DCT
1:25-cv-13609
Path Vibe LLC v. Geometry Int
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Path Vibe LLC (Delaware)
- Defendant: Geometry Int and Guangzhou Pinling Network Technology Co., Ltd. (China)
- Plaintiff’s Counsel: Nicholas S. Lee
- Case Identification: 1:25-cv-13609, N.D. Ill., 11/06/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Illinois because Defendants target U.S. consumers, including those in Illinois, through interactive e-commerce stores and because Plaintiff purchased and received an accused product within the district.
- Core Dispute: Plaintiff alleges that Defendants’ exercise mats, which incorporate integrated speakers and Bluetooth connectivity, infringe a patent related to exercise mats with built-in audio interfaces.
- Technical Context: The technology involves embedding audio playback and communication capabilities, such as speakers and microphones, directly into the structure of a flexible exercise mat.
- Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2009-07-28 | U.S. Patent No. 8,506,455 Priority Date |
| 2013-08-13 | U.S. Patent No. 8,506,455 Issued |
| 2025-11-06 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. 8506455, “EXERCISE MAT WITH INTEGRATED AUDIO,” issued August 13, 2013 (’455 Patent).
The Invention Explained
- Problem Addressed: The patent addresses the use of exercise mats in workout settings, where users may wish to listen to instructional audio or music without the inconvenience of separate audio equipment (’455 Patent, col. 1:11-13; col. 2:41-48).
- The Patented Solution: The invention is a flexible exercise mat with integrated audio components, including at least one speaker and an audio interface embedded into the mat’s material. This interface is designed to receive an audio signal from an external source (e.g., a smartphone) and output an amplified signal to the built-in speakers, with a specific configuration that includes a "speakerphone circuit" to enable two-way communication (’455 Patent, Abstract; col. 2:32-40). The overall system is illustrated in Figure 1, which shows a user on a mat (100) wirelessly connected to external audio sources (106, 108, 110).
- Technical Importance: This approach provides a self-contained system for audio playback and communication during physical activity, potentially enhancing safety and convenience by eliminating the need for separate devices or headphones (’455 Patent, col. 2:41-48).
Key Claims at a Glance
- The complaint asserts independent Claim 1 of the ’455 Patent (Compl. ¶19).
- Claim 1 requires:
- a flexible mat of a size suitable for use as an exercise mat;
- at least one speaker integrated into said flexible mat;
- an audio interface integrated into said flexible mat and configured to receive an audio signal from at least one audio source external to the exercise mat and to output an amplified audio signal to the at least one speaker,
- wherein said audio interface comprises a speakerphone circuit.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
- The "Bambilo Exercise Mat with Built-in Bluetooth Speakers," identified by ASIN B0B6FCYZ75 (Compl. ¶20).
Functionality and Market Context
- The accused product is described as a flexible mat made of pliable polymer material designed for exercise or yoga activities (Compl. ¶20a).
- It allegedly incorporates an audio interface with control buttons, indicator lights, and a Bluetooth module that is embedded into the mat’s body or an attached housing (Compl. ¶20b). This interface allows wireless pairing with external devices like smartphones to stream audio content (Compl. ¶20c).
- The complaint alleges the product includes an "integrated speaker and microphone circuit enabling two-way communication," which permits a user to answer or reject calls while exercising (Compl. ¶20d).
- The product is allegedly sold to U.S. consumers through online storefronts, including one operated by Defendant Geometry Int (Compl. ¶3, ¶13).
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint.
Claim Chart Summary
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a flexible mat of a size suitable for use as an exercise mat; | The accused product is a flexible mat made of pliable polymer material designed for physical exercise or yoga activities. | ¶20a | col. 2:59-60 |
| at least one speaker integrated into said flexible mat; | The product allegedly includes an "integrated speaker and microphone circuit," which implies the presence of a speaker. | ¶20d | col. 2:60-61 |
| an audio interface integrated into said flexible mat and configured to receive an audio signal from at least one audio source external to the exercise mat and to output an amplified audio signal to the at least one speaker, | The product allegedly incorporates an audio interface with a Bluetooth module that pairs with external devices to stream audio content wirelessly. | ¶20b, ¶20c | col. 2:61-65 |
| wherein said audio interface comprises a speakerphone circuit. | The product includes an integrated speaker and microphone circuit for two-way communication, allowing a user to answer or reject calls. The complaint alleges this system constitutes the claimed "speakerphone circuit." | ¶20d | col. 2:65-3:1 |
Identified Points of Contention
- Scope Questions: A central dispute may arise over the proper construction of "speakerphone circuit." The question for the court will be whether the combination of a "Bluetooth module and speakerphone system" in the accused product, as alleged in the complaint, constitutes the specific "circuit" limitation required by the claim (Compl. ¶20d).
- Technical Questions: An evidentiary question may be whether the accused product’s general-purpose Bluetooth audio functionality, which often includes hands-free calling features, is structurally and functionally the same as the "speakerphone circuit" contemplated by the patent. The complaint alleges these components "together constitute the claimed speakerphone circuit," a characterization that may be contested (Compl. ¶20d).
V. Key Claim Terms for Construction
- The Term: "speakerphone circuit"
- Context and Importance: This term is the most specific technical limitation in the independent claim and appears to be the primary feature distinguishing the invention from a simple mat with speakers. The outcome of the infringement analysis may depend heavily on whether the accused product's call-handling hardware and software meet the definition of this term.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification does not provide an explicit definition. A party might argue for a broader, functional definition, pointing to language describing how the mat "may be configured to provide speakerphone functionality by incorporating a speakerphone circuit into the audio interface" when the audio source is a smart phone (’455 Patent, col. 2:32-36). This could support an interpretation where any circuit that enables hands-free, two-way audio communication qualifies.
- Evidence for a Narrower Interpretation: A party might argue that the term requires a specific, discrete hardware component distinct from a general-purpose Bluetooth chipset. The claim language uses the structural term "circuit" rather than functional language like "configured to perform a speakerphone function." The specification also describes incorporating a microphone "into the mat" as part of this feature, which could be argued as a required structural element of the circuit's implementation (’455 Patent, col. 2:37).
VI. Other Allegations
- Indirect Infringement: The complaint makes a passing allegation of direct and/or indirect infringement (Compl. ¶18) and requests injunctive relief against aiding and abetting (Prayer ¶1b). However, it does not plead specific facts to support the knowledge and intent elements required for claims of induced or contributory infringement.
- Willful Infringement: The complaint alleges that Defendants' infringement was "knowing[] and willful[]" and "undertaken with knowledge of Plaintiff's patent rights" (Compl. ¶18, ¶22). These allegations are conclusory and are not supported by specific facts in the complaint, such as evidence of pre-suit notification.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction: how will the court define the term "speakerphone circuit"? Will it be interpreted broadly to cover the common hands-free calling feature of modern Bluetooth audio systems, or will it be construed more narrowly to require a specific hardware structure as disclosed in the patent?
- A key evidentiary question will be one of technical correspondence: assuming a construction is adopted, what is the actual architecture of the accused product's electronics? Does the combination of its Bluetooth module, microphone, and speaker function as, and structurally constitute, the claimed "speakerphone circuit," or is there a material difference in its design and operation?