DCT
1:25-cv-13609
Path Vibe LLC v. Geometry Int
Key Events
Amended Complaint
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., 11/11/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendants target U.S. consumers, including those in Illinois, through interactive e-commerce websites and because Plaintiff purchased an accused product that was shipped to Illinois.
- Core Dispute: Plaintiff alleges that Defendants’ exercise mats, which incorporate Bluetooth speakers and speakerphone functionality, infringe a patent related to exercise mats with integrated audio components.
- Technical Context: The technology involves embedding electronic audio systems directly into flexible exercise mats, combining a common piece of fitness equipment with a personal audio device to enhance convenience during workouts.
- Key Procedural History: The filing is a First Amended Verified Complaint. The complaint does not mention any prior litigation, licensing history, or post-grant proceedings involving 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 |
| 2025-11-11 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,506,455 - "Exercise Mat with Integrated Audio"
- Patent Identification: U.S. Patent No. 8,506,455, "Exercise Mat with Integrated Audio", issued August 13, 2013.
The Invention Explained
- Problem Addressed: The patent addresses the need for a convenient method for an individual to listen to audio during exercise without requiring separate, external speakers or headphones. This is described as particularly useful in group exercise scenarios where participants need to clearly hear an instructor, or for individuals listening to music or instructional recordings from a personal device (’455 Patent, col. 2:41-48).
- The Patented Solution: The invention is an exercise mat made of a flexible material that has speakers and an audio interface embedded directly into it ('455 Patent, col. 2:3-10). This integrated interface can receive audio signals from an external source (such as a smartphone or MP3 player) either wirelessly or through a cable, amplify the signal, and play it through the built-in speakers ('455 Patent, Abstract; Fig. 1). The specification also describes the inclusion of a microphone and a "speakerphone circuit" to enable hands-free calls ('455 Patent, col. 2:33-39).
- Technical Importance: The invention consolidates two distinct products—a passive exercise mat and an active audio playback system—into a single, integrated unit, potentially simplifying the user's equipment needs for a workout.
Key Claims at a Glance
- The complaint asserts independent claim 1 ('455 Patent, col. 2:57-68; Compl. ¶19).
- Claim 1 of the ’455 Patent 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 an external source and output an amplified signal to the speaker;
- Wherein the audio interface comprises a speakerphone circuit.
III. The Accused Instrumentality
Product Identification
- The "Bambilo Exercise Mat with Built-in Bluetooth Speakers" (ASIN B0B6FCYZ75) ('Compl. ¶20).
Functionality and Market Context
- The accused product is described as a flexible exercise mat made of pliable polymer material ('Compl. ¶20a). It allegedly incorporates an audio interface with control buttons and a Bluetooth module that allows for wireless pairing with external devices like smartphones to stream audio ('Compl. ¶¶20b, 20c). The complaint further alleges that the product includes an "integrated speaker and microphone circuit" that enables two-way communication, such as answering phone calls ('Compl. ¶20d).
- The product is allegedly marketed under the "BAMBILO" brand and sold on e-commerce platforms by a seller operating under the alias "Geometry Int" ('Compl. ¶¶3, 11).
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint.
Claim Chart Summary
8,506,455 Patent Infringement Allegations
| 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 (e.g., EVA or PVC) designed for physical exercise or yoga. | ¶20a | col. 2:58-59 |
| at least one speaker integrated into said flexible mat | The accused product includes an integrated speaker as part of its speakerphone system. | ¶20d | col. 2:60 |
| 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 has an integrated audio interface with a Bluetooth module for receiving audio wirelessly from devices like smartphones, along with control buttons for playback. | ¶¶20b, 20c | col. 2:61-65 |
| wherein said audio interface comprises a speakerphone circuit | The product's Bluetooth module and an "integrated speaker and microphone circuit" allegedly enable two-way communication for answering or rejecting calls, which together are alleged to constitute the speakerphone circuit. | ¶20d | col. 2:33-36 |
Identified Points of Contention
- Scope Questions: A central issue may be whether the term "speakerphone circuit" can be construed to cover the functionality provided by a standard Bluetooth hands-free protocol, which is a common feature in many consumer electronics. The defense may argue that the term requires a more specific hardware configuration than what is alleged.
- Technical Questions: The analysis may turn on the physical nature of the integration. The complaint alleges the audio interface is "embedded into the body or attached housing of the mat" (Compl. ¶20b). A potential point of dispute is whether an electronic module in an "attached housing" satisfies the claim limitation "integrated into said flexible mat," or if the claim requires components to be physically embedded within the mat’s layers.
V. Key Claim Terms for Construction
The Term: "speakerphone circuit"
Context and Importance: This term appears to be the most specific limitation in claim 1. Its construction will be critical in determining whether the accused product's alleged capability to handle phone calls via a standard Bluetooth connection falls within the scope of the claim.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes this feature functionally, stating "the mat may be configured to provide speakerphone functionality by incorporating a speakerphone circuit into the audio interface" ('455 Patent, col. 2:33-36). This lack of structural detail could support a broader, function-based interpretation that encompasses standard wireless protocols.
- Evidence for a Narrower Interpretation: The use of the word "circuit" could be argued to imply a specific set of electronic components dedicated to the speakerphone function, potentially narrower than the multipurpose functionality of a standard Bluetooth chipset. The patent does not provide a schematic, which may lead a defendant to argue the term is limited to its plain and ordinary meaning in electrical engineering.
The Term: "integrated into"
Context and Importance: This term dictates the required physical relationship between the electronic components (speaker, audio interface) and the mat itself. The infringement question may depend on whether placing electronics in a housing attached to the mat's surface meets this limitation.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The complaint alleges the accused product's interface is "embedded into the body or attached housing of the mat" (Compl. ¶20b), suggesting Plaintiff views attachment as a form of integration. The patent's general description of components being "embedded into the mat" ('455 Patent, col. 2:5-10) could be argued to encompass various methods of combining the elements into a single unit.
- Evidence for a Narrower Interpretation: The patent repeatedly uses the term "embedded" when describing the placement of the speaker drivers and audio interface ('455 Patent, col. 2:5, col. 2:10). A defendant could argue that "integrated into" requires the components to be physically inside the material of the mat, not merely affixed to its exterior in a separate housing.
VI. Other Allegations
- Indirect Infringement: The complaint does not plead specific facts to support claims of induced or contributory infringement, though the prayer for relief includes a request to enjoin "Aiding, abetting, [or] contributing to" infringement (Compl. ¶1b).
- Willful Infringement: The complaint alleges that Defendants' infringement was "knowing[] and willful[]" and undertaken "with knowledge of Plaintiff's patent rights" (Compl. ¶¶18, 22). However, the complaint does not allege specific facts establishing pre-suit knowledge of the ’455 Patent, such as a cease-and-desist letter or prior dealings.
VII. Analyst’s Conclusion: Key Questions for the Case
This dispute appears to center on the interpretation of two key claim phrases, raising fundamental questions of scope for the court.
- A core issue will be one of definitional scope: can the term "speakerphone circuit," as used in the patent, be construed to read on the common hands-free calling feature of a standard Bluetooth module, or does it require a more distinct and specific electronic configuration?
- A second key issue will be one of physical scope: does placing an electronic audio module within an "attached housing" on an exercise mat satisfy the "integrated into said flexible mat" limitation, or must the components be physically embedded within the structural layers of the mat itself?