In PowerBlock Holdings Inc. v. iFIT Inc., No. 2024-1177 (Fed. Cir. Aug. 11, 2025) the Federal Circuit reversed a lower court grant of a motion to dismiss and held that claims for adjustable dumbbells were not ineligible under 35 U.S.C. §101.
PowerBlock asserted U.S. Patent No. 7,578,771, which covers dumbbells with automated weight adjustment in the District of Utah. On iFit's motion to dismiss under §101, the district court found certain claims directed to the abstract idea of automated weight stacking without any meaningful limitations, which would "preempt any weight selection and stacking system." It also determined the non-abstract elements did not add significantly more.
The Federal Circuit disagreed, finding the claims directed to a sufficiently specific mechanical invention, not an abstract idea. The Court noted the independent claim provided meaningful limitations, explaining it is limited to a particular type of dumbbell and requires an electric motor "operatively coupled to the selector" that physically moves the weight selector. The Court rejected iFit's argument that the patent did not explain how the system improves dumbbell technology, instead finding the motor coupled to a movable selector was sufficiently specific.
The Federal Circuit also rejected iFit's urgings to ignore limitations that recited known prior art elements during the abstract idea inquiry. The Court cautioned against oversimplifying claims, noting the proper § 101 inquiry addresses the claim as a whole.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
