DCT
2:20-cv-00184
Finish Time Holdings LLC v. Garmin Intl Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Finish Time Holdings, LLC (Texas)
- Defendant: Garmin International Inc. (Kansas)
- Plaintiff’s Counsel: Sheridan Ross P.C.; Murray Plumb & Murray
- Case Identification: 2:20-cv-00184, D. Me., 05/22/2020
- Venue Allegations: Plaintiff alleges venue is proper in the District of Maine based on Defendant’s regular and established place of business in Yarmouth, Maine, and its operation of an interactive website, Garmin Connect, accessible to customers within the district. The complaint also notes a prior agreement between the parties that this district is the proper venue for this action.
- Core Dispute: Plaintiff alleges that Defendant’s Garmin Coach and Garmin Gear Tracking features, offered through its Garmin Connect platform, infringe three patents related to remote athletic coaching and automated tracking of athletic equipment usage.
- Technical Context: The technology at issue falls within the networked fitness and wearable device sector, where platforms integrate data from GPS-enabled devices to provide athletes and coaches with tools for performance monitoring and equipment management.
- Key Procedural History: The complaint states that Plaintiff originally sued Garmin Ltd. in the Eastern District of Texas, but the parties conferred and agreed that Garmin International Inc. was the proper defendant and that venue was proper in the District of Maine. The complaint also details the prosecution history of the asserted patents, noting that claims in all three were initially rejected under 35 U.S.C. § 101 as abstract ideas. For U.S. Patent Nos. 9,345,948 and 9,889,340, the rejections were withdrawn after applicant arguments. For U.S. Patent No. 10,124,234, the rejection was overcome on appeal to the Patent Trial and Appeal Board (PTAB), which found the claims were directed to a technological improvement.
Case Timeline
| Date | Event |
|---|---|
| 2011-05-31 | Priority Date for U.S. Patent No. 10,124,234 |
| 2012-10-19 | Priority Date for U.S. Patent Nos. 9,345,948 and 9,889,340 |
| 2016-05-24 | U.S. Patent No. 9,345,948 Issued |
| 2018-02-13 | U.S. Patent No. 9,889,340 Issued |
| 2018-07-10 | Date of YouTube video introducing Garmin Coach |
| 2018-11-13 | U.S. Patent No. 10,124,234 Issued |
| 2020-04-17 | Date Plaintiff alleges Garmin gained knowledge of Asserted Patents |
| 2020-05-22 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,889,340 - “Method for Providing a Coach with Live Training Data of an Athlete as the Athlete is Training”
Issued February 13, 2018
The Invention Explained
- Problem Addressed: The patent family addresses the challenge athletes face in maintaining a relationship with a preferred coach after moving to a new location, which can disrupt training continuity and effectiveness (Compl. ¶12; U.S. Patent No. 9,345,948, col. 1:24-34).
- The Patented Solution: The invention is a method that uses a computer web-based platform to facilitate remote coaching. The method involves creating an athlete profile on a training log server, receiving workout data from a mobile device carried by the athlete during training, updating the athlete's training record with this data (including distance and time), and permitting a selected coach to be granted access to log onto the platform and view the training record as the data is being entered (’340 Patent, Claim 1; ’948 Patent, Fig. 9).
- Technical Importance: The claimed method provides a technical framework for near-real-time, data-driven remote coaching, potentially negating the need for geographic proximity between an athlete and their coach (Compl. ¶12).
Key Claims at a Glance
- The complaint asserts claims 1, 3, 4, 8, 9, 12, 13, and 14, with independent claim 1 being central (’340 Patent, Claim 1; Compl. ¶51).
- Independent Claim 1 requires:
- Creating an athlete profile on a training log server of a computer web-based platform.
- The athlete profile includes a training record with predefined fields for at least a distance aspect and a time aspect of a workout.
- Receiving from the athlete a selection of a coach to be granted access.
- Updating the training record with workout data (including distance and time) from a mobile tracking device carried by the athlete as the athlete is performing the workout.
- Permitting the selected coach to log onto the platform and view the training record as the athlete is performing the workout.
U.S. Patent No. 10,124,234 - “System and Method for Tracking the Usage of Athletic Equipment”
Issued November 13, 2018
The Invention Explained
- Problem Addressed: The patent aims to solve the problem of athletes being unaware of the wear and tear on their equipment, which could lead to inconvenience or injury, such as a worn bicycle tire failing during a ride (Compl. ¶11). Existing tracking systems were described as being limited in their features (’234 Patent, col. 1:19-22).
- The Patented Solution: The invention is a system that automates the tracking of equipment usage. It comprises a database server for user records and a training log server that receives activity data. A processor tracks usage (e.g., cumulative distance) for specific equipment, compares it to a user-entered warning value, and issues warnings and alerts as the equipment approaches and reaches its maximum usage limit (’234 Patent, col. 8:40-col. 9:14, Fig. 11). The system is designed to work with a wearable GPS-enabled mobile device that communicates training data "live" to the server to enable automatic updates (’234 Patent, Claim 1).
- Technical Importance: The invention provides a specific technical solution for preventing equipment failure by automating a previously manual tracking process. During prosecution, the PTAB found that configuring the mobile device to communicate data live to the server was an improvement to the device itself, as it reduced on-board memory requirements (Compl. ¶30).
Key Claims at a Glance
- The complaint asserts claims 1, 4, 5, 6, 7, 8, 9, 12, 13, 14, 15, 16, and 17, with independent claim 1 being central (’234 Patent, Claim 1; Compl. ¶52).
- Independent Claim 1 requires:
- A database server with a user database.
- A training log server that receives and stores data for registered users, including activity category, distance, and time.
- A processor that calculates a time-based total distance and generates a graphical representation.
- The processor is configured to determine if a user is registered, generate a GUI for entering equipment data (including first use date and a warning value), track equipment usage, issue a warning when the warning value is reached, and issue an alert when maximum usage is reached.
- A wearable, internet-ready, GPS-enabled mobile device configured to communicate training data live to the training log server for automatic updates.
U.S. Patent No. 9,345,948 - “System for Providing a Coach with Live Training Data of an Athlete as the Athlete is Training”
Issued May 24, 2016
Technology Synopsis
This patent, the parent of the ’340 patent, claims a system for remote athletic coaching. It addresses the problem of maintaining coach-athlete relationships over distances by providing a permissions-based coaching dashboard. The system allows an authorized coach to access an athlete's training record, which is updated with live data from a device worn by the athlete during a workout (Compl. ¶¶ 23, 25).
Asserted Claims
Claims 1, 9, 10, 17, 18, and 19 are asserted, with Claim 1 being the sole independent claim (Compl. ¶51, 55).
Accused Features
The Garmin Coach feature is accused of infringing this patent (Compl. ¶51).
III. The Accused Instrumentality
Product Identification
The Garmin Coach and Garmin Gear Tracking features, which are part of the Garmin Connect website and mobile application ecosystem (Compl. ¶¶ 36, 38).
Functionality and Market Context
- The accused features are services provided to users of Garmin's GPS and wearable fitness devices (Compl. ¶¶ 35-37).
- Garmin Coach: This feature provides users with "adaptive training plans" from a selection of coaches for specific running goals (e.g., a 5K race) (Compl. ¶¶ 39-40, p.17). The plan syncs to a user's compatible Garmin watch and adjusts based on the user's performance. The system allows a selected coach to access a "ton" of data about a user's run, including mileage, pace, and rate of exertion (Compl. ¶43, p.18). A screenshot of the Garmin Coach mobile application dashboard shows the user's progress, scheduled workouts, and confidence level (Compl. p.19).
- Garmin Gear Tracking: This feature allows a user to create a profile for an item of gear, such as running shoes, and set a maximum usage distance (Compl. ¶47). The system then uses activity data from the user's wearable device to track the cumulative distance on that gear. It provides a visual warning (an orange-colored bar) when the gear is approaching its maximum distance and an alert (a red-colored bar) when it meets or exceeds the value (Compl. ¶48). A screenshot from the accused product displays a graphical representation of equipment usage as a circular progress bar indicating 34% of the maximum distance has been used (Compl. p.24).
IV. Analysis of Infringement Allegations
U.S. Patent No. 9,889,340 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A method for providing a coach with live training data...the method comprising: creating an athlete profile on a training log server of a computer web-based platform... | Users of the Garmin Coach feature create a profile by inputting goals, fitness level, and selecting a coach. This profile is associated with a user's Garmin Connect account, which is accessible online and allegedly stored on a server (Compl. p.18). | ¶51, p.17-18 | ’948 Patent, col. 4:42-53 |
| the athlete profile including a training record having a plurality of predefined fields, at least one...corresponding to a distance aspect...at least another...to a time aspect... | Each athlete profile includes a training record with data fields for mileage (distance) and time, among others like pace and calories (Compl. p.19). | ¶51, p.19-20 | ’948 Patent, Fig. 4 |
| receiving from the athlete a selection of a coach who is to be granted access to the athlete's profile; | The Garmin Coach feature provides users with a selection of three coaches (e.g., Jeff Galloway, Greg McMillan) to guide their training (Compl. p.20). | ¶51, p.20 | ’948 Patent, col. 11:9-14 |
| updating, at the platform, a training record...with workout data from a mobile tracking device carried with the athlete as the athlete is performing the workout... | Workout data is uploaded from a user's Garmin wearable device (e.g., a Fenix device) through the Garmin Connect application. The uploaded data includes distance and time aspects (Compl. p.21). | ¶51, p.21 | ’948 Patent, col. 8:25-33 |
| permitting the selected coach to log onto the platform and view the training record of the athlete as the athlete is performing the training workout. | The complaint alleges that workout information is provided to the Garmin Connect system as the athlete performs, citing the Garmin LiveTrack feature which allows real-time tracking. It alleges this data is entered into the training record and may be viewed by the coach (Compl. p.22). | ¶51, p.22-23 | ’948 Patent, col. 2:14-20 |
Identified Points of Contention
- Scope Questions: Does the term "coach" in the patent, which the specification describes in the context of a personal human relationship, read on the accused Garmin Coach feature, which appears to be a pre-packaged, algorithm-driven training plan associated with a named running personality? The complaint alleges users select from "real-life coaches," but the level of direct, real-time interaction is a question for the court (Compl. p.18).
- Technical Questions: A central question is whether the accused system provides data to the coach "as the athlete is performing the workout," as required by the claim. The complaint alleges this functionality by pointing to a separate "LiveTrack" feature (Compl. p.22), but it is an open question whether the "Garmin Coach" feature itself operates in this live manner or merely adapts plans based on data synced after a workout is completed.
U.S. Patent No. 10,124,234 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a database server including a user database for maintaining records of users...; a training log server configured to: receive and store data from each registered user regarding a category of athletic activity...distance...and time... | Garmin Connect is alleged to be a server-based system that stores registered user accounts. It receives and stores information about activities like running and biking, including the distance and time for each workout (Compl. pp.24-27). | ¶52, p.24-27 | col. 4:50-56; col. 5:1-8 |
| calculate a time-based total distance...and generate a graphical representation... | The Gear Tracking feature tracks the total distance accumulated on a piece of gear and generates a graphical progress bar to represent the usage relative to a maximum (Compl. pp.27-28). | ¶52, p.27-28 | col. 8:65-9:2 |
| a processor configured to determine whether the user is a registered user...generate a graphical user interface having...fields for entering data regarding the...athletic equipment...at least one...pertaining to...a warning value... | The processor allegedly confirms a user's login credentials before granting access. The Gear Tracking feature presents a GUI for entering equipment details, including a "maximum distance," which the complaint alleges is equivalent to the claimed "warning value" (Compl. p.29-30). | ¶52, p.29-30 | col. 4:15-24; col. 8:43-45 |
| said processor being configured to: track usage...issue a warning...once the usage reaches the warning value...and issue an alert...after determining that the maximum usage has been reached; | The complaint alleges the feature tracks mileage and issues a warning (orange bar) as the equipment approaches maximum usage and an alert (red bar) when it is reached. It argues that entering a maximum distance is equivalent to entering a warning value under the doctrine of equivalents (Compl. p.31). | ¶52, p.30-31 | col. 9:3-14 |
| a wearable GPS-enabled mobile device...configured to communicate training data live to said training log server as the user is training to automatically update said training log server. | Usage data is recorded by a GPS-enabled Garmin wearable (e.g., Forerunner 245). The complaint alleges this data is uploaded as the athlete is training, citing the LiveTrack feature, to automatically update the server (Compl. p.32). | ¶52, p.32 | col. 14:1-10 |
Identified Points of Contention
- Scope Questions: The complaint explicitly raises a doctrine of equivalents argument for the limitation "a warning value enterable by the registered user" (Compl. p.31). The court will have to determine whether the accused feature, which allows a user to enter a maximum distance from which the system calculates a warning, is legally equivalent to a feature where the user directly enters the warning value itself.
- Technical Questions: As with the '340 patent, a key factual question is whether the Gear Tracking system operates "live...as the user is training." The complaint relies on the existence of the "LiveTrack" feature to support this allegation, but discovery will be needed to determine if gear usage data is streamed to the server in real time or synced only after the workout concludes.
V. Key Claim Terms for Construction
Term: "coach" (from ’340 Patent, Claim 1)
- Context and Importance: The definition of "coach" is critical to infringement of the coaching patents. The dispute may center on whether an automated, algorithm-based training plan (the "Garmin Coach") satisfies the claim language requiring a "coach" who is "granted access" to "view the training record."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims do not explicitly define "coach" as a human being, focusing instead on the role of providing a training plan and viewing data within a specific permissions-based system architecture (’340 Patent, Claim 1).
- Evidence for a Narrower Interpretation: The patent specification's background discusses the invention in the context of a personal "relationship with a preferred coach" and the problem of physical separation, which suggests a human actor ('948 Patent, col. 1:24-34). Figure 9 depicts the "coach" at a distinct workstation (138), separate from the athlete and platform, further implying a distinct human or entity.
Term: "a warning value enterable by the registered user" (from ’234 Patent, Claim 1)
- Context and Importance: This term is central to the literal infringement analysis for the '234 patent. Practitioners may focus on this term because the complaint preemptively argues for infringement under the doctrine of equivalents, signaling a potential mismatch with the claim's literal language (Compl. p.31).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation (supporting equivalence): The specification describes a method where "a warning distance and a maximum distance are recorded for the selected equipment," suggesting the two values are functionally linked to achieve the goal of notifying the user (’234 Patent, col. 8:43-45). The overall purpose is to provide a warning, which the accused system does.
- Evidence for a Narrower Interpretation (against equivalence): The plain language of the claim requires a "warning value" that is "enterable by the registered user." The patent's Figure 7 depicts a specific GUI field labeled "Warning Distance," distinct from any maximum value (’234 Patent, Fig. 7). This could support an argument that the claim requires the user to input the specific threshold for the warning, not just the ultimate limit from which a warning is derived.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement. Inducement is predicated on Garmin allegedly advising, advertising, and distributing instructions (e.g., user manuals) that guide customers to use the Garmin Coach and Gear Tracking features in an infringing manner (Compl. ¶63). Contributory infringement is alleged on the basis that the accused features are specially designed for infringement and have no substantial non-infringing uses (Compl. ¶64).
- Willful Infringement: The willfulness claim is based on alleged knowledge of the asserted patents as of at least April 17, 2020, when counsel for the parties discussed the matter prior to the complaint's filing. The complaint alleges that Garmin's continued infringement after this date has been willful and intentional (Compl. ¶¶ 57, 59).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "coach," which is described in the patents' background in the context of a personal human relationship, be construed to cover the algorithm-driven, adaptive training plans offered in the accused "Garmin Coach" system?
- A second central issue will be one of legal equivalency: does Garmin's "Gear Tracking" feature, which allows a user to set a maximum usage distance, infringe claims of the '234 patent that explicitly require a user-enterable warning value, a question the plaintiff has already framed under the doctrine of equivalents?
- A key evidentiary question for all asserted patents will be one of functional operation: does the accused Garmin Connect system transfer workout data "live...as the athlete is performing," as required by the claims, or is data primarily synced post-activity? The answer will determine if there is a fundamental mismatch in the technical operation between the patented inventions and the accused features.