Modern electro-mechanical systems—ranging from humanoid robots and automated assembly lines, to smart workout equipment and medical devices—combine mechanical and electronic components to automate the performance of physical tasks once done manually. In PowerBlock Holdings, Inc. v. iFit, Inc., the Federal Circuit confirmed that patent claims covering such systems can be eligible for protection under 35 U.S.C. § 101 when they recite the automation or movement of specific, tangible physical components. This precedential decision underscores how precise claim drafting can protect robotic, industrial automation, and electro-mechanical technologies from Alice-based eligibility attacks.
Case Background
PowerBlock sued iFit for infringing a patent directed to selectorized dumbbells that use an electric motor to attach weighted plates to a dumbbell handle. iFit moved to dismiss, arguing that that the claims were invalid under 35 U.S.C. § 101 as abstract ideas. The district court agreed, finding the claims covered the abstract idea of “automated weight stacking.”
PowerBlock appealed.
Federal Circuit Decision
Applying the Supreme Court’s Alice two-step framework, the Federal Circuit reversed. Under Alice Step One, the Federal Circuit held that the claims, viewed as a whole, were not directed to an abstract idea.
Unlike the patent ineligible claims in both University of Florida Research Foundation v. GE—directed to automation of a manual data process using a computer—and Chamberlain Group v. Techtronic—directed to wirelessly communicating status information—the Federal Circuit noted that the PowerBlock claims recited a specific apparatus with physical components including weighted plates, a handlebar, a selector, and an electric motor for plate attachment. The Federal Circuit found these tangible components placed the invention within the realm of a concrete machine, not an abstract idea. Citing Diamond v. Diehr, the Federal Circuit also emphasized that all claim elements—including those known in prior art—must be considered at Alice Step One. Stripping away conventional structure in the Alice analysis incorrectly distorts the patent eligibility inquiry.
Considering the claims in their entirety under Alice Step One, the Federal Circuit found that the claims covered a specific physical implementation of a technological improvement—automated selectorized dumbbell stacking—making them patent eligible under § 101.
Takeaways for Practitioners
- Automating physical tasks with electro-mechanical components can clear the § 101 hurdle.
Automating physical tasks or actions (e.g., moving, attaching, or stopping physical objects) using tangible electro-mechanical components is different from automating mental processes with generic computing hardware. The former can meet § 101 eligibility; the latter generally cannot.
- To better withstand Alice-based eligibility attacks, patent claims should recite physical, not generic computing components.
To clear the § 101 hurdle, the patent claims themselves must capture this distinction. Claims that recite the automation or physical movement of tangible components—motors, selectors, weights, and supports—are more resistant to Alice attacks than claims merely reciting functional results or automation of electro-mechanical systems in abstract terms.
Conclusion
The PowerBlock decision confirms that tangible electro-mechanical automation systems—when claimed in a way that meaningfully ties the automation to concrete, tangible structures—can survive § 101 scrutiny. For innovators in robotics, manufacturing technology, smart equipment, and medical devices, careful claim drafting remains an important shield against Alice-based eligibility attacks.
