Iron Grip Barbell Co. v. USA Sports, Inc.

Weightlifting barbells consist of a rigid bar with removable weighted plates at each end. Traditionally, weight plates had only a center attachment hole, making it hard to grasp and move them. To address that problem, Iron Grip Barbell Company (Iron Grip) (plaintiff) developed a weight plate that had three elongated grip openings in addition to the center attachment hole. At the time Iron Grip applied for a patent for its three-grip plate, prior art existed for one-, two-, and four-grip weight plates. The patent examiner initially rejected the patent application for obviousness but eventually issued the patent. Iron Grip promptly sued competing manufacturer USA Sports, Inc. (defendant) for patent infringement based on USA Sports’ manufacture of three-grip weight plates. As a defense, USA Sports argued that Iron Grip’s patent was invalid for obviousness and Iron Grip therefore did not have a viable infringement claim. To counter the obviousness allegation, Iron Grip presented evidence that three competitors had obtained licenses from Iron Grip to produce three-grip plates and that there were no three-grip plates on the market when Iron Grip applied for its patent. The district court granted summary judgment in USA Sports’ favor, finding that various claims in Iron Grip’s patent were invalid for obviousness. Iron Grip appealed.