Can § 101 Carry the Weight?

POWERBLOCK HOLDING, INC. v. IFIT, INC.

Before Taranto, Stoll, and District Judge Scarsi. Appeal from the United States District Court for the District of Utah.

Summary: Under step one of the Alice test, claims should be considered in their entirety to ascertain whether their character as a whole is directed to excluded subject matter.

PowerBlock Holdings (PowerBlock) sued iFit for patent infringement and unfair competition. iFit filed a motion to dismiss under 35 U.S.C. § 101, arguing that the claims were directed to the abstract idea of automated weight stacking. iFit argued that the patent claimed a weight selection and adjustment system consisting of generic components, without adding significantly more to the abstract idea. The district court agreed, found all but one claim ineligible under § 101, and granted iFit’s motion to dismiss. PowerBlock appealed.

The Federal Circuit reversed, holding that the claims at issue were not directed to an abstract idea under step one of the Alice test. The court held that the claims recited meaningful structural limitations, not just generic components, that provided a specific implementation of automatic weight stacking. Further, the Federal Circuit rejected iFit’s attempts to read out or ignore limitations merely because they could be found in the prior art, because step one of Alice should involve consideration of the claims in their entirety to ascertain whether their character as a whole is directed to excluded subject matter. Failing to do so can improperly conflate the separate novelty and obviousness inquires under 35 U.S.C. §§ 102 and 103 with the eligibility inquiry under § 101. Accordingly, the Federal Circuit reversed and remanded.

Editor: Sean Murray