The United States Court of Appeals for the Federal Circuit recently denied a petition for rehearing en banc in the case of Range of Motion Products, LLC v. Armaid Company Inc. This decision affects how design patent infringement cases are evaluated, particularly regarding the roles of judges and juries in such cases. The ruling is significant for companies involved in design patents and could influence future legal battles over similar issues.
The case, docket number 23-2427, originated in the United States District Court for the District of Maine. Range of Motion Products, LLC, the plaintiff, accused Armaid Company Inc. of infringing on its design patent. The dispute centers on whether the designs of the two companies' products are substantially similar, which is a key factor in determining patent infringement.
Range of Motion Products, LLC is a company that develops and sells products designed to improve physical mobility and comfort. Armaid Company Inc. specializes in creating devices aimed at muscle relief and rehabilitation. The two companies found themselves in court after Range of Motion alleged that Armaid's product was too similar to its patented design, which could mislead consumers and infringe upon its intellectual property rights.
The case reached the Federal Circuit after the district court granted summary judgment in favor of Armaid, concluding that no reasonable jury could find the designs substantially similar. This ruling prompted Range of Motion to file a petition for rehearing en banc, seeking a review by the full court, which would have involved a larger panel of judges.
On August 11, 2026, the Federal Circuit issued its ruling, denying the petition for rehearing en banc. The court's opinion highlighted that the panel decision was consistent with established precedent regarding design patent infringement. The ruling stated, "The petition for panel rehearing is denied. The petition for rehearing en banc is denied." Chief Judge Moore, along with Judge Reyna, dissented from the denial, expressing concerns that the current approach limits the jury's role in assessing design patent cases.
Judge Cunningham, who concurred with the denial, emphasized that the panel's decision aligned with longstanding Supreme Court and Federal Circuit precedent. He argued that allowing district courts to resolve design patent cases at summary judgment is appropriate when no reasonable jury could find the designs substantially similar. The opinion also noted that the dissent's arguments did not sufficiently demonstrate why en banc review was warranted.
The impact of this ruling is significant for companies involved in design patents. It reinforces the current standard for assessing design patent infringement, which places considerable weight on judicial interpretation rather than jury assessment. This ruling may set a precedent for future cases, potentially limiting the ability of juries to weigh in on design patent disputes.
Moving forward, the denial of the rehearing en banc means that the ruling from the panel stands, and Range of Motion Products, LLC's options for further appeal are limited. The case highlights ongoing debates within the legal community about the roles of judges and juries in patent infringement cases, particularly concerning design patents. The Federal Circuit's decision may influence how similar cases are approached in the future, particularly regarding the balance of responsibilities between judges and juries.
Details were not available in the court filing regarding any potential related cases pending or whether Range of Motion Products, LLC plans to pursue further legal action. The outcome of this case could have lasting implications for design patent law and the rights of companies seeking to protect their intellectual property.