Echelon Fitness Multimedia LLC v. Peloton Interactive Inc

1. Case Identification

• Case #: IPR2020-01187
• Patent #: 10,022,590
• Filed: June 29, 2020
• Petitioner(s): Echelon Fitness Multimedia, LLC
• Patent Owner(s): Peloton Interactive, Inc.
• Challenged Claims: 1-20

2. Patent Overview

• Title: System for Providing Streaming and On-Demand Exercise Classes
• Brief Description: The ’590 patent discloses a networked exercise system for providing users with live and on-demand cycling classes. The system aims to replicate the competitive and motivational features of in-studio classes, such as comparative leaderboards, for in-home use.

3. Grounds for Unpatentability

Ground 1: Obviousness over Watterson and Hurwitz - Claims 1-4, 7-20 are obvious over Watterson in view of Hurwitz.

• Prior Art Relied Upon: Watterson (Patent 7,628,730) and Hurwitz (Patent 7,874,957).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Watterson disclosed the core system of claim 1: a user interface for displaying live and archived exercise classes to remotely located users over a network. While Watterson taught a general networked exercise system, it lacked specific implementation details for cycling. Hurwitz allegedly supplied these missing elements, disclosing exercise cycles with sensors for tracking cycling-specific performance parameters (e.g., power output, cadence) and a leaderboard display for comparing performance between users in real-time.
  • Motivation to Combine: A POSITA would combine Hurwitz's cycling-specific features with Watterson's general system to create a more complete and commercially viable product. Hurwitz’s sensors provided a simple, known way to measure cyclist performance, and its leaderboard display offered a well-understood method to enhance the user's competitive experience, which was a stated goal of Watterson’s system.
  • Expectation of Success: A POSITA would have a high expectation of success because Hurwitz’s sensors were described with communication components designed to interface with processing devices like those in Watterson's system. Integrating these known components to achieve a predictable improvement in functionality was argued to be a straightforward task.

Ground 2: Obviousness over Hurwitz, Garcia, and Martens - Claims 1-4, 7-12, and 14-19 are obvious over Hurwitz in view of Garcia and Martens.

• Prior Art Relied Upon: Hurwitz (Patent 7,874,957), Garcia (Application # 2011/0224999), and Martens (Patent 7,736,272).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground used Hurwitz as the primary reference for a networked competitive cycling system. Petitioner contended that Hurwitz, while teaching live classes, did not explicitly disclose offering archived classes. Garcia was introduced for its teaching of a conventional web interface that provides users access to both live and prerecorded (archived) exercise classes, a common feature in the art. To address competition in an archived class context, Martens was added for disclosing the time-synchronization of a live user’s performance data with the archived performance data of "shadow competitors," allowing for a real-time competitive experience against previously recorded sessions.
  • Motivation to Combine: A POSITA would combine these references to improve Hurwitz's system. Garcia provided a known technique to add archived classes, broadening the system's appeal by allowing users to exercise on-demand. To maintain the competitive aspect that made live classes engaging, a POSITA would be motivated to incorporate Martens's method for synchronizing live and archived data, a predictable solution to a known problem that enhances user motivation.
  • Expectation of Success: The combination involved applying known techniques (offering archived classes and synchronizing performance data) to an existing system (Hurwitz) to achieve the predictable result of a more versatile and engaging exercise platform.

Ground 3: Obviousness over Grounds 1/2 and Loveland - Claims 5-6, 13, and 20 are obvious over the systems of Grounds 1 or 2, further in view of Loveland.

• Prior Art Relied Upon: The combinations of Ground 1 or Ground 2, and Loveland (Application # 2011/0086707).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground argued that the networked exercise systems described in the first two grounds would have been obviously implemented on a conventional mobile device, such as a tablet with a touchscreen. Loveland was cited for its disclosure of using a portable tablet computer (specifically an iPad) as the user interface and computing device for an exercise machine. This combination was argued to render obvious claim 5 (mobile device with touchscreen), claim 6 (casting content to a display, which Loveland's iPad could do via "AirPlay"), and claims 13 and 20 (video chat, which the iPad could do via "FaceTime").
  • Motivation to Combine: A POSITA would be motivated to use a conventional tablet, as taught by Loveland, to implement the exercise system for user convenience, portability, and cost-effectiveness. Using a commercially available device like an iPad would leverage its built-in functionalities (touchscreen, wireless connectivity, mobile applications), benefiting both the system designer and the end-user.
  • Expectation of Success: Implementing a software application on a conventional, commercially available tablet was a routine and predictable design choice for a POSITA at the time.

4. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of the ’590 patent as unpatentable.