DCT
1:24-cv-00012
Lightning Fitness Systems LLC v. Precor Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Lightning Fitness Systems LLC (Delaware)
- Defendant: Precor Incorporated (Delaware) and Peloton Interactive Incorporated (Delaware)
- Plaintiff’s Counsel: Garibian Law Offices, P.C.; houstonip (Of Counsel)
- Case Identification: 1:24-cv-00012, D. Del., 01/05/2024
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because both defendants are incorporated in Delaware.
- Core Dispute: Plaintiff alleges that Defendants’ smart treadmill products and associated services infringe a patent related to systems that integrate user-monitoring sensors with exercise equipment to provide real-time feedback and control.
- Technical Context: The technology at issue falls within the connected fitness domain, where exercise machines are integrated with sensors and software to create interactive and personalized workout experiences.
- Key Procedural History: The complaint details the prosecution history of the patent-in-suit and its family members, noting that the applicant distinguished the claims from prior art references, such as "Watterson", by arguing the prior art lacked features like measuring "control factors" against "set points" to control a device. This history may inform the scope of the asserted claims. The complaint also asserts the patented technology was unconventional at the time of invention.
Case Timeline
| Date | Event |
|---|---|
| 2013-03-15 | Priority Date for ’285 Patent (Provisional App. Filing) |
| 2017-11-14 | U.S. Patent No. 9,818,285 Issues |
| 2018-03-20 | U.S. Patent No. 9,922,574 (related patent) Issues |
| 2023-05-09 | U.S. Patent No. 11,645,929 (related patent) Issues |
| 2024-01-05 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,818,285 - "Method and Apparatus for Moving While Receiving Information"
- Patent Identification: U.S. Patent No. 9818285, "Method and Apparatus for Moving While Receiving Information", issued November 14, 2017.
The Invention Explained
- Problem Addressed: The patent identifies the dual problems of increasingly sedentary lifestyles linked to screen-based work and entertainment, and the general inefficiency of multitasking (Compl. ¶21, ¶23; ’285 Patent, col. 1:31-39, 1:60-2:5). Existing exercise equipment at the time of the invention allegedly lacked the ability to create an integrated feedback loop between a user's physiological state and the device's operation (Compl. ¶77-78).
- The Patented Solution: The invention describes a system that creates a feedback loop involving sensors, a computer processor, an output device, and a movement device. A "sensor relay" (e.g., a heart rate monitor) detects user information, which a processor analyzes against pre-defined or user-defined "set points." Based on this analysis, the system either sends a signal to an output device to instruct a "decision maker" (like the user or a coach) or sends a signal to directly and automatically control the movement device, for example, by causing a treadmill to slow down when a user's breathing indicates they are out of breath (Compl. ¶79; ’285 Patent, Abstract; ’285 Patent, col. 2:57-62).
- Technical Importance: The technology claims to provide an unconventional method for integrating sensory feedback with exercise, enabling automatic adjustment of equipment based on real-time user biometrics, thereby improving upon prior art systems that relied on manual adjustments (Compl. ¶90, ¶112).
Key Claims at a Glance
- The complaint asserts at least independent claims 1 and 4 (Compl. ¶137, ¶160).
- Independent Claim 1 (Method):
- A method of receiving sensory feedback while moving involving:
- one or more sensor relays;
- any number of output devices;
- any number of movement devices; and
- one or more computer processors that:
- receive a signal from the sensor relays, detecting information related to the user;
- analyze the detected information against one or more default or user-defined set points; and
- perform one of two actions: (1) send a signal to an output device to instruct a decision maker with feedback, or (2) send a signal to a movement device to control it based on the analysis.
- Independent Claim 4 (Apparatus):
- An apparatus comprising:
- one or more sensor relays; and
- either one or more output devices or one or more movement devices;
- wherein the sensor relay may detect information related to user "control factors" and may send signals to other components;
- the system then performs one of three actions: (1) the output devices translate and communicate signals to a decision maker, (2) the movement devices alter their operation based on the signal, or (3) other sensor relays use the information for further analysis.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are the "TRM apparatus" from Defendant Precor, specifically including the TRM 445 Treadmill, and the "PT apparatus" from Defendant Peloton, specifically including the Peloton Tread device (Compl. ¶137, ¶160-161).
Functionality and Market Context
- The accused products are internet-connected treadmills featuring large touchscreen displays. They are designed to operate in conjunction with external sensors, such as ANT+ or Bluetooth-enabled heart rate monitors, to track user biometrics during a workout (Compl. ¶141, ¶164).
- The complaint alleges that these systems collect user heart rate data, display it on the screen, and use it to provide a personalized workout. This includes features like Precor's "SmartRate" and "Heart Rate Zones" and Peloton's "Heart Rate Zones" and "Strive Score," which allegedly compare the user's real-time heart rate to pre-set target zones (Compl. ¶146, ¶169-171). Based on this comparison, the systems are alleged to either provide feedback to the user on the screen or automatically adjust the treadmill's speed and/or incline (Compl. ¶148, ¶171). A screenshot from a Precor manual shows a "SmartRate zone bar" that provides a visual indicator of the user's current heart rate relative to the active zone (Compl. p. 62). Similarly, a Peloton marketing image shows "On-screen metrics" including real-time heart rate, incline, and speed (Compl. p. 71).
IV. Analysis of Infringement Allegations
The complaint outlines separate infringement counts against Precor and Peloton, but the underlying theory of infringement is functionally identical for both. The following chart summarizes the allegations for the method of Claim 1 as applied to both accused product lines.
U.S. Patent No. 9,818,285 Infringement Allegations (Claim 1)
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation (Precor/Peloton) | Patent Citation |
|---|---|---|---|
| A method of receiving sensory feedback while moving involving: one or more sensor relays; | The systems use an attached heart rate monitor or chest/arm band, which acts as a sensor relay to detect the user's heart rate. A screenshot shows Precor's compatibility with a "Polar compatible chest strap transmitter" (Compl. p. 50). | ¶141 / ¶164, ¶168 | col. 3:57-67 |
| any number of output devices; | The systems include a touchscreen display which acts as an output device to present information to the user. A Peloton manual screenshot shows the "CLASS SCREEN" interface displaying various metrics (Compl. p. 82). | ¶142 / ¶165 | col. 4:19-27 |
| any number of movement devices; | The systems include a treadmill with a moving belt, which is a movement device that facilitates user movement. | ¶143 / ¶166 | col. 5:20-27 |
| and one or more computer processors that: receive a signal from any of the one or more sensor relays, detecting the information related to the user; | The processor within the treadmill console receives wireless signals (e.g., ANT+ or Bluetooth) from the heart rate monitor, thereby detecting the user's heart rate information. | ¶145 / ¶168 | col. 4:1-11 |
| analyze the detected information against one or more default or user defined set points; | The processor analyzes the user's heart rate against pre-set or user-defined target zones (e.g., "Heart Rate Zones," "SmartRate," "Strive Score") to determine if the user is in, above, or below their target exertion level. | ¶146 / ¶169 | col. 2:39-43 |
| and either: send a signal to any of the output devices, instructing the decision maker with feedback... | The processor sends signals to the touchscreen display, showing the user their current heart rate zone via colored bars and numbers, thereby instructing the user to adjust their effort to match the target. | ¶147 / ¶170 | col. 2:32-39 |
| or send a signal to any of the movement devices, controlling said movement devices based on said analysis. | The processor sends signals to the treadmill's motor to automatically adjust the speed or incline to keep the user within their selected heart rate zone. | ¶148 / ¶171 | col. 2:44-53 |
- Identified Points of Contention:
- Scope Questions: A central question will be whether a standard, off-the-shelf heart rate monitor (like a Polar strap) that wirelessly transmits data constitutes a "sensor relay" as that term is used in the patent. Similarly, does the user acting on visual cues on a screen qualify as "instructing the decision maker" in the manner required by the claim?
- Technical Questions: What is the specific nature of the "analysis" performed by the accused systems? The case may turn on whether the software merely executes a pre-programmed workout profile (e.g., "increase speed at minute 5") or if it performs a dynamic, real-time comparison of the user's biometric data against a "set point" to trigger a change in device operation, as the claim requires.
V. Key Claim Terms for Construction
The Term: "sensor relay"
Context and Importance: This term is foundational to the claimed apparatus and method. Its scope will determine whether readily available consumer electronics like ANT+ heart rate monitors fall within the claims. Practitioners may focus on this term because its construction could either sweep in a wide range of connected fitness products or narrow the claim scope to only custom-designed sensor systems.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification provides a broad definition, stating the term refers to "an apparatus composed of any or any combination of devices including but not limited to sensors... and relays" for sending sensory or positional information (Compl. ¶81; ’285 Patent, col. 3:57-65). This language may support an interpretation covering any device that senses and transmits data.
- Evidence for a Narrower Interpretation: The specification also describes highly specific embodiments, such as sensors that detect sweat gland moisture, nerve cell voltage, or pulse via vein movement (Compl. ¶100-103; ’285 Patent, col. 6:37-45, 7:13-20). A defendant could argue these specific, unconventional examples limit the term's scope to something more than a standard heart rate monitor.
The Term: "analyze the detected information against one or more default or user defined set points"
Context and Importance: This term defines the core logic of the invention. The infringement case hinges on whether the accused treadmills perform this specific type of analysis.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent describes "set points" as potentially "permanent or adjustable values of attributes that may be predefined by individuals, including but not limited to a user, an observer, or a manufacturer" (Compl. ¶82; ’285 Patent, col. 4:11-14). Plaintiff may argue this covers the pre-defined "Heart Rate Zones" used in the accused products.
- Evidence for a Narrower Interpretation: A defendant may argue that a "set point" implies a single target value, and that "analyzing" requires more than the simple categorization into broad percentage-based "zones" that the accused products allegedly perform. They might argue their systems follow a time-based script rather than a feedback-driven analysis against a specific set point.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement. Inducement is based on Defendants allegedly instructing and encouraging users to connect heart rate monitors and use the infringing features through user manuals and on-screen prompts (Compl. ¶150, ¶173). Contributory infringement is based on allegations that the systems are not staple articles of commerce and are especially adapted for the infringing use (Compl. ¶151, ¶174).
- Willful Infringement: The willfulness allegation is based on Defendants' continued infringement after having notice of the patent, at the latest, from the service of the complaint (Compl. ¶155, ¶178). The complaint does not allege pre-suit knowledge of the patent.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction: Can the term "sensor relay", which the patent illustrates with unconventional examples like nerve-voltage detectors, be broadly construed to cover standard, commercially available heart rate monitors as alleged by the Plaintiff?
- A key evidentiary question will be one of technical operation: Do the accused products' "Heart Rate Zone" and "Strive Score" features perform the specific, feedback-driven "analysis against a set point" required by the claims, or do they function in a technically distinct manner, such as by following a time-based workout script that is not dynamically controlled by real-time biometric analysis?
- A threshold legal battle may concern patent eligibility under § 101: As anticipated by the complaint's detailed arguments on the topic, a central question will be whether the claims are directed to a specific, tangible improvement in exercise machine technology or to the patent-ineligible abstract idea of gathering data, analyzing it, and providing feedback.