Peloton Interactive Inc v. iFIT Inc

1. Case Identification

• Case #: IPR2022-00788
• Patent #: 10,864,407
• Filed: March 31, 2022
• Petitioner(s): Peloton Interactive, Inc.
• Patent Owner(s): ICON Health & Fitness, Inc. (d/b/a iFIT Inc.)
• Challenged Claims: 1-16 and 18-20

2. Patent Overview

• Title: Coordinated Weight Selection
• Brief Description: The ’407 patent is directed to an exercise machine that integrates a free weight cradle with a traditional aerobic machine (e.g., stationary bike, treadmill). The system features a console that presents a programmed workout with instructions for both the aerobic exercise element and the free weights, and automatically controls an operating parameter (e.g., resistance, speed) of the machine.

3. Grounds for Unpatentability

Ground 1: Obviousness over Shea and Rocker - Claims 1-16 and 18-20 are obvious over Shea in view of Rocker.

• Prior Art Relied Upon: Shea (Patent 7,056,265) and Rocker (Application # 2006/0135322).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Shea disclosed an exercise system with nearly all limitations of independent claim 1. Shea taught a stationary bike with a console, processor, and memory for executing programmed workouts that automatically controlled pedal resistance. Shea’s workouts included instructions for both aerobic and free weight exercises, presenting them on a display with audio. However, Shea’s system contemplated free weight exercises being performed at a separate station. Petitioner asserted that Rocker supplied the missing limitation: an integrated free weight cradle on an aerobic exercise machine (a treadmill) to provide a “total workout.” Rocker’s console also presented programmed workouts with instructions for alternating between aerobic and free weight exercises. The combination of Shea’s advanced, automatically controlled exercise programming with Rocker’s integrated hardware design renders the claims obvious.
  • Motivation to Combine: A POSITA would combine Rocker's integrated free weight cradle with Shea's stationary bike to achieve the well-known benefits of a more efficient, full-body workout. This combination would allow for seamless transitions between exercise types, or simultaneous performance, and save valuable space in a home environment, a key market for such devices. Both references are directed to computer-based exercise systems, making the integration of features logical and predictable to meet market demand for combined cardio and strength training equipment.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success because Shea’s bike already possessed the necessary control hardware (processor, memory, display) and its software already included instructions for free weight exercises. Adding Rocker’s physical cradle and updating the existing software to guide exercises on the same machine, rather than a separate station, would have been a routine modification within the skill of a POSITA.

Ground 2: Obviousness over ProForm and Shea - Claims 1-16 and 18-20 are obvious over ProForm in view of Shea.

• Prior Art Relied Upon: ProForm (PRO•FORM CT 1160 User's Manual) and Shea (Patent 7,056,265).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner contended that ProForm, a user manual for a treadmill sold by the Patent Owner, disclosed a treadmill with an integrated free weight cradle (“hand weight holder”), a console, and programmed workouts that automatically controlled speed and incline. ProForm’s console provided instructions for alternating between treadmill use and free weight exercises. However, ProForm’s more advanced features, such as video workouts with a personal trainer, required connecting the treadmill to a separate external computer. Petitioner used Shea to teach the integration of this computer functionality directly into the exercise machine’s console. Shea disclosed a self-contained console with a processor, display, and speakers capable of presenting detailed audiovisual workout instructions (including for free weights), calculating workouts based on user goals, and downloading new programs from a remote server.
  • Motivation to Combine: A POSITA would have been motivated to modify ProForm’s system by incorporating the integrated console technology taught by Shea. This would eliminate the inconvenience of connecting to a separate computer, making the machine more commercially viable and aligning with the industry trend toward integrated, internet-connected consoles. A POSITA would also turn to Shea for more detailed implementation of programmed instructions for a variety of exercises, as Shea provides more technical detail than the ProForm user manual. The combination would create a more seamless and user-friendly product.
  • Expectation of Success: A POSITA would have expected to succeed because, by the patent's 2016 timeframe, the reduction in size and cost of computer hardware had made integrated multimedia consoles commonplace. Shea provided a detailed blueprint for the necessary hardware and software logic, making the integration into ProForm’s existing treadmill framework a predictable and straightforward task.

4. Arguments Regarding Discretionary Denial

• Petitioner argued against discretionary denial under 35 U.S.C. §325(d) because the primary prior art references, Shea and ProForm, were not disclosed or considered during the patent’s original prosecution.
• Petitioner further asserted that denial under the Fintiv factors was unwarranted because the parallel district court litigation involving the ’407 patent was stayed at a very early stage. No trial date had been set, and the Patent Owner had not yet served infringement contentions, indicating that institution would be more efficient than allowing the district court case to proceed.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-16 and 18-20 of the ’407 patent as unpatentable.