PowerBlock Holdings, Inc. v. iFit, Inc., No. 2024-1177 (Fed. Cir. (D. Utah) Aug. 11, 2025). Opinion by Stoll, joined by Taranto and Scarsi (sitting by designation).
PowerBlock sued iFit for infringement of a patent directed to an integrated system for selecting and adjusting the weight of a selectorized dumbbell. iFit moved to dismiss the complaint for failure to state a claim, arguing that the claims are patent ineligible under 35 U.S.C. § 101.
The district court determined that all claims but one are ineligible. In finding most claims ineligible, the district court ruled under Alice step one that the claims are directed to the abstract idea of automated weight stacking. Next, the district court determined under Alice step two that nothing transformed the claims into something other than the abstract idea itself. PowerBlock appealed.
The Federal Circuit reversed because the claims are “not directed to an abstract idea.” Instead, the claims are “limited to a particular type of dumbbell: a selectorized dumbbell with a stack of nested left weight plates, a stack of nested right weight plates, a handle, and a movable selector with different adjustment positions, where moving the selector to different adjustment positions changes the number of left and right weight plates coupled to the dumbbell.” The claims also recite an electric motor that “physically moves the selector into different adjustment positions.” The Federal Circuit ruled that these claim limitations “provide enough specificity and structure to satisfy § 101.”
The Federal Circuit distinguished several cases relied on by the district court and iFit, ultimately concluding that considering the claims in their entirety, they are “directed to a sufficiently specific mechanical invention that, as a whole, advantageously automates selectorized dumbbell weight stacking.” Because the claims are not directed to an abstract idea under Alice step one, the Federal Circuit did not reach Alice step two.
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Laboratory Corp. of America Holdings, et al. v. Qiagen Sciences, LLC, et al., No. 2023-2350 (Fed. Cir. (D. Del.) Aug. 13, 2025). Opinion by Lourie, joined by Dyk and Cunningham.
Labcorp sued Qiagen for infringement of two patents directed to methods for preparing DNA samples for sequencing through enrichment techniques involving amplifying regions of interest using various types of primers. The jury found infringement of several claims in both patents, found that Qiagen proved none of those claims invalid, and awarded damages. Following the jury verdict, the district court denied Qiagen’s post-trial motion for judgment as a matter of law (JMOL) as to noninfringement, invalidity, and damages. Qiagen then appealed.
The Federal Circuit reversed as to infringement and thus did not reach Qiagen’s challenges on validity and damages.
For the first patent, the jury found infringement under the doctrine of equivalents, and Qiagen raised two arguments on appeal. First, Qiagen contended that it was error for the district court to allow the jury to apply a “plain meaning” of the claims such that claim language requiring one sequence to be “identical” to another sequence had the exact same meaning as claim language requiring one sequence to be “identical to a portion of” another sequence. The Federal Circuit ruled that “it was error for the district court to turn a matter of claim construction over to the jury to decide as a factual dispute.” The court explained that “as a matter of claim construction, ‘identical’ cannot mean ‘identical to a portion’ because ‘identical’ means the same.” Also, the specification and claims differentiated the two terms according to their degree, and the Federal Circuit stated that “a proper construction should give effect to that difference.”
Second, Qiagen argued that no reasonable jury could have found that the accused “sample index primer” (SIP) satisfies a “second target-specific primer” requirement in certain claims. Qiagen argued that the accused SIP does not infringe under the doctrine of equivalents because it fails all three prongs of the function-way-result test. The Federal Circuit agreed, ruling that the evidence presented to the jury did “not rise to the level of ‘particularized testimony and linking argument’ showing substantial similarity between the accused products and asserted claims in function, way, or result.”
Turning to the second patent, the Federal Circuit again ruled “there was insufficient evidence from which a reasonable jury could have found liability.” Specifically, the court agreed with Qiagen that no reasonable jury could have found that its accused kits, which contain materials used to prepare a DNA sample for sequencing, include the claimed “target-specific primer.” The district court had denied Qiagen’s post-trial JMOL motion on this issue by relying on two primary pieces of evidence, but the Federal Circuit ruled that the evidence could not support the jury’s infringement finding.
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