DCT
2:25-cv-09907
Balanced Body Inc v. La Pilates Holdings LLC
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Balanced Body, Inc. (California)
- Defendant: LA Pilates Holdings LLC (California)
- Plaintiff’s Counsel: Greenberg Traurig, LLP
- Case Identification: 2:25-cv-09907, C.D. Cal., 10/16/2025
- Venue Allegations: Venue is alleged to be proper as Defendant resides in the judicial district and has committed the alleged acts of infringement within the district.
- Core Dispute: Plaintiff alleges that Defendant’s use of certain Pilates reformer machines in its fitness studios infringes seven of Plaintiff's utility and design patents related to reformer apparatus technology.
- Technical Context: The technology concerns Pilates reformers, a type of exercise equipment using a sliding carriage against spring-based resistance, which constitutes a significant segment of the physical fitness market.
- Key Procedural History: The complaint notes that in August 2025, the U.S. International Trade Commission issued a general exclusion order related to products infringing two of the asserted patents and a limited exclusion order related to a third, indicating prior enforcement activity against infringing imported goods. Plaintiff also alleges providing Defendant with actual notice of infringement via a letter dated September 4, 2025, prior to filing the complaint.
Case Timeline
| Date | Event |
|---|---|
| 2011-07-13 | Earliest Priority Date for all Asserted Patents ('511, '829, '311, '645, D'205, D'206, D'208 Patents) |
| 2012-05-08 | U.S. Design Patent Nos. D659,205; D659,206; and D659,208 Issue |
| 2014-05-13 | U.S. Patent No. 8,721,511 Issues |
| 2014-12-23 | U.S. Patent No. 8,915,829 Issues |
| 2015-09-15 | U.S. Patent No. 9,132,311 Issues |
| 2016-03-22 | U.S. Patent No. 9,289,645 Issues |
| 2025-08-01 | Alleged first use of Infringing Products by Defendant |
| 2025-08-11 | International Trade Commission issues exclusion orders related to '511, D'208, and D'205 Patents |
| 2025-09-04 | Plaintiff sends notice letter to Defendant alleging infringement |
| 2025-10-16 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,721,511 - "Reformer Exercise Apparatus"
- Patent Identification: U.S. Patent No. 8,721,511, titled “Reformer Exercise Apparatus,” issued May 13, 2014.
The Invention Explained
- Problem Addressed: The patent’s background section identifies several drawbacks with traditional Pilates reformers, including the difficulty for users to properly center themselves, inconvenience in adjusting the foot support bar, arm cords dragging on the floor, and open rails that collect dust and dirt (’511 Patent, col. 1:25-56).
- The Patented Solution: The invention proposes a redesigned reformer frame where the side rails have a specific cross-sectional shape described as an "inverted generally U shape" (’511 Patent, Abstract). This profile creates a hidden, outwardly open slot within the rail structure, which houses and guides the foot bar support assembly, concealing it from view and protecting the carriage support surfaces from debris (’511 Patent, col. 2:3-12; Fig. 3).
- Technical Importance: This design approach integrates key mechanical components into the main frame extrusion, aiming to create a cleaner aesthetic, improve operational hygiene, and enclose moving parts that were previously exposed (’511 Patent, col. 1:50-56).
Key Claims at a Glance
- The complaint asserts at least Claim 1 (Compl. ¶49).
- The essential elements of independent Claim 1 include:
- A reformer exercise apparatus comprising:
- a generally rectangular frame having a pair of parallel spaced side rail portions, a head end portion, and a foot end portion;
- a movable carriage supported by the side rail portions for movement of the carriage between the head and foot end portions;
- a bias member connected between the carriage and the foot end portion of the frame for biasing the carriage toward the foot end of the frame; and
- a foot support member supported by the side rail portions of the frame, wherein each of the side rail portions has an outer surface inverted generally U shape in transverse cross section, formed by an upright outer wall, an integral horizontal top wall, and an inwardly and downwardly slanted inner wall.
U.S. Patent No. 8,915,829 - "Reformer Exercise Apparatus"
- Patent Identification: U.S. Patent No. 8,915,829, titled “Reformer Exercise Apparatus,” issued December 23, 2014.
The Invention Explained
- Problem Addressed: As a continuation of the application leading to the ’511 Patent, this patent addresses the same problems of traditional reformers, such as exposed mechanical parts, difficulty in adjustment, and accumulation of dust (’829 Patent, col. 1:12-58).
- The Patented Solution: The ’829 Patent describes and claims a similar solution centered on the unique frame and side rail geometry. The core inventive concept remains the integration of the foot bar support mechanism within a specially-shaped, semi-enclosed channel in the side rails, which are described as having an "inverted generally U shape" in transverse cross section (’829 Patent, Abstract; col. 2:2-10).
- Technical Importance: This patent provides further protection for the integrated frame design, which seeks to improve the reformer’s aesthetics, serviceability, and user experience by concealing functional components within the main structural members (’829 Patent, col. 1:59-62).
Key Claims at a Glance
The complaint asserts at least Claim 1 (Compl. ¶60).
The essential elements of independent Claim 1 include:
- A reformer exercise apparatus comprising:
- a generally rectangular frame having side rail portions with an outer surface of an inverted generally U shape in transverse cross section, formed by an upright outer wall, an integral top wall, and a sloping inner wall;
- a movable carriage supported by the side rail portions;
- a bias member connected between the carriage and the foot end portion; and
- a foot support member supported by the side rail portions of the frame.
Multi-Patent Capsule: U.S. Design Patent No. D659,205 - "Reformer Exercise Apparatus"
- Technology Synopsis: This patent protects the ornamental design for a complete reformer exercise apparatus, as shown in its figures (Compl. ¶21).
- Asserted Claims: Design patents have a single claim for the ornamental design as shown and described (Compl. ¶23).
- Accused Features: The overall visual appearance of the Defendant's "knockoff Pilates reformers" is alleged to be substantially similar to the patented design (Compl. ¶23; p. 8).
Multi-Patent Capsule: U.S. Design Patent No. D659,206 - "Reformer Exercise Apparatus Frame"
- Technology Synopsis: This patent protects the ornamental design for the frame of a reformer apparatus, separate from other components like the carriage or footbar (Compl. ¶29).
- Asserted Claims: Design patents have a single claim for the ornamental design as shown and described (Compl. ¶31).
- Accused Features: The ornamental appearance of the frame of Defendant’s reformers is alleged to infringe the patented design (Compl. ¶31; p. 10).
Multi-Patent Capsule: U.S. Design Patent No. D659,208 - "Reformer Exercise Apparatus Footbar"
- Technology Synopsis: This patent protects the ornamental design for the footbar component of a reformer apparatus (Compl. ¶37).
- Asserted Claims: Design patents have a single claim for the ornamental design as shown and described (Compl. ¶39).
- Accused Features: The visual appearance of the footbar on Defendant’s reformers is alleged to infringe the patented design (Compl. ¶39; p. 13).
Multi-Patent Capsule: U.S. Patent No. 9,132,311 - "Reformer Exercise Apparatus Footbar Support Assembly"
- Technology Synopsis: This patent is directed to a specific assembly for adjusting the position of the reformer's footbar, comprising components like a slide plate, hook plate, support arm, and a locking member that restricts movement based on the support arm's position (Compl. ¶¶ 67, 71).
- Asserted Claims: The complaint asserts at least Claim 1 (Compl. ¶71).
- Accused Features: The complaint alleges that Defendant's reformers feature a footbar assembly with a slide plate, hook plate, footbar support arm, and locking mechanism that practices the elements of the asserted claim (Compl. ¶72).
Multi-Patent Capsule: U.S. Patent No. 9,289,645 - "Reformer Exercise Apparatus Arm Cord Retraction Assembly"
- Technology Synopsis: This patent is directed to an assembly for retracting the arm cords used in exercises, featuring a pair of spring-biased reels and mechanically linked latch assemblies mounted to the underside of the carriage (Compl. ¶¶ 78, 82).
- Asserted Claims: The complaint asserts at least Claim 1 (Compl. ¶82).
- Accused Features: Defendant's reformers are alleged to include an arm cord retraction assembly with cord retraction devices, rotatable spring-biased reels, and mechanically linked latch assemblies that allegedly infringe the patent (Compl. ¶83).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are "knockoff Pilates reformer machines" that Defendant allegedly uses in its Pilates studios (Compl. ¶13, ¶15).
Functionality and Market Context
- The complaint alleges these machines possess the fundamental features of a Pilates reformer, including a rectangular frame with side rails, a movable carriage, coil springs, and a foot support bar (Compl. ¶50, ¶61). The complaint includes a still from a video showing several of the accused reformers in a studio setting with the caption "CLASS JUST GOT UPGRADED," suggesting they are a central feature of Defendant's service offering (Compl. ¶14, Fig. 4). The core of the infringement allegation is that the side rails of these machines are constructed with a specific cross-section that includes an upright wall, a horizontal wall, and a slanted inner wall, forming a slot that supports the footbar assembly (Compl. ¶50, ¶61). An image from Defendant's Instagram page shows two users exercising on the accused reformers (Compl. ¶14, Fig. 5).
IV. Analysis of Infringement Allegations
'511 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A reformer exercise apparatus comprising: a generally rectangular frame having a pair of parallel spaced side rail portions, a head end portion, and a foot end portion; | The accused products include a generally rectangular frame with parallel side rails, a head end, and a foot end. | ¶50 | col. 7:3-5 |
| a movable carriage supported by the side rail portions for movement of the carriage between the head and foot end portions; | The accused products include a movable carriage supported on the rails for movement between a head end and a foot end. | ¶50 | col. 7:6-9 |
| a bias member connected between the carriage and the foot end portion of the frame for biasing the carriage toward the foot end of the frame; and | The accused products include one or more coil springs connected between the carriage and the foot end to bias the carriage toward the foot end. | ¶50 | col. 7:15-18 |
| a foot support member supported by the side rail portions of the frame... | The apparatus further includes a foot support bar supported by the side rails. | ¶50 | col. 7:10-11 |
| ...wherein each of the side rail portions has an outer surface inverted generally U shape in transverse cross section, formed by an upright outer wall beginning at an outer bottom edge, extending substantially upright to an integral horizontal top wall merging into an inwardly and downwardly slanted inner wall... | On information and belief, the side rails of Defendant's apparatus include an upright wall, a horizontal wall, and a slanted inner wall forming an outwardly open slot that supports the foot bar assembly. | ¶50 | col. 7:45-53 |
'829 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A reformer exercise apparatus comprising: generally rectangular frame...wherein each of the side rail portions has an outer surface inverted generally U shape in transverse cross section, formed by an upright outer wall..., an integral top wall merging into an inwardly and downwardly sloping inner wall...; | The accused products include a generally rectangular frame with parallel side rail portions. Each side rail portion is alleged to have an outer surface with an inverted generally U shape, including an upright outer wall, a top wall, and an inwardly and downwardly sloping inner wall. | ¶61 | col. 16:51-64 |
| a movable carriage supported by the side rail portions for movement of the carriage between the head and foot end portions; | The apparatus includes a movable carriage that is supported by the side rail portions and is capable of moving between the head and foot end portions. | ¶61 | col. 18:1-3 |
| a bias member connected between the carriage and the foot end portion of the frame for biasing the carriage toward the foot end of the frame; and | The apparatus includes a bias member, such as one or more springs, connected between the carriage and the foot end portion of the frame, which biases the carriage. | ¶61 | col. 18:4-7 |
| a foot support member supported by the side rail portions of the frame. | On information and belief, the accused products include a foot support member (a foot bar) that is supported by the side rail portions of the frame. | ¶61 | col. 18:8-10 |
- Identified Points of Contention:
- Scope Questions: The infringement analysis for the '511 and '829 patents may focus on the scope of the phrase "inverted generally U shape." A central question will be how much deviation from a perfect "U" is permitted by the term "generally" and whether the specific combination of an "upright outer wall," "horizontal top wall," and "slanted inner wall" is a strict requirement for all infringing structures. A close-up image of the accused reformer's frame shows the carriage on the rail, but does not provide a clear cross-sectional view of the internal slot structure (Compl. ¶14, Fig. 2).
- Technical Questions: A primary evidentiary question will be whether the internal structure of the accused reformers' side rails, which is not visible in the complaint's photographs, actually contains the claimed "outwardly open slot" formed by the specific wall geometry. The allegations regarding this internal structure are made "on information and belief," suggesting this will be a key area for discovery (Compl. ¶50, ¶61).
V. Key Claim Terms for Construction
- The Term: "outer surface inverted generally U shape in transverse cross section" (’511 Patent, Claim 1; ’829 Patent, Claim 1).
- Context and Importance: This term is the central structural limitation defining the novel side rail profile in both the '511 and '829 patents. The outcome of the infringement analysis for these patents will depend heavily on whether the cross-sectional shape of the accused reformers' side rails is found to fall within the court's construction of this term.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The use of the word "generally" suggests that the shape is not required to be a perfect, symmetrical inverted "U." The claims further define the shape as being "formed by" a series of walls (upright, horizontal, slanted), which could be argued to define the character of the "general" shape rather than limit it to one exact profile (’511 Patent, col. 25:61-67).
- Evidence for a Narrower Interpretation: The specification provides a specific embodiment of the cross-section in a figure, showing a distinct and particular profile (’511 Patent, Fig. 3). A party could argue that the claim term should be interpreted as being limited to shapes that are substantially similar to this disclosed embodiment, particularly given that the walls forming the shape are explicitly recited.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement, asserting that Defendant encourages and instructs its customers to directly infringe by using the accused reformers. The alleged acts of inducement include advertising and marketing Pilates classes on its website and Instagram account featuring the infringing products, and providing instructions to customers on their use during classes (Compl. ¶27, ¶54, ¶65).
- Willful Infringement: The complaint alleges willful infringement based on Defendant's continued use of the accused reformers after receiving a cease-and-desist letter dated September 4, 2025, which allegedly provided actual notice of infringement (Compl. ¶15, ¶25, ¶52, ¶63). This forms a basis for post-notice willfulness.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of structural identity: will discovery confirm the complaint's "information and belief" allegations that the internal, non-visible cross-section of the accused reformers' side rails contains the specific wall and slot geometry required by the '511 and '829 patent claims?
- A second key question will be one of visual similarity: for the three asserted design patents, the issue will be whether an ordinary observer would find the overall aesthetic of the accused reformers, their frames, and their footbars to be substantially the same as the designs claimed in the patents, a question for which the complaint offers side-by-side photographic comparisons as initial evidence.
- Finally, a central question for damages will be willfulness: did the Defendant's conduct, particularly its alleged continued use of the accused machines after receiving the September 4, 2025 notice letter, rise to the level of egregious behavior that would warrant an award of enhanced damages?