weight stacking.
Because the Federal Circuit found the claims eligible at Alice step one, it did not reach step two. Claims 2-18 and 20 rose or fell with Claim 1 because the parties did not argue them separately. The court therefore reversed the district court’s ineligibility ruling and remanded, eventually nudging the parties toward their recent settlement.
The PowerBlock ruling gives patent owners a useful example of how mechanical automation claims can survive Alice when they contain enough specificity and structure and include a concrete structural improvement that performs the work. For an area of patent law that remains judge-made, fact-sensitive, and sometimes murky, PowerBlock is an uncommon §101 win from the Federal Circuit, and one with enough practical weight to move the parties from dismissal to settlement.
