This case concerns U.S. Patent No. 7,578,771 (hereinafter, the ‘771 Patent), which is directed to an automated weight selection system for use as exercise equipment.  Claim 1 of the ‘771 Patent recites a selectorized dumbbell that includes nested weights on both sides, a handle, and moveable selector, as well as an electric motor that physically moves the selector to attach the weights to the handle.  Claim 20 of the ‘771 Patent recites a dumbbell with an adjustable exercise weight, an electric motor that causes a desired number of weight plates to be coupled to the handle of the dumbbell, and a data entry device that allows a user to input a weight selection, causing the electric motor to adjust the exercise weight accordingly.

The Federal Circuit reversed the district court’s determination that the claims are ineligible under 35 U.S.C. § 101, further holding that the claims are not directed to an abstract idea under Step 1 of the two step Alice test. 

The Federal Circuit determined that claim 1 (and similarly claim 20) is limited to a particular type of dumbbell, and that claim 1 also recites an electric motor that causes physical movement of a selector to adjust weights on the particular type of dumbbell.  Therefore, the Federal Circuit indicated that the claims are “limited to a specific implementation of a technological improvement to” selectorized dumbbells, and that these limitations provide “enough specificity and structure to satisfy § 101.”  The Federal Circuit stated that claim 1 “passes muster at Alice step one, as it is sufficiently focused on a specific mechanical improvement to selectorized dumbbell weight stacking.” 

The Federal Circuit noted that the district court erred in treating the specific components recited in claim 1 as “generic” and therefore incorrectly concluded that the claims are directed to a broad concept of automating a known technique.  The Federal Circuit further indicated that the claims provide a “specific manner of performing automated weight stacking,” thereby providing some restrictions on how the result is accomplished.

Lastly, iFit attempted to argue that the recited mechanical components are generic and well-known in the prior art, and therefore do not provide any specific structure.  That is, iFit argued that the generic or well-known components should be excluded from consideration as to whether the claim is directed to an abstract idea.  The Federal Circuit refused to entertain this argument, reiterating that Alice step one involves “consideration of the claims in their entirety to ascertain whether their character as a whole is directed to excluded subject matter.”  Thus, whether mechanical elements are generic or well-known in the art is likely of little concern in the analysis of step one of Alice, at least with respect to mechanical components.

The Federal Circuit concluded that the claims are “directed to a sufficiently specific mechanical invention that, as a whole, advantageously automates selectorized dumbbell weight stacking” and are therefore not directed to an abstract idea.

Therefore, in view of this decision, for mechanical automation patents, the claims should recite sufficiently specific structures with some limitation as to how the result is achieved that reflects an improvement to the technology or an improvement to the automation of said technology (e.g., as set forth in the Applicant’s Specification), and it is likely not required that the specific structures be unconventional, novel or non-obvious in order to ensure that the claims are directed to eligible subject matter.