Balanced Body Inc v. Refined Pilates LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Balanced Body, Inc. (California)
  • Defendant: Refined Pilates LLC (California)
  • Plaintiff’s Counsel: Greenberg Traurig, LLP
• Case Identification: 2:26-cv-00895, C.D. Cal., 01/28/2026
• Venue Allegations: Venue is alleged to be proper in the Central District of California because Defendant is a California LLC that resides in the district and has committed the alleged acts of infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s use of "knockoff" Pilates reformer machines in its commercial studio constitutes infringement of seven U.S. patents, including three design patents and four utility patents, covering the overall apparatus, frame, footbar, and other sub-assemblies.
• Technical Context: The technology at issue is the mechanical and aesthetic design of Pilates reformers, which are specialized exercise machines used for resistance training and core stabilization.
• Key Procedural History: The complaint references a prior International Trade Commission investigation (Inv. No. 337-TA-1419) that concluded in August 2025. This investigation resulted in a General Exclusion Order prohibiting importation of products infringing U.S. Patent Nos. 8,721,511 and D659,208, and a Limited Exclusion Order for products infringing U.S. Patent No. D659,205. The complaint alleges that Defendant is using products subject to these orders.

Case Timeline

II. Technology and Patent(s)-in-Suit Analysis

U.S. Design Patent No. D659,205 - Reformer Exercise Apparatus

• Issued: May 8, 2012

The Invention Explained

• Problem Addressed: The patent family addresses perceived drawbacks in traditional reformer designs, including dated aesthetics and exposed mechanical components (Compl. ¶9; ’511 Patent, col. 1:25-56).
• The Patented Solution: The D’205 Patent claims the specific, holistic ornamental appearance of a reformer apparatus, characterized by a smooth, integrated frame with curved ends, a particular footbar shape, and the overall arrangement of the carriage and shoulder stops as depicted in the patent’s figures D’205 Patent, Figs. 1-7 The complaint highlights the upper perspective, head end, and top plan views as exemplary Compl. ¶21
• Technical Importance: The design provides a distinct visual identity that differentiates the product in the marketplace and contributes to an integrated, contemporary aesthetic Compl. ¶45

Key Claims at a Glance

• Design patents contain a single claim for the ornamental design as shown in the drawings. The claim of the D’205 Patent is for “The ornamental design for a reformer exercise apparatus, as shown and described” D’205 Patent

U.S. Patent No. 8,721,511 - Reformer Exercise Apparatus

• Issued: May 13, 2014

The Invention Explained

• Problem Addressed: The patent’s background section identifies several problems with prior art reformers, including difficulty cleaning tracks, users' clothing getting caught in exposed mechanisms, and the inconvenience of adjusting the foot support bar '511 Patent, col. 1:41-52
• The Patented Solution: The invention discloses a reformer frame with uniquely shaped side rails that have an "inverted generally U shape in transverse cross section" '511 Patent, col. 26:17-18 This profile creates an "outwardly open slot" that houses the foot support bar assembly, hiding the mechanism from view and creating a cleaner, potentially safer apparatus ('511 Patent, Abstract; col. 2:3-11; Fig. 3).
• Technical Importance: This integrated design, where the foot bar mechanism is housed within the rail extrusion itself, represents a departure from designs with externally mounted or exposed components, potentially improving safety, cleanability, and aesthetics '511 Patent, col. 10:63-67

Key Claims at a Glance

• The complaint asserts independent claim 1 and reserves the right to assert others Compl. ¶¶48-49
• Claim 1 of the ’511 Patent recites the following essential elements:
  • 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. Design Patent No. D659,206 - Reformer Exercise Apparatus Frame

• Patent Identification: D659,206, issued May 8, 2012 Compl. ¶28
• Technology Synopsis: This patent claims the ornamental design for the reformer frame itself, separate from the carriage, footbar, and other components. The design features a continuous, smooth surface with curved corners and integrated leg supports D’206 Patent, Figs. 1-7
• Asserted Claims: Single design claim Compl. ¶31
• Accused Features: The overall ornamental appearance of the frame of the accused reformer machines Compl. ¶31

U.S. Design Patent No. D659,208 - Reformer Exercise Apparatus Footbar

• Patent Identification: D659,208, issued May 8, 2012 Compl. ¶36
• Technology Synopsis: This patent claims the ornamental design for the U-shaped footbar component of the reformer apparatus, including its specific curvature and connection points D’208 Patent, Figs. 1-7
• Asserted Claims: Single design claim Compl. ¶39
• Accused Features: The ornamental appearance of the footbar on the accused reformer machines Compl. ¶39

U.S. Patent No. 8,915,829 - Reformer Exercise Apparatus

• Patent Identification: 8,915,829, issued December 23, 2014 (Compl. ¶55).
• Technology Synopsis: A continuation of the '511 Patent application, the '829 Patent similarly claims a reformer apparatus with a specific side rail cross-section. Claim 1 requires an "inverted generally U shape in transverse cross section" formed by an upright outer wall, an integral top wall, and a sloping inner wall '829 Patent, col. 26:2-9
• Asserted Claims: Independent claim 1 is asserted as an example (Compl. ¶60).
• Accused Features: The frame, side rails, carriage, bias member, and foot support member of the accused reformers (Compl. ¶61).

U.S. Patent No. 9,132,311 - Reformer Exercise Apparatus Footbar Support Assembly

• Patent Identification: 9,132,311, issued September 15, 2015 (Compl. ¶66).
• Technology Synopsis: This patent claims the specific mechanical assembly that allows the footbar to be adjusted. The invention comprises a "slide plate" that moves within the side rail, a "hook plate" with discrete notches for setting the footbar angle, and a "locking member" to secure its position along the rail ('311 Patent, col. 26:45-67).
• Asserted Claims: Independent claim 1 is asserted as an example (Compl. ¶71).
• Accused Features: The footbar support and adjustment mechanism of the accused reformers (Compl. ¶72).

U.S. Patent No. 9,289,645 - Reformer Exercise Apparatus Arm Cord Retraction Assembly

• Patent Identification: 9,289,645, issued March 22, 2016 (Compl. ¶77).
• Technology Synopsis: This patent claims a mechanism mounted to the underside of the carriage for managing the arm cords. It includes a pair of spring-biased reels to retract the cords and a pair of mechanically linked "latch assemblies" that simultaneously hold or release both cords ('645 Patent, col. 26:48-61).
• Asserted Claims: Independent claim 1 is asserted as an example (Compl. ¶82).
• Accused Features: The arm cord retraction assembly of the accused reformers (Compl. ¶83).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are "knockoff Pilates reformer machines" used by Defendant Refined Pilates LLC in its exercise studio Compl. ¶¶5, 13 The complaint presents a photograph showing multiple reformer machines in the defendant's studio Compl. ¶14, Infringing Image 1

Functionality and Market Context

The complaint alleges these reformers are used to conduct Pilates classes for Defendant's customers (Compl. ¶¶27, 35). The functionality described includes a rectangular frame with parallel side rails, a movable carriage biased by springs, and an adjustable foot support bar (Compl. ¶¶50, 61). The complaint alleges Defendant is using these machines in its business operations despite having received notice of infringement (Compl. ¶¶15, 19).

IV. Analysis of Infringement Allegations

D'205 Patent Infringement Allegations

The complaint does not provide a limitation-by-limitation analysis for the D’205 design patent. Instead, it presents a side-by-side visual comparison chart juxtaposing figures from the patent with photographs of the accused products Compl. pp. 7-8 The complaint places Figure 1 of the patent, showing a full perspective view, next to "Infringing Image 1," a wide photograph of Defendant's studio Compl. p. 7 It also compares Figure 2, a head-on view from the patent, with "Infringing Image 2," a close-up photograph of the head end of an accused reformer Compl. p. 7 The infringement theory rests on the allegation that the similarities between the patented design and the accused products are "apparent" to an ordinary observer Compl. ¶23

• Identified Points of Contention: The central question for the D'205 patent will be whether an ordinary observer, familiar with prior art designs, would be deceived into purchasing the accused reformer believing it to be the one shown in the D'205 Patent. The analysis will focus on the overall visual impression created by the combination of the frame shape, footbar, carriage, and other visible components.

'511 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A central issue may be the construction of "inverted generally U shape." The analysis will question whether the specific geometry of the accused product's side rails—composed of an "upright wall, a horizontal wall, and a slanted inner wall" as alleged—falls within the scope of this claim language as it is defined by the patent's specification and drawings.
  • Technical Questions: The complaint's allegations regarding the specific cross-section of the side rails are made "on information and belief" (Compl. ¶50). This raises an evidentiary question as to what the actual, measured cross-sectional profile of the accused reformer's side rails is, and how that technical reality compares to the requirements of the claim.

V. Key Claim Terms for Construction

• The Term: "an outer surface inverted generally U shape in transverse cross section" (’511 Patent, Claim 1).
• Context and Importance: This term defines the core structural feature of the asserted independent claim. The outcome of the infringement analysis for the '511 and '829 patents will likely depend on how broadly or narrowly this geometric limitation is construed and whether the accused product's rails meet that definition. Practitioners may focus on this term because the allegation of infringement for this element is based "on information and belief," suggesting it is a potential point of dispute.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The use of the word "generally" suggests that the shape is not limited to the exact angles and proportions shown in the patent's figures. A party may argue that any three-sided, partially open channel with a top, an outer side, and an inner side qualifies, as long as it performs the function of housing the foot bar mechanism. The specification describes the shape as an "upright outer wall merging with a horizontal top wall which merges with a downwardly and inwardly slanted inner wall" ('511 Patent, col. 7:22-26), which could be read as a functional description rather than a strict geometric one.
  • Evidence for a Narrower Interpretation: A party may argue that the term is defined by the specific embodiment shown in Figure 3 of the patent. This figure depicts a distinct profile with a "slanted inner wall" at a particular angle and a specific relationship between the inner, top, and outer walls. The abstract also refers to a "downwardly slanted inner wall," suggesting this feature is a key aspect of the invention's shape ('511 Patent, Abstract).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement for all seven asserted patents. The factual basis for inducement is Defendant's alleged advertising and marketing of Pilates classes on its Instagram account, which features images of the accused reformers, and providing instructions to customers on how to use the machines during those classes Compl. ¶¶27, 54, 65, 76, 87
• Willful Infringement: The complaint alleges willful infringement based on knowledge obtained from a cease-and-desist letter sent by Plaintiff on December 17, 2025. It is alleged that Defendant's continued use of the accused products after receiving this actual notice constitutes willful, deliberate infringement Compl. ¶¶15, 19, 25, 52, 63, 74, 85

VII. Analyst’s Conclusion: Key Questions for the Case

This case presents several key questions for the court that span both design and utility patent law:

• A primary issue for the design patents will be a visual comparison: Will an ordinary observer, looking at the overall aesthetic of the accused reformers, be deceived into thinking they are the products depicted in the D'205, D'206, and D'208 patents?
• A central question for the '511 patent family will be one of definitional scope and factual correspondence: First, what is the precise geometric structure required by the claim term "an outer surface inverted generally U shape in transverse cross section"? Second, does the actual physical structure of the accused reformers' side rails, once examined in discovery, meet that definition?
• A key procedural question will be the impact of the prior ITC determination: To what extent will the ITC's finding that certain reformers infringe the '511, D'205, and D'208 patents influence the current district court proceedings, particularly on questions of infringement and willfulness?