DCT
1:25-cv-03074
Strava Inc v. Garmin Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Strava, Inc. (Delaware)
- Defendant: Garmin Ltd. (Switzerland) and Garmin International, Inc. (Kansas)
- Plaintiff’s Counsel: Faegre Drinker Biddle & Reath LLP
- Case Identification: 1:25-cv-03074, D. Colo., 09/30/2025
- Venue Allegations: Venue is alleged against Garmin International, Inc. based on its regular and established place of business in Boulder, Colorado. Venue against Garmin Ltd., an alien corporation, is asserted as proper in any judicial district.
- Core Dispute: Plaintiff alleges that Defendant’s Garmin Connect platform and associated fitness devices infringe patents related to GPS-based activity segment matching and popularity-based route generation.
- Technical Context: The lawsuit concerns core technologies in the digital fitness and activity tracking market, where GPS data from users' activities is aggregated and analyzed to provide competitive and social features.
- Key Procedural History: The complaint alleges that the parties entered into a Master Cooperation Agreement ("MCA") in 2015, which granted Garmin a narrow license to integrate "Strava Segments" into its devices. Strava alleges Garmin exceeded the scope of this license and, in parallel, infringed its patents. The complaint also notes that Strava provided written notice of infringement to Garmin by June 30, 2025.
Case Timeline
| Date | Event |
|---|---|
| 2009 | Strava founded |
| 2011-03-31 | Earliest Priority Date for ’922 Patent |
| 2013-12-11 | Earliest Priority Date for ’651 and ’053 Patents |
| 2014 | Garmin launches its own "segment" feature |
| 2015-04-08 | Strava and Garmin enter Master Cooperation Agreement (MCA) |
| 2015-08-25 | U.S. Patent No. 9,116,922 Issues |
| 2016-03-29 | U.S. Patent No. 9,297,651 Issues |
| 2017-10-03 | U.S. Patent No. 9,778,053 Issues |
| 2025-06-30 | Strava provides written notice of infringement to Garmin |
| 2025-07-XX | Strava provides second written notice of infringement |
| 2025-09-30 | Complaint filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,116,922 - “Defining and matching segments,” Issued August 25, 2015
The Invention Explained
- Problem Addressed: The patent's background describes the difficulty for athletes to manually synchronize their activities to compare performance over the same geographical terrain, noting such attempts are often "inefficient and imprecise" (’922 Patent, col. 1:19-20).
- The Patented Solution: The invention provides a system for users to define a "segment"—a specific portion of a route—from GPS data. The system then automatically detects when other GPS-tracked activities, or "efforts," match that segment. A core technical aspect is the creation of a "virtual start line" based on the path and orientation of the segment, which is then used to determine if an effort crosses it and thus qualifies for a match (’922 Patent, Abstract; col. 10:25-44). Figure 12 illustrates the geometric creation of this virtual start line relative to GPS points from an effort.
- Technical Importance: This technology automates asynchronous competition, allowing users to compete against each other's times on the same course without having to be there at the same time, a foundational feature for social fitness platforms (Compl. ¶31).
Key Claims at a Glance
The complaint asserts independent claims 1 (method) and 15 (system), as well as dependent claims 11 and 12 (Compl. ¶69).
- Essential Elements of Independent Claim 1:
- Receiving a user-submitted definition of a segment associated with a first set of GPS data.
- Generating a "virtual start line" by determining a path through a selected start point, determining the path's orientation, and setting the line in relation to that orientation.
- Determining that a subsequent "effort" (with a second set of GPS data) matches the segment, based at least in part on the effort's GPS data crossing the virtual start line.
- Accessing information associated with the matched segment.
The complaint reserves the right to assert additional claims (Compl. ¶69).
U.S. Patent No. 9,297,651 - “Generating user preference activity maps,” Issued March 29, 2016
The Invention Explained
- Problem Addressed: The patent identifies that typical mapping technology uses functional road classifications (e.g., arterial, collector) which are not based on the "actual behavior of athletes," making conventional routing technology suboptimal for cyclists and runners (’651 Patent, col. 1:12-21). It also notes the difficulty in obtaining accurate elevation profiles for routes (’651 Patent, col. 1:30-40).
- The Patented Solution: The invention describes collecting a large number of GPS-tracked user activities and aggregating them onto a base map to create a "user-preference map." This map reflects how people actually use roads and trails. The system can then determine suggested routes between two points based on this user preference map and user-input preferences like desired elevation or popularity (’651 Patent, Abstract; col. 3:20-34). The solution also includes a method for improving elevation accuracy by normalizing barometric data from user devices against looked-up elevation data (’651 Patent, col. 4:40-50).
- Technical Importance: This approach leverages crowdsourced community data to generate routes that are tailored to the preferences and habits of specific user groups (e.g., cyclists), a significant improvement over generic, car-centric routing algorithms (Compl. ¶4, 47).
Key Claims at a Glance
The complaint asserts independent claims 1 (system) and 23 (computer program product), as well as several dependent claims (Compl. ¶87).
- Essential Elements of Independent Claim 1:
- A user activity data collection engine that collects user activities and mines the data based on an order associated with GPS device types.
- A map data aggregation engine that determines a "user preference map" by analyzing and aggregating the user activities onto a base map.
- A map querying engine that determines suggested routes between two endpoints based at least in part on the user preference map.
The complaint reserves the right to assert additional claims (Compl. ¶87).
U.S. Patent No. 9,778,053 - “Generating user preference activity maps,” Issued October 3, 2017 (Multi-Patent Capsule)
- Technology Synopsis: As a continuation of the '651 Patent, this patent claims computer-implemented pipelines for generating and using a "user-preference map." The claimed system involves collecting GPS activities, mining them according to device-type accuracy, aggregating them to a base map, and then using the resulting map to generate suggested routes based on user-specified endpoints (Compl. ¶99).
- Asserted Claims: Claims 1, 3, 9, 10, and 21 (Compl. ¶101).
- Accused Features: The accused features are Garmin's Trendline/Popularity routing, heatmaps, and Courses features, which are alleged to use aggregated community GPS data to generate route suggestions (Compl. ¶102).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are the Garmin Connect web and mobile application, Garmin's "Popularity/Trendline" routing and heatmap features, and various Garmin GPS-enabled hardware devices, including the Edge, Forerunner, Fenix, and Epix product lines (Compl. ¶57).
Functionality and Market Context
- The complaint alleges that Garmin is a leading provider of GPS fitness hardware (Compl. ¶7). The accused functionality falls into two main categories:
- Segment Functionality: The Garmin Connect platform allows users to define "Garmin segments" from their GPS activity tracks (Compl. ¶71). A screenshot illustrating the "Create Segment" user interface shows a user selecting start and end points from a past activity to define a new segment (Compl. p. 19). Garmin devices then allegedly alert users when they approach these segments and automatically record their performance for comparison on leaderboards (Compl. ¶71, 74).
- Popularity Routing: Garmin's "Trendline Popularity Routing" feature is described as utilizing "billions of miles from Garmin Connect™ online network data to help you find and follow the best paths for your bike or run activity" (Compl. p. 28). This functionality allegedly generates route suggestions based on the most popular routes taken by the Garmin community, as visualized in heatmap displays that show high-traffic routes (Compl. ¶91). A screenshot of a heatmap over the Denver metro area illustrates this aggregation of user activity data (Compl. p. 10).
IV. Analysis of Infringement Allegations
’922 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| receiving a user submitted definition of a segment... associated with a first set of [GPS] data | Garmin Connect allows users to define a segment by selecting start and end points from a map of a previously recorded GPS activity. | ¶71, p. 19 | col. 2:46-48 |
| generating a virtual start line... based at least in part on... determining an orientation of the path; and setting the virtual start line in relation to the orientation | Garmin devices allegedly detect when a user's path approaches a stored segment and present a segment screen, which the complaint alleges involves generating and using a segment start line aligned to the path's orientation. | ¶71 | col. 2:48-55 |
| determining that the second set of GPS data [from an effort] crosses the virtual start line... | Garmin devices allegedly determine a match by comparing the user's live activity GPS data to the stored start line. A screenshot of a Garmin device "Racing a Segment" shows real-time progress, which implies a match has been determined after crossing a start point. | ¶71, p. 21 | col. 2:59-62 |
| determining that the effort matches the segment based at least in part on the crossing, and accessing information associated with the matched segment | Upon completion of a segment, Garmin's system records the result and populates leaderboards with performance data. | ¶71, 75 | col. 2:62-65, 3:1 |
- Identified Points of Contention:
- Technical Question: What evidence does the complaint provide that Garmin's system performs the specific step of "generating a virtual start line" based on "determining an orientation of the path"? The complaint alleges this functionality (Compl. ¶71), but the provided evidence does not detail the underlying technical method Garmin uses to trigger a segment start.
- Scope Question: The complaint alleges Garmin's system determines a match via "extrapolation" from performance metrics (Compl. ¶64), a feature described in the patent. A key question will be whether discovery reveals evidence of such an extrapolation, or if Garmin uses a simpler proximity-based method that may fall outside the claim's scope.
’651 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| ...collecting a plurality of user activities... wherein to collect... comprises to mine user activity data based... on an order associated with... GPS recording device types | Garmin's "Trendline Popularity Routing" is based on "billions of miles from Garmin Connect™ online network data" (Compl. p. 28). The complaint alleges this involves collecting and prioritizing activities recorded on different device types to favor higher-accuracy sources (Compl. ¶88). | ¶88, 91 | col. 28:46-55 |
| ...determine a user preference map based... on analyzing the plurality of user activities to aggregate user activity data associated with a base map | Garmin allegedly generates a "user-preference map" (e.g., its popularity/heatmap datasets) by aggregating user activities onto a base map and storing edge-level metadata like popularity counts. The heatmap for Olathe visually represents this aggregation (Compl. p. 28). | ¶88, 91 | col. 28:56-60 |
| ...determine one or more suggested routes between a user input first endpoint and a user input second endpoint based at least in part on the user preference map | Garmin devices offer a "Popularity Routing" setting that "Calculates routes based on the most popular runs and rides from Garmin Connect," which the complaint alleges is the use of the user-preference map to generate routes (Compl. p. 29). | ¶88, 91 | col. 28:61-65 |
- Identified Points of Contention:
- Technical Question: A central factual question will be whether Garmin's system actually performs the claimed step of "mining user activity data based at least in part on an order associated with a plurality of GPS recording device types." While the complaint alleges this (Compl. ¶88), the public-facing documents cited do not explicitly confirm this device-based prioritization, suggesting this will be a focus of discovery.
- Scope Question: Does Garmin's collection of "billions of miles" of data and its use in routing and heatmaps meet the full definition of generating and using a "user-preference map" as claimed? While the functionality appears similar on its face, the dispute may turn on specific technical details of how Garmin aggregates and stores the data relative to a "base map."
V. Key Claim Terms for Construction
’922 Patent
- The Term: "generating a virtual start line... based at least in part on... determining an orientation of the path" (Claim 1)
- Context and Importance: This term defines the specific technical method for creating the trigger that determines a segment match. The infringement analysis for the '922 Patent may hinge on whether Garmin's segment-detection mechanism can be shown to perform this claimed process, versus a simpler geofencing or proximity alert.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent describes the virtual start line as being "perpendicular to the path direction at the selected start point" (’922 Patent, col. 10:29-30), which could support a construction covering any method that orients a line relative to the segment's direction of travel at its beginning.
- Evidence for a Narrower Interpretation: Figure 12 of the patent illustrates a specific geometric construction involving a linear path between two GPS points. A defendant may argue that the term requires this specific calculation and does not read on other methods for establishing a start-of-segment boundary.
’651 Patent
- The Term: "mine user activity data based at least in part on an order associated with a plurality of GPS recording device types" (Claim 1)
- Context and Importance: This limitation is a key point of novelty, as it claims not just aggregating data, but doing so in a way that prioritizes more accurate data sources to reduce noise. Practitioners may focus on this term because proving that Garmin's system implements this specific prioritization logic will be critical for infringement of the '651 and '053 patents.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification provides an example where data from devices known to have better accuracy (e.g., Garmin Edge 805 or 810) is "mined first" (’651 Patent, col. 10:35-42). This could support a broad interpretation that covers any system that weights or preferentially uses data from more accurate device classes.
- Evidence for a Narrower Interpretation: A defendant could argue that this term requires a strict, sequential mining process based on a pre-defined device hierarchy, and that a different weighting algorithm (or no device-specific weighting at all) would not infringe.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement by citing Garmin's publicly available user guides and support articles that instruct users on how to create and "race" segments (Compl. ¶77, 93). A cited screenshot provides step-by-step instructions for "Creating a Garmin Segment in Garmin Connect Web" (Compl. p. 19).
- Willful Infringement: Willfulness allegations are based on two grounds: 1) Garmin's alleged pre-suit knowledge of Strava's technology gained through the collaboration under the 2015 MCA, and 2) Garmin's alleged continued infringement after receiving explicit written notice of infringement from Strava on or by June 30, 2025 (Compl. ¶60, 78, 94).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of technical implementation: For the ’922 patent, can Strava demonstrate that Garmin's method for detecting a segment start performs the specific claimed steps of "generating a virtual start line" based on "path orientation"? For the ’651 and ’053 patents, can Strava prove through discovery that Garmin's routing algorithm "mines" data according to an "order associated with... GPS recording device types"? The public-facing evidence is suggestive but not definitive on these technical details.
- A second central question will be the interplay of contract and patent law: How will the history of the 2015 MCA between the parties influence the case? The court will likely need to analyze what knowledge and rights Garmin obtained under the agreement to distinguish between legitimate, licensed activity or independent development and what Strava alleges is a breach of contract and infringement of its intellectual property.
- Finally, a key evidentiary question will be one of functional equivalence: Even if Garmin’s systems do not literally perform every claimed step, does the functionality of Garmin's segment matching and popularity routing perform in substantially the same way to achieve substantially the same result as the patented inventions? The visual similarity of the features, such as the segment creation interface and popularity heatmaps, suggests this may be a central point of contention.