DCT

1:25-cv-07699

Balanced Body Inc v. Pilates Club Middletown

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-07699, S.D.N.Y., 09/16/2025
  • Venue Allegations: Venue is based on Defendants residing in the district and allegedly committing acts of infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendants’ use of "knockoff" Pilates reformer machines in their fitness studio directly and indirectly infringes seven of its patents covering both ornamental designs and functional improvements for such equipment.
  • Technical Context: The technology concerns Pilates reformer exercise equipment, a market where aesthetic design and specific mechanical functionalities are key competitive differentiators.
  • Key Procedural History: The complaint notes that in August 2025, the International Trade Commission issued a general exclusion order related to the ’511 and D’208 Patents and a limited exclusion order related to the D’205 Patent, suggesting prior successful enforcement actions against imported products.

Case Timeline

Date Event
2011-07-13 Priority Date for all Asserted Patents
2012-05-08 U.S. Patent Nos. D659,205, D659,206, and D659,208 Issue
2014-05-13 U.S. Patent No. 8,721,511 Issues
2014-12-23 U.S. Patent No. 8,915,829 Issues
2015-09-15 U.S. Patent No. 9,132,311 Issues
2016-03-22 U.S. Patent No. 9,289,645 Issues
2023-08-08 Alleged first use of infringing products by Defendants
2025-08-11 International Trade Commission issues exclusion orders
2025-08-06 Plaintiff sends first cease and desist letter to Defendants
2025-08-22 Plaintiff’s counsel calls Defendants regarding infringement
2025-08-26 Plaintiff sends second cease and desist letter to Defendants
2025-09-16 Complaint Filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. D659,205 - Reformer Exercise Apparatus

  • Issued: May 8, 2012 (Compl. ¶21)

The Invention Explained

The D’205 Patent claims the ornamental design for a complete reformer exercise apparatus (Compl. ¶22). The design is defined by the overall visual impression created by the apparatus as depicted in the patent's figures, which show a frame with curved corners and integrated legs, a sliding carriage, shoulder stops, and a footbar assembly (D’205 Patent, Figs. 1-7).

Key Claims at a Glance

The patent contains a single claim: "The ornamental design for a reformer exercise apparatus, as shown and described" (D’205 Patent, Claim). Infringement analysis for design patents is based on the "ordinary observer" test, which compares the overall visual appearance of the claimed design with the accused product.

U.S. Patent No. D659,206 - Reformer Exercise Apparatus Frame

  • Issued: May 8, 2012 (Compl. ¶29)

The Invention Explained

The D’206 Patent claims the ornamental design for the frame component of a reformer apparatus, separate from other elements like the carriage or footbar (Compl. ¶30). The claimed design is characterized by the specific visual appearance of the frame itself, including its curved corners, parallel side rails, and integrated leg structures (D’206 Patent, Figs. 1-7).

Key Claims at a Glance

The patent contains a single claim: "The ornamental design for a reformer exercise apparatus frame, as shown" (D’206 Patent, Claim). The legal test for infringement focuses on whether an ordinary observer would find the accused product's frame design to be substantially the same as the patented design.

U.S. Patent No. D659,208 - Reformer Exercise Apparatus Footbar

  • Issued: May 8, 2012 (Compl. ¶37)

The Invention Explained

This patent claims the ornamental design for a footbar component of a reformer exercise apparatus (Compl. ¶38). The design encompasses the specific shape and configuration of the footbar as shown in the patent's figures (D’208 Patent, Figs. 1-7).

Key Claims & Allegations

  • Asserted Claims: The single claim for the ornamental design is asserted (Compl. ¶40).
  • Accused Features: The footbar assemblies on the "knockoff Pilates reformers" used by Defendants are accused of infringing this design patent (Compl. ¶40).

U.S. Patent No. 8,721,511 - Reformer Exercise Apparatus

  • Issued: May 13, 2014 (Compl. ¶45)

The Invention Explained

The ’511 Patent addresses the structural design of the side rails of a reformer frame. The invention describes a specific cross-sectional profile for the rails, characterized as an "inverted generally U shape," formed by an upright outer wall, an integral horizontal top wall, and an inwardly and downwardly slanted inner wall ('511 Patent, col. 2:3-6). This claimed structure provides support for both the movable carriage and a foot support member, while concealing certain mechanical components within the rail itself ('511 Patent, col. 1:10-24).

Key Claims & Allegations

  • Asserted Claims: Claim 1 is asserted (Compl. ¶50).
  • Accused Features: The complaint alleges that the side rails of the accused reformers have the same inverted U-shaped cross-section claimed in the patent, including an upright outer wall, horizontal top wall, and slanted inner wall (Compl. ¶51).

U.S. Patent No. 8,915,829 - Reformer Exercise Apparatus

  • Issued: December 23, 2014 (Compl. ¶56)

The Invention Explained

The ’829 Patent, related to the ’511 Patent, also claims a reformer apparatus with side rail portions having an "inverted generally U shape in transverse cross section." This shape is again defined by an upright outer wall, an integral top wall, and a sloping inner wall ('829 Patent, col. 2:12-19). This design is intended to provide a simplified and straightforward apparatus that integrates support for the carriage and foot support member into the rail structure ('829 Patent, col. 1:51-56).

Key Claims & Allegations

  • Asserted Claims: Claim 1 is asserted (Compl. ¶61).
  • Accused Features: The complaint alleges the side rails of the accused reformers embody the claimed inverted U-shaped structure, including the specified upright outer wall, top wall, and sloping inner wall (Compl. ¶62).

U.S. Patent No. 9,132,311 - Reformer Exercise Apparatus Footbar Support Assembly

  • Issued: September 15, 2015 (Compl. ¶67)

The Invention Explained

The ’311 Patent describes a foot bar assembly with a specific mechanism for adjusting its position along the reformer frame. The claimed assembly includes an elongated slide plate that moves within the frame's side rail, a hook plate, a rotatable and slidable support arm for the foot bar, and a "locking member" that permits movement of the slide plate only when the support arm is in a predetermined position ('311 Patent, col. 2:25-50). This allows the foot bar to be securely positioned for exercises but easily moved when adjustment is needed.

Key Claims & Allegations

  • Asserted Claims: Claim 1 is asserted (Compl. ¶72).
  • Accused Features: The complaint alleges the accused reformers have a foot bar assembly with a slide plate, hook plate, support arm, and a locking mechanism that restricts movement except when the support arm is in a specific position, thereby mapping to the claimed elements (Compl. ¶73).

U.S. Patent No. 9,289,645 - Reformer Exercise Apparatus Arm Cord Retraction Assembly

  • Issued: March 22, 2016 (Compl. ¶78)

The Invention Explained

The ’645 Patent discloses an assembly for retracting the arm cords on a reformer, which is mounted to the underside of the carriage. The claimed invention includes a pair of cord retraction devices with spring-biased reels and a pair of latch assemblies. A key inventive concept is that the latch assemblies are "operably connected mechanically together," so that actuating one latch to hold or release its arm cord causes the other latch to perform the same action simultaneously ('645 Patent, col. 3:35-50).

Key Claims & Allegations

  • Asserted Claims: Claim 1 is asserted (Compl. ¶83).
  • Accused Features: The complaint alleges, on information and belief, that the accused reformers include an arm cord retraction assembly with two spring-biased reels and two mechanically linked latch assemblies, such that actuating one operates the other (Compl. ¶84).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are "knockoff Pilates reformer machines" that Defendants use in their Pilates studio business (Compl. ¶¶15, 17).

Functionality and Market Context

The complaint alleges these are exercise apparatuses that embody the patented inventions, including the ornamental designs and functional features of the asserted patents (Compl. ¶¶15, 49). The complaint uses several images from Defendants' Instagram account to depict the accused reformers in use in a studio setting (Compl. ¶¶16, 24). One such image shows multiple reformers arranged in a classroom setting, illustrating their use in Defendants' commercial operations (Compl. p. 8, Figure 4). The complaint frames the accused products as part of a market of "unauthorized products" produced by foreign manufacturers and "sold at a fraction of the cost of genuine goods" (Compl. ¶14).

IV. Analysis of Infringement Allegations

As the lead patents are design patents, a traditional claim chart is not applicable. The complaint's infringement theory is based on a visual comparison between the patented designs and the accused products, asserting that they create the same overall visual impression to an ordinary observer.

D659,205 Infringement Allegations

The complaint presents a side-by-side visual chart comparing figures from the D’205 Patent with photographs of the accused products taken from Defendants' social media (Compl. p. 8). The complaint juxtaposes the patent's perspective, head-end, and top-down views with corresponding photos of the accused reformers, alleging the "similarities are apparent" (Compl. p. 8, ¶24).

D659,206 Infringement Allegations

Similarly, for the D’206 Patent covering the reformer frame, the complaint provides a visual chart comparing the patented frame design with photos of the complete accused reformers (Compl. p. 11). This comparison alleges that the frame component of the accused products is visually indistinguishable from the claimed design (Compl. ¶32).

Identified Points of Contention

  • Scope Questions: A central question for the D'206 Patent will be the proper scope of the visual comparison. Does the presence of non-claimed elements on the accused product (e.g., carriage, footbar) alter the overall visual impression of the frame itself in the eyes of an ordinary observer?
  • Technical Questions: For the design patents, the dispute is not technical but aesthetic. The primary question is whether the alleged visual similarities are substantial enough to meet the legal standard for infringement, which considers the design as a whole and requires more than the presence of isolated similar features.

V. Key Claim Terms for Construction

This section is not applicable to the lead design patents, which do not rely on the construction of specific textual terms.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement for all seven asserted patents. It claims Defendants encourage their customers to directly infringe by advertising Pilates classes using the accused reformers on social media and providing in-class instructions on their use (Compl. ¶¶28, 36, 44, 55, 66, 77, 88).

Willful Infringement

Willfulness is alleged based on actual, post-notice conduct. The complaint states that Plaintiff provided Defendants with explicit notice of the asserted patents and infringement through cease and desist letters dated August 6 and August 26, 2025, as well as a phone call from counsel on August 22, 2025 (Compl. ¶¶17-19). The complaint alleges that Defendants' continued use of the reformers after receiving this notice constitutes willful infringement (Compl. ¶¶26, 34, 42, 53, 64, 75, 86).

VII. Analyst’s Conclusion: Key Questions for the Case

The resolution of this case may turn on three central questions:

  • A core issue for the design patents will be one of visual identity: would an ordinary observer, familiar with prior art Pilates reformers, be deceived into believing the accused reformers are the same as the patented designs? This will require a holistic comparison of the overall visual effect, not merely an enumeration of features.
  • For the utility patents, a key evidentiary question will be one of technical implementation: what evidence will demonstrate that the accused "knockoff" products, obtained from foreign manufacturers, actually contain the specific mechanical structures and functionalities recited in the claims, such as the precise rail cross-section, the footbar locking mechanism, and the linked arm cord retraction system?
  • Given the allegations of explicit pre-suit notice, a central question for damages will be one of objective recklessness: after being notified of the specific patents-in-suit, did Defendants act despite a risk of infringement that was either known or so obvious that it should have been known, thereby justifying enhanced damages for willfulness?