PTAB

IPR2020-01541

Echelon Fitness Multimedia LLC v. Peloton Interactive Inc

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System for Providing Streaming and On-Demand Exercise Classes
  • Brief Description: The ’026 patent discloses a networked exercise system that provides users with live and archived fitness classes. The system aims to replicate the competitive and social features of in-studio classes, such as a comparative leaderboard, for an in-home setting.

3. Grounds for Unpatentability

Ground 1: Claims 1-20 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 providing live and archived exercise activities over the internet, including a "Competition Module" for comparing user performance. However, Watterson lacked specific implementation details for cycling. Hurwitz allegedly supplied these missing elements, teaching an internet-connected exercise cycle with specific sensors for measuring cycling parameters like power output and cadence, and a detailed leaderboard display for comparing performance data among users in real-time.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Hurwitz with Watterson to implement Watterson’s general networked exercise system for the specific, popular application of cycling. Hurwitz provided a known, simple way to measure and share cycling-specific performance data. A POSITA would also have been motivated to use Hurwitz's well-defined leaderboard to implement Watterson’s generic "graphical representation" of competition, thereby creating a more motivating and engaging user experience.
    • Expectation of Success: Petitioner asserted a high expectation of success, as the combination merely involved integrating Hurwitz’s known cycling sensors with Watterson's control panel, which was already designed to interface with sensor data, and using Hurwitz's established leaderboard display format.

Ground 2: Claims 1-19 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 base system for competitive, networked cycling. Petitioner asserted that Garcia supplemented Hurwitz by teaching conventional methods for users to access both live and archived classes via a standard web interface, a feature not explicitly detailed in Hurwitz. Martens was introduced to add the concept of competing against "shadow competitors"—the archived and time-synchronized performance data of previous users. This allows a current user to experience a competitive race against past performances as if they were occurring simultaneously.
    • Motivation to Combine: A POSITA would combine Garcia with Hurwitz to add the conventional and predictable feature of offering on-demand archived classes, improving user convenience and flexibility. The combination with Martens was motivated by the desire to extend the competitive features of live classes to the archived classes, allowing users to simulate a live race against prior participants. This would enhance user motivation, a key goal of such systems.
    • Expectation of Success: Success would be expected, as the combination involved applying known techniques—Garcia’s web interface for class selection and Martens’s data synchronization method—to Hurwitz’s existing system to achieve the predictable result of a more feature-rich, competitive on-demand exercise platform.

Ground 3: Claim 20 is obvious over Hurwitz, Garcia, and Martens, further in view of Loveland

  • Prior Art Relied Upon: Hurwitz (Patent 7,874,957), Garcia (Application # 2011/0224999), Martens (Patent 7,736,272), and Loveland (Application # 2011/0086707).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination in Ground 2 to address the limitations of claim 20, which specifically required a "video chat" function. Petitioner argued that the system described in Ground 2 did not specify the computing equipment used. Loveland disclosed using conventional mobile tablets, such as an iPad, as the display and computing device for exercise systems to enhance portability and usability. Petitioner asserted that implementing the Ground 2 system on a tablet like an iPad was an obvious design choice. Since such devices have well-known, built-in video chat capabilities (e.g., FaceTime), the claimed feature was obvious.
    • Motivation to Combine: A POSITA would combine Loveland with the base system from Ground 2 to leverage a conventional, commercially available, and portable device (an iPad) for the user interface. This would benefit both the designer (by using standard hardware) and the end-user (by providing a multi-purpose, mobile device). The motivation to include video chat arose directly from this choice of hardware, as it is an inherent and popular feature of such tablets.
    • Expectation of Success: The expectation of success was high because it involved implementing the software-based exercise system on a standard, commercially available computing device known to be suitable for such applications.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under 35 U.S.C. §325(d) would be inappropriate. Although the core prior art references were listed in an Information Disclosure Statement (IDS) during prosecution, they were never substantively analyzed, discussed, or used in a rejection by the Examiner. Petitioner contended that the arguments and evidence presented in the petition were therefore not considered during prosecution.

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-20 of Patent 10,486,026 as unpatentable.