The U.S. Court of Appeals for the Federal Circuit affirmed a lower court's ruling that Armaid Company Inc. did not infringe a design patent owned by Range of Motion Products, LLC, in a decision issued Feb. 2, 2026.
The Federal Circuit upheld the U.S. District Court for the District of Maine's grant of summary judgment of non-infringement in favor of Armaid Company. Circuit Judge Cunningham wrote the majority opinion, while Chief Judge Moore filed a dissenting opinion, indicating a split decision on the three-judge panel.
The case centers on U.S. Design Patent No. D802,155, titled "Body Massaging Apparatus," which Range of Motion Products owns. The patent claims "the ornamental design for a body massaging apparatus, as shown and described." The patent was filed on May 25, 2016, and issued on Nov. 7, 2017.
Range of Motion Products initially sued Armaid Company in the District of Maine in 2022, alleging that Armaid's products infringed the design patent. The case was assigned to Chief Judge Jon D. Levy, who granted summary judgment in favor of Armaid Company on Aug. 28, 2023.
The district court's ruling found that Armaid's accused products did not infringe Range of Motion's design patent. This type of summary judgment ruling typically means the court determined that no reasonable jury could find infringement based on the evidence presented, making a trial unnecessary.
Design patents protect the ornamental appearance of functional items rather than their utility. Unlike utility patents, which protect how an invention works, design patents focus on how a product looks. To prove infringement of a design patent, the patent holder must show that an accused product is substantially similar in overall appearance to the patented design when viewed by an ordinary observer.
The Federal Circuit has exclusive jurisdiction over patent appeals from federal district courts, making it the final appellate authority for most patent disputes unless the Supreme Court agrees to hear a case. The court's expertise in intellectual property law makes its decisions particularly significant for companies operating in patent-intensive industries.
Range of Motion Products was represented by attorneys from Lambert Shortell and Connaughton in Boston, including Justin Tinger, who argued the appeal. The legal team also included David Connaughton and Brendan M. Shortell.
Armaid Company was represented by a team from Sidley Austin LLP in Washington, D.C., including Joshua John Fougere, who presented oral arguments. The defense team also included Claire Homsher and Susan K. Whaley from Sidley Austin, along with Peter J. Brann, Stacy O. Stitham, and David Swetnam-Burland from Brann & Isaacson in Lewiston, Maine.
The presence of Chief Judge Moore's dissenting opinion suggests the case involved complex legal issues where reasonable judges could disagree on the outcome. Dissenting opinions often highlight different interpretations of patent law or factual disputes that could influence future cases.
The fitness and therapeutic equipment industry frequently sees patent disputes as companies compete to protect their product designs and market positions. Body massaging and exercise equipment often involves both functional and aesthetic elements, making design patent protection an important consideration for manufacturers.
For Range of Motion Products, the affirmance represents a setback in its efforts to enforce its design patent rights against what it viewed as infringing products. The company will need to decide whether to seek further review, though the Supreme Court rarely grants certiorari in patent cases unless they involve significant legal questions.
For Armaid Company, the Federal Circuit's affirmance provides finality to the litigation and confirms that its products do not infringe the asserted design patent. This outcome allows the company to continue marketing and selling its products without concern about this particular patent claim.
The case demonstrates the challenges patent holders face when asserting design patent rights, particularly when trying to prove that accused products are substantially similar to their patented designs. Courts must balance protecting legitimate patent rights while ensuring that design patents do not create overly broad monopolies on basic product features.
The decision also highlights the importance of the Federal Circuit's role in providing consistency in patent law interpretation across different judicial districts. As the sole appellate court for patent matters, the Federal Circuit's rulings establish precedent that guides both trial courts and patent practitioners in future cases involving similar legal questions.