Holding: When determining whether a claim is directed to an abstract idea under step one of the Alice test, the entire claim must be considered. Elements of the claim that are found in the prior art cannot be ignored.
PowerBlock owns US Patent No. 7,578,771, which pertains to automated selectorized dumbbells that use an electric motor connected to a selector for selecting and adjusting the weight of a dumbbell. PowerBlock sued iFit for infringement of the ‘771 Patent, and the district court found that all but one claim of the ‘771 Patent were patent ineligible under Section 101. According to the district court, the claims of the ‘771 Patent were directed to the abstract idea of the end result of an automated selectorized dumbbell weight stacking system.
Independent claim 1 of the ‘771 Patent recites a weight selection and adjustment system for a selectorized dumbbell that includes specific structural features such as: a stack of nested left weight plates, a stack of nested right weight plates, a handle, and a movable selector having a plurality of different adjustment positions. Claim 1 also recites that an electric motor is operatively connected to the selector and physically moves the selector into the adjustment position corresponding to the desired exercise weight that was selected for use by the user. Independent claim 20 similarly recites a dumbbell and an electric motor that may be energized to cause weight plates to be coupled to an end of the handle of the dumbbell.
The Federal Circuit reversed the district court’s decision, finding that the claims of the ‘771 Patent are not directed to an abstract idea under step one of the Alice test. At step one, the court must look to whether the claims focus on a specific means or method of improvement or directed to a result itself that is the abstract idea while using generic machinery. For the ‘771 Patent, the claims recite elements of a mechanical device and are limited to a particular type of dumbbell with certain structural features such as a stack of nested weight plates, a handle, and a movable selector. The claims also describe how the system works, by using the electric motor coupled to a selector to move the selector into a desired position. This limits the claims to a specific implementation of a technological improvement to selectorized dumbbells rather than to an abstract idea.
iFit argued that the claim limitations involving conventional selectorized dumbbell components should be ignored when determining whether the claims are directed to an abstract idea. However, step one of the Alice test requires that a claim is considered in its entirety to determine whether that claim is directed to an abstract idea. Therefore, it is improper to ignore limitations simply because those limitations can be found in the prior art. The Federal Circuit further cautioned that novelty and obviousness questions under Section 102 and 103 should not be conflated with the abstract idea inquiry of step one of the Alice test. Since the claims of the ’771 Patent were directed to sufficiently specific mechanical invention that performs the function of automating selectorized dumbbell weight stacking, the claims of the ‘771 Patent are not patent ineligible under Section 101.
Federal Circuit Precedential 
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