On August 11, in Powerblock Holdings, Inc. v iFit, Inc., the Federal Circuit offered at least two observations that can benefit patentees seeking patent protection for inventions involving software. First, the court noted that, notwithstanding the presence of software, the claim at issue is limited to a particular physical configuration of a tangible machine that performs a useful task. And second, the court reminded the reader that claims should be read as a whole and that one should not ignore old elements in the claim when assessing patent eligibility.
The invention in Powerblock relates to an automated selectorized dumbbell system. The system uses nested weight plates on each side and a movable selector to choose how many plates attach to the handle, thereby setting the weight. An electric motor, operatively connected to the selector and controlled by software, moves the selector to a desired position based on user input, thereby automating weight adjustment without requiring manual pin pulling.
The presence of the electric motor integrated into the dumbbell’s weight-selection mechanism was a key differentiator. The claims do not just say “adjust weight automatically.” Instead, the claims recite a motorized selector system to do so. This concrete implementation meant the claims “go beyond the broad concept of automating a known technique” and specified a particular way to achieve the result. These concrete limitations provided “meaningful boundaries on how the automation is achieved,” rather than merely claiming the concept of automation itself. The court emphasized that the claimed invention is a tangible machine performing a useful task, akin to an improved exercise device, and not just a disembodied idea or software routine.
The court also cautioned against oversimplifying claims or disregarding claim elements when conducting a § 101 analysis. iFit had argued that the patent simply combined known dumbbell parts with functional language. The court rejected this, cautioning that one should not dissect claims into old vs. new elements and then ignore the old elements. Even conventional components, when arranged in a new way, must be considered as part of the whole. Here, the combination of known weight plates and selectors with a motor was new and specific enough to define a patent-eligible invention.
This decision demonstrates that courts are more likely to uphold inventions that automate manual processes as patent-eligible machines when the claims are directed to a specific apparatus and that emphasize technological improvements and structures that achieve a desired result. Improvements in existing mechanical technology can fall within the scope of patentable subject matter even when they incorporate automation. This case is a useful precedent for overcoming abstract idea challenges, perhaps especially for hybrid innovations that straddle the line between software and hardware.
Powerblock reminds us that the patent system can indeed protect concrete technical solutions—even ones that make our dumbbells smarter.
