3:26-cv-01283
Guangzhou Langzhu Crafts Co Ltd v. Domesick
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Guangzhou Langzhu Crafts Co., Ltd. (People's Republic of China)
- Defendant: Michael H. Domesick, d/b/a ABMILL (Connecticut)
- Plaintiff's Counsel: Harris Beach Murtha Cullina PLLC
- Case Identification: 3:26-cv-01283, D. Conn., 08/11/2026
- Venue Allegations: Venue is alleged to be proper in the District of Connecticut because the Defendant, a natural person, resides in the District.
- Core Dispute: Plaintiff seeks a declaratory judgment that its Pilates-board and abdominal-exercise products do not infringe Defendant's patent and that the patent is invalid and unenforceable.
- Technical Context: The technology relates to exercise apparatuses designed to assist users in performing abdominal core and plank exercises, a market segment focused on improving exercise ergonomics and effectiveness.
- Key Procedural History: The dispute arose from patent infringement notices Defendant sent to Amazon regarding Plaintiff's products, resulting in the delisting of at least six of Plaintiff's product listings. The complaint alleges that the patent-in-suit issued from a long family of applications personally prosecuted by the Defendant, a licensed attorney, and that the claims were improperly broadened during prosecution to cover competitors' products, including Plaintiff's.
Case Timeline
| Date | Event |
|---|---|
| 2014-02-25 | Earliest Priority Date for '871 Patent (Provisional App. 61/944,154 filed) |
| 2022-10-07 | Application for '871 Patent filed |
| 2026-05-05 | U.S. Patent No. 12,616,871 issues |
| ~2026 | Defendant asserts '871 Patent via Amazon takedown notice process |
| 2026-08-11 | Complaint for Declaratory Judgment filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,616,871 - "Abdominal Core and Plank Exercise Apparatus"
The patent-in-suit is U.S. Patent No. 12,616,871 ("Abdominal Core and Plank Exercise Apparatus"), issued May 5, 2026 (the "'871 Patent").
The Invention Explained
- Problem Addressed: The patent's background describes drawbacks of conventional plank exercises, including user discomfort and susceptibility to injury, particularly strain on the user's wrists and forearms from bearing body weight on elbows or hands. ('871 Patent, col. 1:24-42).
- The Patented Solution: The invention is an exercise apparatus designed to assist with plank exercises. As described in the specification, it provides a frame with hand grips and at least one arm support pad. ('871 Patent, abstract). This design purports to solve the identified problem by distributing the user's body weight across the forearms via the support pads, rather than concentrating it on the elbows, and by providing ergonomic hand grips. ('871 Patent, col. 6:52-59). Some embodiments include a curved "destabilizing device" to add instability, enhancing the core-strengthening aspect of the exercise. ('871 Patent, col. 6:61-68; '871 Patent, Fig. 3).
- Technical Importance: The apparatus aims to make plank exercises safer and more comfortable, potentially allowing for longer exercise duration and reducing the risk of strain-related injuries common with traditional methods. ('871 Patent, col. 6:57-59).
Key Claims at a Glance
The complaint seeks a declaratory judgment of non-infringement and invalidity for all thirteen independent claims of the '871 Patent (claims 1, 8, 19, 30, 37, 52, 65, 89, 98, 115, 118, 145, and 156) (Compl. ¶30). Independent claim 1 is representative and includes the following essential elements:
- An exercise apparatus with a frame having a centerline and a midway axis.
- The frame comprises a handle/grip structure and a rigid mounting surface with an arm support pad.
- The handle/grip structure has at least two upwardly extending elongated grip portions on opposite sides of the centerline.
- A weight-bearing element configured to engage a ground surface.
- This weight-bearing element has a "curved or contoured surface symmetrically disposed about a pivot axis," which allows the frame to "undergo rotational or tilting movement."
III. The Accused Instrumentality
Product Identification
The complaint identifies two categories of accused products sold under the "VigorEdge" brand: "One-Handle Products" and "Two-Handle Products" (collectively, the "Accused Products") (Compl. ¶¶22-23).
Functionality and Market Context
- The Accused Products are described as "foldable, multi-purpose Pilates reformer boards" sold on Amazon.com and other online marketplaces (Compl. ¶22).
- The "One-Handle Products" feature a "single unitary sliding pad or platform" that moves along a central channel on a "flat, multi-suction-foot base" (Compl. ¶23(a)).
- The "Two-Handle Products" feature "two independently sliding hand-grip assemblies" mounted on a similar "flat, multi-suction-foot base" (Compl. ¶23(b)).
- A critical functional distinction alleged in the complaint is that both product types are used while the "user sits or kneels on the board itself," in contrast to the prone plank position described in the '871 Patent (Compl. ¶23(a); Compl. ¶23(b)). The complaint provides an image showing two categories of the accused Pilates boards, one with a single sliding handle and another with two independent handles, both appearing to have flat bases. (Compl. p. 5).
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement, arguing that the Accused Products lack multiple elements required by the independent claims of the '871 Patent. The following table summarizes the non-infringement arguments for representative claim 1.
'871 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a weight-bearing element, intersected by the centerline and configured to engage a ground surface, comprising a curved or contoured surface symmetrically disposed about a pivot axis, wherein the pivot axis aligns or substantially coincides with an axis of symmetry of the curved or contoured surface, thereby allowing the frame to undergo rotational or tilting movement about the pivot axis relative to the ground surface. | The Accused Products employ a "flat frame supported by feet" or a "flat, multi-suction-foot base" that is "incapable of pivoting or tilting." The complaint alleges this structure is "substantially different in structure, way of operation, and result from a rocking base." | ¶32; ¶43 | col. 6:61-68 |
| [Implicit limitation of] a user in a prone plank position with forearms on pads and knees or feet located behind the rearmost edge of the frame. | The Accused Products are used with the "user seated or kneeling on the board itself." The user's knees and feet are on the frame, not behind it. | ¶35; ¶56 | col. 6:40-45 |
| a frame having ... a handle or grip structure and at least one rigid mounting surface... wherein the handle or grip structure includes at least two upwardly extending elongated grip portions arranged respectively on opposite sides of the centerline... | The "One-Handle Products" use a "single unitary sliding pad or platform" and a "single arched hand-grip assembly," not a pair of independent left and right components. | ¶31 | col. 5:40-47 |
Identified Points of Contention
- Structural Mismatch: A primary dispute concerns the base of the apparatus. The analysis will question whether the claimed "curved or contoured surface" that enables "rotational or tilting movement" can be construed to cover the Accused Products' allegedly "flat, multi-suction-foot base" that is "incapable of pivoting or tilting" (Compl. ¶32; Compl. ¶43).
- Functional Mismatch (User Position): The complaint alleges the '871 Patent consistently describes and claims use in a "prone plank position" (Compl. ¶35). This raises the question of whether the claims can read on the Accused Products, which are allegedly used with the user "seated or kneeling on the board itself" (Compl. ¶35).
- Component Mismatch: For the One-Handle Products, a question exists as to whether a "single unitary sliding pad" can meet claim limitations requiring distinct "left" and "right" independent components (Compl. ¶31).
V. Key Claim Terms for Construction
The Term: "channel or groove"
Context and Importance
This term appears frequently in the claims of the '871 Patent (Compl. ¶19). Practitioners may focus on this term because the complaint alleges it appears "zero times in the written description of the '871 Patent and its patent family," forming the basis for invalidity challenges under 35 U.S.C. § 112 for lack of written description, lack of enablement, and indefiniteness (Compl. ¶36; Compl. ¶73(a); Compl. ¶96).
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The complaint does not present evidence for this position. A defendant would likely argue that "channel or groove" is a common structural term that one of ordinary skill in the art would understand without an explicit definition in the specification.
- Evidence for a Narrower (or Invalidating) Interpretation: The complaint alleges the term is entirely absent from the specification, which it claims "do not disclose a 'channel or groove,' and do not enable a person of ordinary skill in the art to distinguish which structures are 'channels or grooves' from those that are not" (Compl. ¶36).
The Term: "curved or contoured surface" that allows "rotational or tilting movement"
Context and Importance
This term is central to the non-infringement argument. Its construction will determine whether the claims require a functional rocking capability, which the Plaintiff alleges its flat-based products lack (Compl. ¶32; Compl. ¶43).
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The patentee may argue the term does not require a specific radius or degree of curvature and could encompass minor contours or rely on the doctrine of equivalents.
- Evidence for a Narrower Interpretation: The specification's primary embodiment for this function is a "destabilizing device" with a distinct, curved ground-interface surface intended to "facilitate a destabilizing movement" (e.g., device 160 in Fig. 3) ('871 Patent, col. 6:61-68). This may support an interpretation that requires an actual, functional rocking or pivoting capability.
VI. Other Allegations
The complaint includes several counts seeking a declaratory judgment of invalidity, which are central to the case.
Anticipation and Obviousness (§§ 102/103)
The complaint alleges the claims of the '871 Patent are invalid as anticipated or obvious in light of prior art that was not considered by the USPTO during prosecution (Compl. ¶¶61-63). Specific references cited include U.S. Patent No. 5,224,909 to Hamilton and Chinese Utility Model CN 201108700 Y (Compl. ¶62; Compl. ¶63).
Lack of Written Description (§ 112(a))
The complaint alleges that numerous claim terms, including "channel or groove," "linear, flat path of travel," and "constant height," are not described anywhere in the specification of the '871 Patent or its priority applications (Compl. ¶¶73-74). This alleges the inventor was not in possession of the full scope of the claimed subject matter at the time of filing.
Lack of Enablement (§ 112(a))
The complaint alleges that the scope of the claims is disproportionately broad relative to the disclosure. It argues the specification only teaches how to make and use a specific architecture (a rocking-base, dual-forearm-pad device used in a prone plank position) and does not enable the full scope of the claims, which allegedly cover different structures (like single-pad, non-rocking devices) and uses (seated or kneeling) without undue experimentation (Compl. ¶¶83-85).
Indefiniteness (§ 112(b))
The complaint alleges that terms like "channel or groove" are indefinite because they are not defined or illustrated in the specification, failing to inform a person of ordinary skill in the art of the claim scope with reasonable certainty (Compl. ¶96). It also challenges terms of degree like "substantially" and "elongated" as lacking an objective baseline (Compl. ¶102).
VII. Analyst's Conclusion: Key Questions for the Case
- A central validity question will be one of written description and enablement: can the '871 Patent's claims, which include terms like "channel or groove" and cover a broad genus of exercise devices, be sustained by a specification that the complaint alleges exclusively describes a different, specific architecture featuring a "convex or curved rocking base" and "dual independent components"?
- A key non-infringement issue will be one of structural and functional mismatch: does the claim requirement for a "curved or contoured surface" allowing "rotational or tilting movement" read on the accused products' allegedly "flat, multi-suction-foot base"? Further, can the claims, which the complaint argues are tied to a "prone plank" user position, be construed to cover the accused products' intended use in a "seated or kneeling" posture?
- A third core issue will be one of claim construction and indefiniteness: do terms such as "channel or groove," which are alleged to be absent from the specification, and terms of degree like "substantially," fail to inform a person of ordinary skill in the art about the scope of the invention with reasonable certainty, rendering the claims invalid under 35 U.S.C. § 112(b)?