RampWerks v. Absolute BLACK & Playtri: Oval Chainring Patents Dismissed Without Prejudice
RampWerks, LLC brought a three-patent infringement action against oval chainring maker Absolute BLACK and retailer Playtri Franchising in the Eastern District of Texas, asserting US10677338B2, US11460099B2, and US10711875B2. The plaintiff voluntarily dismissed all claims without prejudice just 342 days after filing — leaving the door open for future enforcement.
Three Oval Chainring Patents, One Quick Exit — and an Open Door
RampWerks, LLC filed this infringement action on 26 May 2023 in the Eastern District of Texas before Judge Rodney Gilstrap, asserting three US patents — US10677338B2, US11460099B2, and US10711875B2 — against Absolute BLACK, a specialist manufacturer of oval chainrings, and Playtri Franchising, LLC, a triathlon-focused retail franchise. The accused products include Absolute BLACK’s OVAL Road 110/4 and Sub-Compact Road chainring lines, as well as premium oval chainrings compatible with Shimano R9100 and Ultegra groupsets.
The case ended on 2 May 2024 when RampWerks filed a Rule 41(a)(1)(A)(i) notice of voluntary dismissal without prejudice — a unilateral procedural mechanism available before the defendant serves an answer or motion for summary judgment. The court accepted and acknowledged the dismissal, ordered each party to bear its own costs, and closed the case. Crucially, ‘without prejudice’ means RampWerks’ claims are not extinguished: the plaintiff may refile the same infringement allegations in a future action subject to applicable statutes of limitations.
The 342-day duration without reaching substantive motion practice is consistent with pre-trial settlement discussions, licensing negotiations, or a strategic reassessment of claim scope — though the public record is silent on which dynamic prevailed. The absence of any defendant law firm on record and the early-stage dismissal suggest the parties may never have reached full adversarial engagement. Whether RampWerks intends to refile against Absolute BLACK, pursue licensing, or abandon enforcement of these chainring patents entirely remains unknown from the available docket.
Filing to Dismissed without Prejudice in 342 days
342 days — resolved well before a typical E.D. Texas trial schedule of 18–24 months
Dismissed without prejudice: what the Rule 41 exit means for both parties
Rule 41(a)(1)(A)(i): a plaintiff’s unilateral exit before answer
Under FRCP 41(a)(1)(A)(i), a plaintiff may dismiss its own action without a court order — and without prejudice — before the defendant serves either an answer or a motion for summary judgment. This is one of the few purely unilateral acts available in federal civil litigation. The court’s role is administrative: it accepts and acknowledges the dismissal rather than ruling on the merits. No findings on infringement, validity, or claim scope were made.
No merits adjudicationWithout prejudice preserves RampWerks’ enforcement rights
A dismissal without prejudice does not extinguish the underlying patent claims. RampWerks retains the right to file a new infringement action asserting the same three patents against Absolute BLACK or Playtri, subject to the six-year patent damages look-back window under 35 U.S.C. § 286 and any applicable equitable defences. This is materially different from a with-prejudice dismissal, which would bar refiling on the same claims. Competitors and licensees should treat these three patents as live enforcement assets.
Refiling remains possibleAbsolute BLACK and Playtri escape judgment — but face ongoing risk
The defendants obtained no invalidity finding, no non-infringement ruling, and no fee award. While the immediate litigation burden is removed, the without-prejudice dismissal means neither Absolute BLACK nor Playtri can invoke res judicata to block a future action on these patents. The own-costs order also confirms no prevailing-party fee shift occurred. Both defendants should consider whether design-around, licensing, or IPR petitions against US10677338B2, US11460099B2, and US10711875B2 would reduce long-term exposure.
No preclusive effectOval chainring IP remains live — market uncertainty persists
With three oval chainring patents surviving without a validity or infringement ruling, other manufacturers and distributors of non-circular chainrings — particularly those producing Shimano-compatible oval rings — face the same freedom-to-operate question that Absolute BLACK does. RampWerks’ willingness to file in E.D. Texas before Judge Gilstrap signals awareness of a plaintiff-friendly venue. The sector should expect continued enforcement risk until these patents are either licensed, invalidated via IPR, or expire.
FTO assessment recommendedFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | RampWerks, LLC | Company | Bicycle drivetrain IP licensor — holder of US10677338B2, US11460099B2, US10711875B2Search in Eureka ↗ |
| Defendant | Absolute BLACK | Individual | Absolute BLACK: oval chainring manufacturer; Playtri Franchising: triathlon retail franchiseSearch in Eureka ↗ |
| Co-Defendant | Playtri Franchising, LLC | Company | Search in Eureka ↗ |
| Plaintiff counsel | Cabrach John Connor | Attorney | Counsel for RampWerks, LLCSearch in Eureka ↗ |
| Plaintiff law firm | Connor Lee & Shumaker PLLC (Austin) | Law Firm | Representing RampWerks, LLCSearch in Eureka ↗ |
| Presiding judge | Judge Rodney Gilstrap | Judge | Texas Eastern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The court’s order is purely administrative — it accepts and acknowledges RampWerks’ unilateral Rule 41(a)(1)(A)(i) notice rather than adjudicating any claim on its merits. The phrase ‘dismissed without prejudice’ is the operative term: no finding of infringement, validity, or invalidity attaches to any of the three asserted patents. The own-costs order forecloses any fee-shifting argument under 35 U.S.C. § 285. Both parties leave the proceeding in the same legal position they entered, with the patents intact and enforceable.
US10677338B2, US11460099B2 & US10711875B2 — Oval Bicycle Chainring Technology
The three asserted patents — US10677338B2 (application US15/620274), US11460099B2 (application US16/895002), and US10711875B2 (application US15/782084) — cover oval or non-circular bicycle chainring technology, a segment that has gained significant traction among road cyclists and triathletes seeking biomechanical efficiency advantages. The application dates span roughly 2017–2020, placing the inventions in the period when oval chainrings began mainstream commercial adoption across Shimano-compatible BCD standards including 110/4 and 110/5 configurations.
RampWerks’ assertion of all three patents simultaneously against Absolute BLACK — widely regarded as a market leader in oval chainrings — suggests these patents collectively address core aspects of oval chainring design that competitors would find difficult to design around without affecting product performance. The Shimano R9100 and Ultegra compatibility of the accused products means the patents potentially implicate a large share of the road cycling aftermarket. Any manufacturer producing oval chainrings to common Shimano BCD standards faces analogous infringement exposure until these patents are licensed or invalidated.
Should your team run an FTO against US10677338B2, US11460099B2 & US10711875B2?
Any company designing, manufacturing, or distributing oval or non-circular bicycle chainrings — particularly those compatible with Shimano 110/4 or 110/5 BCD standards — should treat these three RampWerks patents as live FTO concerns. The without-prejudice dismissal against Absolute BLACK means no invalidity ruling exists to rely upon. Retailers stocking oval chainring products, including triathlon-focused distributors, share downstream infringement exposure and should review their supplier indemnity arrangements.
PatSnap Eureka’s FTO Search Agent can map the claim scope of US10677338B2, US11460099B2, and US10711875B2 against your product specifications, identify prior art that may support an IPR petition, and surface related continuation applications that could extend RampWerks’ coverage. Set up patent family monitoring to track any new filings or assignments linked to these application numbers before a refile or licensing campaign materialises.
Run a freedom-to-operate analysis on US10677338B2 to assess your product’s exposure
Run FTO in Eureka →Similar Oval Chainring & Cycling Drivetrain Patent Cases in E.D. Texas
Browse comparable patent infringement actions involving bicycle drivetrain and chainring technology before the Eastern District of Texas, including Rule 41 dismissals and enforcement patterns.
What this case signals for the oval chainring and cycling drivetrain IP landscape
A without-prejudice exit rarely signals the end of enforcement — for competitors in the oval chainring space, these three patents warrant active monitoring.
Rule 41 without prejudice is not closure — treat the patents as active threats
RampWerks dismissed without prejudice, preserving full refiling rights. Any oval chainring manufacturer or distributor selling Shimano-compatible products should conduct FTO analysis against US10677338B2, US11460099B2, and US10711875B2 before assuming the litigation risk has passed.
E.D. Texas / Gilstrap venue choice signals deliberate enforcement strategy
Filing before Judge Gilstrap in E.D. Texas is a calculated plaintiff-side choice. RampWerks demonstrated willingness to litigate in one of the most patent-plaintiff-friendly venues in the US. A refile — or a parallel action against new defendants — in the same court remains a credible next step.
RampWerks v Absolute — key questions answered
RampWerks, LLC voluntarily dismissed all claims against Absolute BLACK and Playtri Franchising without prejudice on 2 May 2024 under FRCP 41(a)(1)(A)(i). The court accepted the notice and closed the case. No merits ruling was issued. The public record does not disclose whether settlement, licensing, or strategic reassessment drove the decision.
RampWerks asserted three US patents: US10677338B2, US11460099B2, and US10711875B2. All three relate to oval or non-circular bicycle chainring technology. The accused products include Absolute BLACK’s OVAL Road 110/4 and Sub-Compact Road chainring ranges, as well as premium oval rings compatible with Shimano R9100 and Ultegra groupsets at 110/4 and 110/5 BCD.
No. A dismissal without prejudice under Rule 41(a)(1)(A)(i) does not bar refiling. RampWerks retains the right to assert the same three patents against Absolute BLACK or Playtri in a new action, subject to the six-year patent damages window under 35 U.S.C. § 286 and any equitable defences that may arise from delay.
The case was assigned to Judge Rodney Gilstrap in the Eastern District of Texas (Case No. 2:23-cv-00236). RampWerks was represented by Cabrach John Connor of Connor Lee & Shumaker PLLC (Austin). No defendant counsel is recorded on the public docket, consistent with the case ending before defendants formally appeared.
Companies producing or distributing oval chainrings compatible with Shimano 110/4 or 110/5 BCD standards should conduct freedom-to-operate analysis against US10677338B2, US11460099B2, and US10711875B2. The without-prejudice dismissal leaves all three patents enforceable. IPR petitions at the PTAB are one option to reduce long-term litigation risk if prior art against the claims can be identified.
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