DCT
3:22-cv-00606
Johnson Health Tech Co Ltd v. Peloton Interactive Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Johnson Health Tech Co., Ltd. (Taiwan) and Johnson Health Tech North America, Inc. (Wisconsin)
- Defendant: Peloton Interactive, Inc. (Delaware)
- Plaintiff’s Counsel: Michael Best & Friedrich LLP
- Case Identification: 3:22-cv-00606, W.D. Wis., 03/14/2023
- Venue Allegations: Venue is alleged to be proper based on Defendant's regular and established place of business in the district, including a showroom in Madison, Wisconsin where it offers for sale and sells the accused products.
- Core Dispute: Plaintiff alleges that Defendant’s Peloton Tread and Tread+ treadmills infringe patents related to systems for verifying a user's physical presence on motor-driven exercise equipment to ensure the integrity of exercise data before it is transmitted to third parties.
- Technical Context: The technology addresses the risk of falsifying exercise data on motorized equipment, which is commercially valuable for applications like insurance premium discounts and competitive social fitness platforms.
- Key Procedural History: The filing is a First Amended Complaint. No other significant procedural history, such as prior litigation between the parties or administrative challenges to the patents, is mentioned in the complaint.
Case Timeline
| Date | Event |
|---|---|
| 2014-12-30 | Earliest Priority Date for '227, '375, and '340 Patents |
| 2018-07-24 | U.S. Patent No. 10,032,227 Issues |
| 2020-10-06 | U.S. Patent No. 10,796,375 Issues |
| 2020-10-08 | Peloton allegedly aware of '227 and '375 Patents |
| 2022-01-18 | U.S. Patent No. 11,227,340 Issues |
| 2022-04-11 | Peloton allegedly aware of '340 Patent |
| 2023-03-14 | First Amended Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,032,227 - "Exercise Apparatus with Exercise Use Verification Function and Verifying Method," Issued July 24, 2018
The Invention Explained
- Problem Addressed: The patent's background section describes the problem of data unreliability from motor-driven exercise equipment, such as treadmills. Unlike user-driven equipment (e.g., a stationary bike), a motorized treadmill can be left running without a user present, making it easy to generate "faked" exercise data and undermining its value for third parties like insurance companies (U.S. Patent No. 10,032,227, col. 2:1-17).
- The Patented Solution: The invention is an exercise apparatus that uses a sensor to detect the physical "engagement" of a user. A controller then generates "validated exercise use data" when the user is detected as being on the machine and "non-validated exercise use data" when the user is not detected. The controller then transmits the "validated" data to a communication interface for use by third parties (U.S. Patent No. 10,032,227, Abstract; col. 4:51-65). This process is illustrated in a flowchart where the system checks for user engagement and branches to either generate validated or non-validated data ('227 Patent, Fig. 6).
- Technical Importance: The technology aimed to make exercise data from motor-driven equipment trustworthy, enabling it to be used as reliable proof of exercise for external programs (Compl. ¶¶ 25-26).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶44).
- Claim 1 requires:
- An exercise apparatus with a base, a movable operating unit, and a motor.
- A "sensor operable to detect engagement of a user with the operating unit."
- A controller and a communication interface.
- The controller is configured to generate "non-validated exercise use data" when the sensor does not detect user engagement.
- The controller is further configured to generate "validated exercise use data" when the sensor does detect user engagement.
- The controller transmits the "validated exercise use data" to the communication interface.
- The complaint reserves the right to assert claims 2-4, 6, 10, 11, 14-17, 19, and 20 (Compl. ¶45).
U.S. Patent No. 10,796,375 - "Exercise Apparatus with Exercise Use Verification Function and Verifying Method," Issued October 6, 2020
The Invention Explained
- Problem Addressed: As a continuation of the application leading to the '227 Patent, this patent addresses the same problem of preventing the falsification of exercise data on motor-driven equipment ('375 Patent, col. 2:7-24).
- The Patented Solution: The solution is an exercise apparatus where a controller, in response to sensor data indicating user engagement, is configured to "report the exercise use data to the communication interface." Conversely, if the controller determines the user is not engaged, it is configured to "stop reporting the exercise use data." The communication interface is configured to communicate this reported data to a third party ('375 Patent, Abstract; col. 8:14-23).
- Technical Importance: This approach provides an active gating mechanism to control the flow of exercise information to outside parties based on a real-time assessment of user presence (Compl. ¶¶ 30, 32).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶46).
- Claim 1 requires:
- An exercise apparatus with a motor and a motor-driven operating member.
- A "sensor operable to detect engagement of a user with the operating member."
- A controller and a communication interface.
- The controller is configured to "determine whether the user is engaged."
- If the user is engaged, the controller is configured to "report the exercise use data."
- If the user is not engaged, the controller is configured to "stop reporting the exercise use data."
- The communication interface is configured to "communicate the reported exercise use data to a third party."
- The complaint reserves the right to assert claims 2, 3, 6-20 (Compl. ¶47).
U.S. Patent No. 11,227,340 - "Exercise Apparatus with Exercise Use Verification Function and Verifying Method," Issued January 18, 2022 (Multi-Patent Capsule)
- Technology Synopsis: This patent is in the same family and is directed to an exercise apparatus with a sensor and controller. The system solves the data-falsification problem by configuring the controller to generate "validated exercise use data" only in response to the sensor detecting both user engagement and movement of the operating unit (U.S. Patent No. 11,227,340, Abstract; Compl. ¶31).
- Asserted Claims: The complaint asserts independent claim 1 (Compl. ¶48).
- Accused Features: The Peloton Tread and Tread+ products are alleged to infringe by incorporating a system that generates validated exercise data based on user engagement, which is then used for features such as the Peloton Leaderboard (Compl. ¶¶ 21, 32, 48).
III. The Accused Instrumentality
Product Identification
- The Peloton Tread and Tread+ treadmills (Compl. ¶1).
Functionality and Market Context
- The complaint identifies the accused products as exercise treadmills that compete with Plaintiff's products (Compl. ¶43). A key accused feature is the "Leaderboard," which collects, transmits, and displays exercise data to rank users in a competitive environment (Compl. ¶21). The complaint alleges that for this feature to have integrity, the underlying exercise data must be valid, which suggests the need for a verification system (Compl. ¶22). The complaint provides a photograph of the Peloton Tread taken from the company's website (Compl. ¶41).
IV. Analysis of Infringement Allegations
The complaint does not provide claim charts or detailed factual support for its infringement allegations, instead reciting the claim elements and alleging on "information and belief" that the accused products meet each one.
'227 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| An exercise apparatus comprising: a base; an operating unit movable relative to the base; a motor coupled to the operating unit; | The Peloton Tread and Tread+ are alleged to be exercise apparatuses with a base, a motorized, movable belt (operating unit), and a motor (Compl. ¶41). | ¶44 | col. 4:46-50 |
| a sensor operable to detect engagement of a user with the operating unit; | The complaint alleges the Accused Products contain a sensor to detect user engagement but provides no specific details on the sensor's identity or mechanism of action (Compl. ¶32). | ¶44 | col. 5:36-45 |
| a controller in communication with the operating unit and the sensor; and a communication interface in communication with the controller, | The complaint alleges the Accused Products contain a controller and a communication interface that manage and transmit exercise data for features like the Leaderboard (Compl. ¶¶ 21, 32). | ¶44 | col. 4:15-19 |
| wherein the controller is configured to generate a non-validated exercise use data in response to movement of the operating unit relative to the base and the sensor does not detect engagement of the user with the operating unit, | The complaint alleges the Accused Products' controller performs this function, preventing falsified data from being credited (Compl. ¶38). | ¶44 | col. 7:29-33 |
| wherein the controller is further configured to generate a validated exercise use data in response to movement of the operating unit relative to the base and the sensor does detect engagement of the user with the operating unit, and wherein the controller transmits the validated exercise use data to the communication interface. | The complaint alleges the Accused Products' controller generates validated data upon detecting a user and transmits it, for example, to the Peloton Leaderboard system (Compl. ¶¶ 21, 26, 38). | ¶44 | col. 7:41-47 |
'375 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| An exercise apparatus comprising: a motor; an operating member driven by the motor; a sensor operable to detect engagement of a user with the operating member; | The complaint alleges the Peloton Tread and Tread+ are an apparatus with a motor, a motor-driven belt, and a sensor for detecting user engagement (Compl. ¶¶ 32, 41). | ¶46 | col. 8:1-4 |
| a controller...and a communication interface... | The Accused Products are alleged to contain a controller and communication interface for generating and reporting exercise data to third parties like the Leaderboard system (Compl. ¶¶ 21, 30). | ¶46 | col. 8:5-7 |
| wherein the controller is configured determine whether the user is engaged...in response to...the sensor detecting engagement of the user... | The Accused Products' controller is alleged to determine user engagement based on sensor input to validate exercise data (Compl. ¶¶ 32, 38). | ¶46 | col. 8:8-13 |
| wherein in response to the controller determining that the user is engaged...the controller is configured to report the exercise use data to the communication interface, | Upon determining user engagement, the Accused Products' controller is alleged to report exercise data to the communication interface for transmission to the Leaderboard (Compl. ¶30). | ¶46 | col. 8:14-17 |
| wherein in response to the controller determining that the user is not engaged...the controller is configured to stop reporting the exercise use data...and wherein the communication interface is configured to communicate the reported exercise use data to a third party. | When a user is not detected, the controller is alleged to stop reporting data, thereby preventing falsification. The interface is alleged to communicate reported data to Peloton (Compl. ¶30). | ¶46 | col. 8:17-23 |
Identified Points of Contention
- Technical Questions: A primary evidentiary question for all asserted patents will be whether the Accused Products actually contain a "sensor" that "detects engagement" as claimed. The complaint offers no facts on what component performs this function or how it operates (e.g., via motor current analysis, pressure sensing, or optical detection). The case may depend on whether discovery uncovers a specific, corresponding technical mechanism in the accused treadmills.
- Scope Questions: The infringement analysis may raise questions about the precise functional meaning of claim terms. For the '227 Patent, does the accused system "generate a non-validated exercise use data," or does it simply not generate any data at all until a user is present? For the '375 Patent, does the system "stop reporting" data, or does it merely fail to initiate a reporting session? The distinction between an affirmative software action (generate, stop) versus inaction could become a central point of dispute.
V. Key Claim Terms for Construction
The Term: "sensor operable to detect engagement of a user" (asserted in claims of all three patents)
- Context and Importance: This term is the technological core of the patents-in-suit. Infringement hinges on whether the Accused Products possess a component that meets this definition. Practitioners may focus on this term because the complaint provides no factual detail about what component in the Peloton products allegedly performs this function, making its scope critical.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specifications disclose that the "sensor" can take many forms, including "a current sensor, an optical sensor, a pressure sensor, and a thermal sensor" ('227 Patent, col. 10:4-6). This list may support a construction that is not limited to a single embodiment and covers any technical means of detecting user presence.
- Evidence for a Narrower Interpretation: A defendant could argue that "engagement" requires more than a user simply being logged in, but rather the detection of physical interaction that affects the machine's operation, such as "user footfall" causing fluctuations in motor current ('227 Patent, col. 4:56-63). The term might be construed to require a sensor that detects such physical interaction, rather than one that detects user identity through software.
The Term: "generate a non-validated exercise use data" ('227 Patent, Cl. 1)
- Context and Importance: This limitation requires an affirmative step of creating data that is specifically categorized as "non-validated." The infringement analysis for the '227 patent will turn on whether the Peloton system performs this specific function.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A plaintiff might argue that any period where the treadmill motor is running but the resulting distance is not being credited to a user's official record (e.g., for the Leaderboard) constitutes the generation of "non-validated" data, even if it is immediately discarded.
- Evidence for a Narrower Interpretation: The patent's flowchart explicitly depicts a distinct process step labeled "generates non-validated exercise use data" ('227 Patent, Fig. 6, step 116). A defendant may argue this requires the system to actively create and potentially store a data record that is flagged or otherwise identified as non-validated, as opposed to simply not recording data at all.
VI. Other Allegations
Indirect Infringement
- The complaint alleges inducement by asserting that Peloton had pre-suit knowledge of the patents and "actively encouraged distributors, customers and/or others" to use the Accused Products in an infringing manner (Compl. ¶50). It also pleads contributory infringement, alleging the products are a material part of the invention and not a staple article of commerce suitable for substantial noninfringing use (Compl. ¶51).
Willful Infringement
- Willfulness is alleged based on Peloton’s alleged pre-suit knowledge of all three patents-in-suit. The complaint provides specific "no later than" dates for when Peloton was allegedly aware of each patent (Compl. ¶¶ 53-55, 62).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of evidentiary proof: Can the Plaintiff demonstrate through discovery that the Peloton treadmills contain a specific technical component that functions as a "sensor" to "detect engagement" in the manner required by the claims? The complaint's lack of factual specificity places the burden of uncovering this evidence entirely on post-filing discovery.
- The case will likely involve a key question of functional equivalence: Do the accused systems perform the precise logical steps recited in the claims—such as affirmatively "generating non-validated data" ('227 patent) or actively "stopping the reporting" of data ('375 patent)—or do they achieve a similar outcome through a different, non-infringing technical method, such as not initiating data collection until user presence is confirmed?