DCT
1:21-cv-01607
Peloton Interactive Inc v. Echelon Fitness Multimedia LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Peloton Interactive, Inc. (Delaware)
- Defendant: Echelon Fitness Multimedia, LLC (Delaware)
- Plaintiff’s Counsel: Latham & Watkins LLP; Morris, Nichols, Arsht & Tunnell LLP
- Case Identification: 1:21-cv-01607, D. Del., 06/30/2022
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant is a Delaware corporation and has committed acts of infringement in the district.
- Core Dispute: Plaintiff alleges that Defendant’s connected fitness devices and associated applications infringe a patent related to systems for providing on-demand exercise classes with synchronized, competitive features like a shared leaderboard.
- Technical Context: The technology operates in the at-home interactive fitness sector, which integrates exercise hardware with networked software to stream classes and create a competitive, community-based user experience.
- Key Procedural History: This Second Amended Complaint follows an original complaint filed on November 12, 2021. The asserted patent is part of a larger family of patents that have been the subject of prior litigation between the parties. Plaintiff alleges it put Defendant on notice of the asserted patent through the original complaint and a subsequent notice letter, which may form the basis for a willfulness claim.
Case Timeline
| Date | Event |
|---|---|
| 2012-07-31 | '886 Patent Priority Date |
| 2014-01-01 | First Peloton bikes delivered to customers (approx. date) |
| 2018-02-01 | Echelon announces intent to launch Connect bike (approx. date) |
| 2018-01-01 | Peloton Tread introduced to the public (approx. date) |
| 2019-09-26 | Peloton debuts on the NASDAQ stock exchange |
| 2021-11-09 | '886 Patent Issue Date |
| 2021-11-12 | Original Complaint filed, putting Echelon on notice |
| 2022-02-07 | Peloton sends notice letter to Echelon regarding '886 Patent |
| 2022-06-30 | Second Amended Complaint filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,170,886 - "Exercise System and Method"
- Patent Identification: U.S. Patent No. 11,170,886, "Exercise System and Method," issued November 9, 2021 (the “’886 Patent”).
The Invention Explained
- Problem Addressed: The patent identifies the drawbacks of traditional exercise options: in-studio classes are inconvenient due to fixed schedules and locations, while conventional at-home exercise is often unengaging and lacks a competitive element (Compl. ¶3; ’886 Patent, col. 2:7-12).
- The Patented Solution: The invention describes a networked exercise system that allows multiple users, in different locations, to participate in previously recorded on-demand classes. The system captures performance data (e.g., speed, power output) from each user's exercise device and synchronizes it, enabling users to compete in real-time against each other or against the recorded performance of "ghost participants" who have previously taken the class. This is often displayed via a leaderboard, recreating the motivational and competitive aspects of a live group class in an on-demand format (’886 Patent, Abstract; col. 4:56-64).
- Technical Importance: This approach sought to merge the convenience of at-home workouts with the engaging, competitive, and community-driven dynamics of in-studio fitness classes (Compl. ¶3).
Key Claims at a Glance
- The complaint asserts independent claims 1, 19, 26, and 27, as well as several dependent claims (Compl. ¶¶57-66).
- Independent Claim 1, a system claim, recites the following essential elements:
- A network of exercise devices enabling users to join a previously recorded on-demand class.
- The on-demand class includes exercise content and a "synchronizing signal" that marks a start and end point for collecting performance data, enabling synchronization.
- Sensors on the devices to measure user performance parameters.
- A "control station" that collects and synchronizes "live performance parameters" during a "live session of the on-demand exercise class."
- The control station provides the synchronized data back to the user devices, enabling participants to compete with each other during that session.
- The complaint reserves the right to assert additional claims.
III. The Accused Instrumentality
Product Identification
The accused products are collectively termed the "Echelon System," which includes Echelon's line of Smart Connect bikes, Stride treadmills, Row rowers, and Reflect smart mirrors ("Echelon Exercise Devices"), as well as the "Echelon Fit App" and "Echelon Reflect App" (Compl. ¶¶8, 81).
Functionality and Market Context
- The complaint alleges that the Echelon System provides users with access to both live and on-demand exercise classes through a subscription service (Compl. ¶¶72, 77). The Echelon Fit App is described as providing a "studio experience in your home" (Compl. ¶72).
- The system includes a back-end infrastructure that delivers class content, stores customer performance metrics, and provides this data back to users during classes (Compl. ¶¶75, 79).
- A key accused feature is an "advanced leaderboard" that allows users to "compete with friends" (Compl. ¶74). The complaint references an Echelon advertisement for its "New and Improved Leaderboard!" which includes an "Online Filter" that allows users to "see who is taking an On Demand class at the same time" (Compl. ¶¶95, 31). This image from an Echelon support page shows the leaderboard interface with the "Online Filter" feature highlighted and described. (Compl. p. 31).
IV. Analysis of Infringement Allegations
- ’886 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a network system comprising: a plurality of exercise devices connected to a network, the plurality of exercise devices enabling a plurality of users to participate in a previously recorded on-demand exercise class led by at least one instructor... | The Echelon System comprises Echelon Exercise Devices (bikes, treadmills, etc.) connected to a network (the internet), which allows users to participate in previously recorded on-demand classes (Compl. ¶¶8, 81, 84). Echelon marketing materials show options for "ON DEMAND... RIDES." (Compl. p. 29). | ¶¶81, 84 | col. 3:20-28 |
| ...the on-demand exercise class includes exercise content and at least one synchronizing signal that indicates a starting point and an ending point for collecting performance parameters associated with users' exercise performance...and the at least one synchronizing signal enables synchronization of the collected performance parameters; | Echelon's on-demand classes include exercise content and, on information and belief, a "synchronizing signal" to align performance data from users who participate in the same on-demand class (Compl. ¶80). | ¶80 | col. 13:58-14:2 |
| sensors associated with the plurality of exercise devices, the sensors measuring the performance parameters associated with the users' exercise performance; and | The Echelon Exercise Devices are alleged to include sensors that measure users' performance parameters (Compl. ¶82). | ¶82 | col. 5:62-6:4 |
| a control station collecting and synchronizing live performance parameters during a live session of the on-demand exercise class by: ...providing the synchronized live performance parameters to the plurality of exercise devices thereby enabling the plurality of users...to participate with each other during the live session of the on-demand exercise class. | Echelon's back-end system allegedly functions as the "control station," collecting, synchronizing, and providing performance data to users (Compl. ¶83). This enables competition via features like its "copycat leaderboard" (Compl. p. 30), which allows users taking an on-demand class to see each other's metrics (Compl. ¶95). | ¶¶83, 95 | col. 8:48-54 |
- Identified Points of Contention:
- Scope Questions: A central dispute may arise over the meaning of a "live session of the on-demand exercise class." The claim describes a "live session" built around a "previously recorded" class. The case may turn on whether Echelon's system, which allows users to concurrently participate in a recorded class, creates such a "live session," or if the term requires a more specific server-side architecture not present in the accused system.
- Technical Questions: The complaint alleges "on information and belief" that the Echelon system uses a "synchronizing signal" (Compl. ¶80). A key technical question for the court will be what evidence confirms the existence and operation of such a signal in the accused system, as opposed to an alternative, non-infringing method for aligning performance data.
V. Key Claim Terms for Construction
The Term: "live session of the on-demand exercise class"
Context and Importance: This phrase appears to be a term of art coined by the patentee to describe the novel user experience. Its construction is critical because it bridges the concepts of "live" (synchronous) interaction and "on-demand" (asynchronous) content. The infringement analysis for the entire "control station" limitation of Claim 1 hinges on whether the accused Echelon system facilitates such a "session."
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification states that "a plurality of remote users can simultaneously access the same recorded class and interact with each other in real time" (’886 Patent, col. 4:61-64). This language may support an interpretation where any concurrent participation in a recorded class by multiple users qualifies as a "live session."
- Evidence for a Narrower Interpretation: Elsewhere, the patent distinguishes between "live instructor-led" classes and "recorded cycling classes" (’886 Patent, col. 3:26-28). A defendant may argue this distinction implies that a "live session of the on-demand exercise class" must contain specific interactive elements beyond simple concurrent viewing to be considered "live."
The Term: "synchronizing signal"
Context and Importance: This term defines the core technical mechanism for enabling the competitive, multi-user experience in an on-demand class. Practitioners may focus on this term because the complaint's allegation that the accused system uses such a signal is made "on information and belief," indicating it is a point of factual uncertainty that will require technical discovery (Compl. ¶80).
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent describes the outcome of synchronization—allowing a rider who joins late to have their "data...synched correctly" (’886 Patent, col. 14:6-9). This may support a functional definition where any data or timestamp used by the server to align user performance timelines constitutes the "signal."
- Evidence for a Narrower Interpretation: Figure 17 of the patent depicts a distinct "GO" signal (422) and "STOP" signal (424) that define the comparison period. A defendant could argue this figure, combined with the claim language, requires a specific, discrete signal to be transmitted, rather than merely inferring alignment from data timestamps.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement under 35 U.S.C. § 271(b), stating that Echelon encourages and instructs customers to use the accused system in an infringing manner through its "manuals, guides, webpages, and videos" (Compl. ¶¶90-91). It is also alleged that Echelon provides the requisite hardware, software, and subscriptions with the knowledge and intent that customers will infringe (Compl. ¶92).
- Willful Infringement: Willfulness is alleged based on Echelon's purported knowledge of the ’886 Patent since at least the filing of the original complaint on November 12, 2021, and a formal notice letter sent on February 7, 2022 (Compl. ¶¶89, 102-103). The complaint alleges that infringement has continued despite this notice.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the patent’s unique phrase, "live session of the on-demand exercise class", be construed to read on Echelon's feature that allows users to simply take the same pre-recorded class at the same time, or does the term require a more structured, server-managed event?
- A key evidentiary question will be one of technical proof: what evidence will be produced to show that Echelon's back-end system uses a specific "synchronizing signal" to align user performance data, as claimed in the patent, versus a different, potentially non-infringing method of data comparison and display?