Peloton Interactive Inc v. ICON Health & Fitness Inc

1. Case Identification

• Case #: IPR2022-00030
• Patent #: 7,166,062
• Filed: October 13, 2021
• Petitioner(s): Peloton Interactive, Inc.
• Patent Owner(s): iFIT Inc. (f/k/a ICON Health & Fitness, Inc.)
• Challenged Claims: 49-50, 52, 54, 56-57, 59, 61, 78-85, 87, 89-90, 92-95

2. Patent Overview

• Title: System For Interaction With Exercise Device
• Brief Description: The ’062 patent relates to network-connected exercise devices that simulate a group workout environment by synchronizing the device's operation with remote exercise programming received over a communications network.

3. Grounds for Unpatentability

Ground 1: Obviousness over Studor - Claims 49-50, 52, 54, 56-57, 59, 61, 78-85, 87, 89-90, and 92-95 are obvious over Studor.

• Prior Art Relied Upon: Studor (Patent 6,152,856).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Studor discloses all elements of the challenged claims. Studor teaches an interactive exercise system, including equipment like a bicycle, connected to a computer system that can receive media from a remote server over the Internet. This media includes terrain data used as "control data" to dynamically adjust the equipment's resistance, thereby synchronizing the user's physical effort with a video display of a real-world course. Petitioner contended that Studor’s bicycle is the claimed "exercise mechanism," its computer system is the "user interface," and the necessary network connection is the "communicating mechanism." The terrain data received from the remote server constitutes the "packetized second signal including synchronized control signals," and Studor's microcontroller that adjusts resistance based on this data is the "means for controlling."
  • Motivation to Combine: This ground asserts that Studor alone, or in view of the general knowledge of a person of ordinary skill in the art (POSITA), renders the claims obvious. For claimed features not explicitly detailed in Studor, such as a safety mechanism that manipulates the device upon signal interruption (claim 95), Petitioner argued a POSITA would have been motivated to incorporate such a well-known feature to ensure user safety during network dropouts, which was a predictable and necessary design choice for any network-connected exercise equipment.
  • Expectation of Success: A POSITA would have a high expectation of success in implementing Studor’s system as claimed, as Studor itself describes the core components operating in concert. Integrating common features like safety interlocks would involve applying known principles for their intended purpose.

Ground 2: Obviousness over Clem and Hickman - Claims 49-50, 52, 54, 56-57, 59, 61, 78-85, 87, 89-90, and 92-95 are obvious over Clem in view of Hickman.

• Prior Art Relied Upon: Clem (Patent 6,053,844) and Hickman (Patent 6,059,692).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Clem discloses the core system of a network-connected treadmill that allows a user to engage in real-time, two-way audio and video communication with a live fitness expert at a remote website. The expert can transmit control signals over the internet to adjust the treadmill's operating parameters, such as speed and incline. This system provides the claimed "exercise mechanism," "user interface," and "communicating mechanism" for receiving packetized control signals from a remote source. Hickman is cited for its disclosure of a system where new exercise scripts can be downloaded from a remote computer to a local computer that controls an exercise apparatus, including synchronized audio/visual cues with control signals (e.g., an audio cue for an upcoming hill accompanied by increased resistance).
  • Motivation to Combine: A POSITA would combine Clem and Hickman because they exist in the same technical field and address the common problem of providing effective, convenient, and affordable remote personal training. Petitioner asserted that a POSITA would be motivated to integrate Hickman’s functionality for downloading and executing pre-defined exercise scripts into Clem’s real-time, expert-led communication platform. This combination would create a more versatile system that supports both live interactive sessions and structured, pre-programmed workouts, representing a predictable fusion of known features to improve the user experience.
  • Expectation of Success: A POSITA would have a reasonable expectation of success because combining the references involves the straightforward integration of known software concepts (script downloading from Hickman) with a known hardware and networking platform for remote exercise control (from Clem).

4. Key Claim Construction Positions

• The petition proposed constructions for several means-plus-function terms that were central to its invalidity arguments:
  • "communicating mechanism" (claim 49): The function was identified as communicating with the user interface and receiving a packetized signal from a remote source. The corresponding structure was argued to be a network interface or a modem.
  • "means ... for controlling" (claim 49) / "control means" (claim 78): The function was identified as controlling the exercise mechanism's operating parameters in response to received synchronized control signals. The corresponding structure was argued to be a controller.
  • "means for reproducing the second signal" (claims 49, 59): The function was identified as reproducing the signal received from the remote source. The corresponding structures were argued to be output devices, such as audio speakers and video displays.

5. Arguments Regarding Discretionary Denial

• §325(d) (Advanced Bionics/General Plastic): Petitioner argued against denial, asserting the patent examiner did not substantively review the Studor or Clem references during prosecution. It was contended that the references were "buried" within a large Information Disclosure Statement (IDS) filed after a notice of allowance, causing the examiner to materially overlook their key teachings on receiving remote, packetized control signals—the very feature the patent owner had added to the claims to overcome a prior rejection.
• Fintiv: Petitioner argued that discretionary denial under Fintiv was unwarranted because the petition was filed promptly after the patent owner asserted these specific claims in parallel district court litigation. Furthermore, the district court trial was scheduled for June 2023, well after the statutory deadline for a Final Written Decision (FWD) in the IPR, minimizing concerns of duplicative efforts and inconsistent results.

6. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 49-50, 52, 54, 56-57, 59, 61, 78-85, 87, 89-90, and 92-95 as unpatentable under 35 U.S.C. §103.