Case 1:20-cv-00662-UNA Document 1 Filed 05/15/20 Page 1 of 51 PageID #: 1
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`Plaintiff,
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`v.
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`C.A. No. ______________
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`DEMAND FOR JURY TRIAL
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`PELOTON INTERACTIVE, INC.,
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`ICON HEALTH & FITNESS, INC.,
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`COMPLAINT FOR PATENT INFRINGEMENT,
`FALSE ADVERTISING, AND UNFAIR BUSINESS PRACTICES
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`Plaintiff Peloton Interactive, Inc. (“Peloton”) brings this action against ICON Health &
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`Defendant.
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`Fitness, Inc. (“ICON”), and alleges as follows:
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`SUMMARY OF THE ACTION
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`1.
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`Since its inception in 2012, Peloton has changed the fitness industry, becoming
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`the largest interactive fitness platform in the world with a loyal community of over 2.6 million
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`members. In fiscal year 2019 alone, its members completed over 58 million Peloton workouts.
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`Peloton makes fitness entertaining, approachable, effective and convenient while fostering social
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`connections that encourage its members to be the best versions of themselves. Peloton delivered
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`its first bikes (the “Peloton Bike”) in 2014 and received near-universal adulation, with Men’s
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`Health naming the Bike “the best cardio machine on the planet,” and fitness experts hailing it as
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`“revolutionary,” and “category creating.” Peloton currently employs more than 1,900 people
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`across the country.
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`2.
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`The Peloton Bike is the first ever at-home exercise bike that incorporates a
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`sophisticated graphical user interface—presented on a 22-inch HD, multitouch tablet—that
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`displays live and on-demand cycling classes led by some of the world’s best instructors. The
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`Peloton Bike uses sensors to measure a rider’s performance and can display a dynamically-
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`updating leaderboard comparing the rider’s performance at each point in the class with the
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`performance of every other rider that is currently taking—or has ever taken—the same class,
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`anywhere in the world. This “leaderboard” utilizes Peloton’s patented technology to show
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`Peloton riders how their performance stacks up against all other riders that have taken that same
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`class, past and present, at every point during a class.
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`3.
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`Before Peloton invented and released the Peloton Bike, the fitness industry had
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`struggled with an intractable divide: consumers could either (1) go to in-studio fitness classes to
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`obtain the competitive thrill and engagement of working out with others, or (2) choose to use at-
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`home exercise equipment—which had seen virtually zero innovation in over a decade—to gain
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`flexibility and time. They could never do both. Peloton solved that problem, and others, with its
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`revolutionary new product and patented technology.
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`4.
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`First, Peloton solved the biggest problem associated with in-studio and in-person
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`exercise classes—that they are offered only at fixed locations and times—by allowing users to
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`bring that experience into their own home and on their own schedule. Second, Peloton solved
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`the biggest problem associated with previous at-home fitness products—user boredom due to
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`lack of engagement, community, and class variety—by providing live and on-demand classes
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`with a leaderboard on an improved and more efficient graphical user interface that not only
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`recreates but significantly enhances the real-time competition and community engagement that
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`made in-person and in-studio classes so popular.
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`5.
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`To protect these and other innovations incorporated into the Peloton Bike and the
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`Peloton Tread (Peloton’s acclaimed treadmill, released in 2018), Peloton CEO John Foley and
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`Peloton applied for, and received, multiple patents, including U.S. Patent No. 10,486,026 (“the
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`’026 Patent”) and U.S. Patent No. 10,639,521 (“the ’521 Patent,” and together with the ’026
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`Patent, “the Peloton Patents”), which are at issue in this lawsuit.
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`6.
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`With Peloton’s hard-fought success, competitors, including Defendant ICON,
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`have attempted to free ride off Peloton’s innovative technology. Historically, ICON has sold
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`traditional fitness equipment, and it develops and manufactures exercise equipment (including
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`stationary bikes and treadmills) under the brand names NordicTrack, Proform, and FreeMotion
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`(collectively, the “ICON products”).
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`7.
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`For years, ICON sought to drum up interest in the ICON products with iFit—a
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`functionality encompassing a simplistic suite of fitness offerings designed to operate on, or in
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`tandem with, ICON products. Prior to the actions giving rise to this suit, iFit never delivered live
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`classes—i.e., classes taught by instructors and streamed to users’ devices in substantially real
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`time—or offered its members the ability to participate in competitive classes via a leaderboard.
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`Instead, iFit only allowed subscribers to follow along with pre-recorded exercise classes on their
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`machines, without any sort of community engagement. Although ICON apparently intended for
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`iFit to boost consumer enthusiasm and sales of its products, its actions demonstrate it was not
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`able to reach its goal. Indeed, in July of 2015, just one year after the launch of the successful
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`Peloton Bike, ICON announced that it was laying off 400 workers at the Utah plant where it
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`manufactures much of its equipment.
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`8.
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`In 2019, Peloton became the unquestioned leader in at-home fitness and continued
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`to achieve lightning-fast growth as it went public on the NASDAQ stock exchange in September
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`2019. By that point, it had become clear to the market that consumers were tired of the same
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`boring, at-home fitness equipment that had languished in basements for decades—like the ICON
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`products—and instead wanted the revolutionary new “connected” community fitness experience
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`that Peloton offered through its patented technology.
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`9.
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`Faced with this grim reality, the very same month as Peloton’s IPO, ICON
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`announced that it would be releasing a so-called new feature: “the iFit leaderboard,” which was
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`nothing more than the Peloton leaderboard grafted onto an iFit interface. On September 27,
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`2019, ICON published a picture on The Official iFit Member Facebook page making clear that
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`rather than investing in its own technology and innovating from the ground up—as Peloton had
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`done—ICON would simply copy Peloton’s patented leaderboard technology. Shortly thereafter,
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`ICON announced that it had raised $200 million in venture capital to help “accelerate” the
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`integration of its copycat technology into ICON’s products. As media outlets like Axiom
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`recognized at the time, ICON’s actions were plainly intended to allow it to “compete with
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`Peloton,” and reflected “how home fitness companies and their investors keep moving toward
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`the Peloton model….”
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`10.
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`Then, in January of 2020, ICON launched an expensive, glossy video ad
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`campaign for a new Peloton Bike copycat product that ICON calls the NordicTrack S22i Studio
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`Cycle Bike. That ad, entitled “The Duel,” shows two actors riding their NordicTrack bikes at the
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`same time and competing against each other for a higher position on the iFit leaderboard. The
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`iFit leaderboard ICON advertised in “The Duel,” shown on the NordicTrack S22i Studio Cycle
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`Bike, is an almost exact copy of Peloton’s leaderboard.
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`11.
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`Astoundingly, ICON did not stop there: it introduced Peloton’s patented
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`technology across all ICON products with iFit functionality1—including not only stationary
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`1The list of infringing ICON products include the following: Proform Carbon T7 Treadmill,
`Proform Carbon CX Bike, Proform Studio Bike Limited, Proform 759R Rower, NordicTrack
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`bikes and treadmills, but also rowers, ellipticals, and high-intensity interval training machines. It
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`also advertised for sale exercise systems that, among other things, detect, synchronize and
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`compare the exercise metrics of remote users on a graphical user interface, just like Peloton.
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`12.
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`ICON, and ICON products with iFit functionality, infringe the Peloton Patents
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`because, among other reasons, they display archived exercise class content to remote users, track
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`a remote user’s performance, and compare that remote user’s performance against the
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`performance of other remote users via a time-synced leaderboard. Critically, ICON is profiting
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`immensely from this infringement; indeed, in March 2020, ICON’s Chief Executive Officer told
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`the Wall Street Journal that its recent sales were up over 200%. And in May 2020, ICON’s
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`President reported to the New York Times that it was experiencing sales that were “absolutely
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`bigger than any other boom time we’ve had.”
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`13.
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`Having discovered just how lucrative it was to mimic Peloton, ICON doubled
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`down on its unlawful scheme. In May 2020, ICON set its sights on yet another Peloton
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`innovation—live classes with a real-time leaderboard—and decided that it would copy this
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`aspect of the Peloton experience, as well. In all its years of existence, ICON had never offered
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`live classes on iFit. Yet in early May 2020, on the heels of its copycat leaderboard roll-out,
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`ICON enabled live classes on iFit for users operating ICON bikes and treadmills. ICON’s
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`introduction of live classes and the leaderboard is calculated to perfect its theft of market share
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`from Peloton, who has set the standard for both technologies in the at-home fitness space.
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`Commercial X321 Incline Trainer, NordicTrack T 9.5 S Treadmill, NordicTrack 8.5 S Treadmill,
`NordicTrack Commercial S22i Studio Cycle, NordicTrack Commercial S15i Studio Cycle,
`NordicTrack FS10i Elliptical, NordicTrack Fusion CST Pro, NordicTrack Fusion CST Pro with
`Rower, NordicTrack RW900 Rower, NordicTrack RW500 Rower, Freemotion T10.9b Reflex
`Treadmill, Freemotion E10.9b Elliptical and Freemotion R10.96b Recumbent Bike. Upon
`information and belief, each of these products became available for public purchase after May
`22, 2017.
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`14.
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`As if its patent infringement were not enough, ICON has additionally engaged in
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`an unlawful false advertising campaign to further undercut Peloton’s business. Specifically, to
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`unfairly increase its market share, ICON employs a practice known as false reference pricing.
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`Pursuant to this practice, ICON represents to consumers a false, inflated “original” price of a
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`product, and then informs consumers that the product is currently on sale for a significantly
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`lower, discount price. This false and deceptive practice misleads consumers into making
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`purchases of products which they were led to believe were of a higher quality, and unlawfully
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`diverts sales away from competitors who truthfully advertise their products, like Peloton.
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`Peloton is uniquely harmed by ICON’s unlawful and unfair conduct because ICON has
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`repeatedly advertised itself as an alternative to Peloton and directly sought to compare its
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`offerings to Peloton’s.
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`15.
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`Peloton brings this suit to protect its rights and put an end to ICON’s patent
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`infringement, false advertising, and deceptive business practices.
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`THE PARTIES
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`16.
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`Peloton is a corporation organized and existing under the laws of the State of
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`Delaware, with its principal place of business at 125 West 25th Street, 11th Floor, New York,
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`New York, 10001.
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`17.
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`ICON is a corporation organized and existing under the laws of the State of
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`Delaware. ICON’s principal place of business is at 1500 South 1000 West, Logan, Utah, 84321.
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`ICON sells its products online and through third-party retailers all across the United States, and
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`additionally operates an outlet store in California, located at 630 Nicholas Road, Beaumont, CA
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`92223.
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`JURISDICTION AND VENUE
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`18.
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`Certain claims in this civil action arise under the patent laws of the United States,
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`35 U.S.C. § 1 et seq. This Court has subject matter jurisdiction over the patent claims pursuant
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`to 28 U.S.C. §§ 1331 and 1338. Certain claims in this civil action also arise under the Lanham
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`Act, 15 U.S.C. § 1125. This Court has subject matter jurisdiction over the Lanham Act claims
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`pursuant to 15 U.S.C. § 1121 and under 28 U.S.C. §§ 1331 and 1338. Subject matter jurisdiction
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`over related state law claims is proper pursuant to 28 U.S.C. §§ 1338 and 1367. The state law
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`claims are integrally interrelated with Peloton’s federal claims and arise from a common nucleus
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`of operative facts such that the administration of the state law claims with the federal claims
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`furthers the interest of judicial economy.
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`19.
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`This Court has personal jurisdiction over ICON pursuant to the laws of the State
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`of Delaware and the United States Constitution because ICON is a Delaware corporation. ICON
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`also regularly and continuously transacts business in the jurisdiction, including marketing and
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`selling ICON services and products throughout the State of Delaware. ICON places infringing
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`products within the stream of commerce, which stream is directed at this district, with knowledge
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`and/or understanding that those products will be sold in the State of Delaware. ICON has also
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`disseminated false and misleading information in the State of Delaware about its products and
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`services as part of its false advertising campaign.
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`20.
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`ICON has infringed or caused infringement in the State of Delaware by, among
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`other things, promoting, offering for sale and selling infringing ICON products with iFit
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`functionality in the District. ICON also provides services and assembles products that are and
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`have been used, offered for sale, sold, and purchased in the State of Delaware. Therefore, the
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`exercise of jurisdiction over ICON is appropriate under the applicable jurisdictional statutes and
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`would not offend traditional notions of fair play and substantial justice.
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`21.
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`Venue is proper for claims of patent infringement in this district under 28 U.S.C.
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`§§ 1391(b) & (c) and 1400(b) because ICON is incorporated in the State of Delaware and has
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`committed, and continues to commit, acts of patent infringement within the district.
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`22.
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`ICON actively markets and sells ICON products with iFit functionality to
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`customers across the United States, including in the District of Delaware.
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`23.
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`ICON intends to and does advertise, demonstrate, offer for sale, and sell the
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`infringing products and services to customers in the District of Delaware. ICON intends for
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`customers to use the infringing products with iFit functionality within the District of Delaware.
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`FACTUAL ALLEGATIONS
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`I. Disrupting the Fitness Category with the Peloton Bike
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`24.
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`Unlike the at-home bikes that came before it, the Peloton Bike is a sleek,
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`technologically advanced system that combines a first-in-class exercise bike with state-of-the-art
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`technology that allows riders to experience live and on-demand cycling classes—led by some of
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`the world’s best instructors—from the comfort of their own homes.
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`25.
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`Featuring a 22-inch, high-definition, sweat resistant, multitouch tablet, the
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`Peloton Bike measures and displays a rider’s performance metrics and presents those metrics for
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`live and time-synced comparison with other Peloton riders. This new technology allows Peloton
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`riders to see where their performance stands against all other riders on a leaderboard throughout
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`the cycling class, re-creating the energetic and competitive in-studio cycling experience at home
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`on their own schedule.
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`26.
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`In fact, not only does Peloton recreate the in-studio experience in the user’s own
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`home, it significantly improves it. To illustrate the unprecedented user experience Peloton
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`created, a rider taking a regular in-studio class may (at best) see his or her performance
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`compared only against the other riders in the same class at the same time, whereas the same rider
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`taking a class on a Peloton Bike can see his or her performance compared, at every point in the
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`class, against tens of thousands (for a live class) or even hundreds of thousands (for an on-
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`demand class) of other riders from around the world, regardless of when the rider takes the class.
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`27.
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`Further, Peloton’s leaderboard allows each user to filter and control who they see
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`on the leaderboard by a variety of characteristics, including age and gender. Peloton’s
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`leaderboard also enables filtering by “All Time,” which allows the user to participate against all
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`users who have ever taken the same class, or by “Here Now,” which displays only those users
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`who are presently attending the same class at another remote location.
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`28.
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`In addition, Peloton allows its users to interact with other remote users during a
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`class, for example, by giving a virtual “high five” to another user, encouraging a friend via live
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`video chat, or, with one touch, saving a song heard in class to their favorite streaming service.
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`These features are not available (nor would they be useful) for in-studio-only cycling classes.
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`Above: The Peloton Bike
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`Above: The Peloton Bike Graphical User Interface and Leaderboard
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`Above: Peloton Leaderboard Filters – “All Time” and “Here Now”
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`29.
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`Peloton’s success has been remarkable. Men’s Health has called the Peloton Bike
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`“the best cardio machine on the planet.” USA Today has said it is “attractive, addictive, and
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`seriously whips you into shape.” And in a comparison of numerous at-home bikes, The Wall
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`Street Journal concluded that “the best bike, by far, was [the] Peloton.” The Peloton Bike also
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`received the award for the Best Health and Fitness Device at the Consumer Electronics Show in
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`2018.
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`30.
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`The Peloton Bike retails for $2,245, and owners pay $39 per month for a
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`subscription to Peloton’s exclusive live and on-demand exercise classes.
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`31.
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`As of March 31, 2020, Peloton has built its member base from zero to over 2.6
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`million in six years. Its revenue has been growing rapidly as a result. For example, in fiscal year
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`2017, Peloton’s revenue shot to over $200 million, and in fiscal year 2018, revenue doubled to
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`over $400 million. In fiscal year 2019, its revenue more than doubled again to approximately
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`$900 million. In the last quarter alone (ending March 31, 2020), Peloton generated $524.6
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`million in revenue, representing 66% year-over-year growth. Peloton has also won countless
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`awards, including being named one of the World’s Most Innovative Companies by Fast
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`Company every year since 2016.
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`32.
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`Peloton continues to expand both nationally and internationally. Most
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`importantly, Peloton is doing what it set out to do—allowing more people than ever to participate
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`in high-energy, state-of-the-art exercise classes on their own schedule, and empowering Peloton
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`users to maximize their most valuable resource: time.
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`II. The Journey to Inventing the Peloton Bike
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`33. When Peloton was founded, fitness studios that provided studio cycling classes
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`were becoming tremendously popular. SoulCycle and Flywheel had multiple studios and were
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`growing quickly. While such in-studio classes provide a great consumer experience, they start at
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`predetermined times, have limited space per class, and may meet at inconvenient locations for
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`some customers. As a result, in-studio classes can be hard to attend for people with busy work
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`schedules and families at home. Peloton CEO John Foley was one of those people.
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`34.
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`After realizing that countless others undoubtedly faced the same challenge, Foley
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`began a journey that would see him and his co-founders invent a new category of fitness
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`equipment that provides the immersive, fun and competitive in-studio cycling class experience,
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`at home, at any time.
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`35.
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`Having majored in industrial engineering at Georgia Tech and studied business at
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`Harvard Business School, Foley then worked in e-commerce and the tech industry for over a
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`decade. This gave him a sophisticated understanding of the intersection of business and
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`technology. Foley also realized that this project would require a team of smart, savvy leaders in
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`different fields to bring it to consumers, and he therefore started recruiting other tech leaders who
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`shared his vision.
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`36.
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`In September 2011, Foley shared his vision with Hans Woolley, co-inventor of
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`the Peloton Patents, at a conference for media executives in Sun Valley, Utah. The two bounced
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`ideas back and forth during the weekend conference and began planning next steps shortly after
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`arriving home from the conference.
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`37.
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`Foley also approached his friend and former colleague Tom Cortese. Over dinner
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`one night in December 2011, Foley told Cortese that he believed there was a large, untapped
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`market available if they could just figure out how to allow cycling fans to access the best
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`instructors and have an in-studio cycling class experience at any time, no matter where they live
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`and no matter how busy their schedules are. Cortese joined and has been with Peloton ever
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`since, currently serving as Peloton’s Chief Operating Officer.
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`38.
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`Foley also recruited three others, whom he asked to join as co-founders of
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`Peloton: technology guru Yony Feng, to help design and build a prototype Peloton Bike;
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`accomplished lawyer Hisao Kushi, to guide Peloton through the legal and regulatory framework
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`facing the new start-up; and internet executive Graham Stanton, to help guide the company
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`through its early years and to manage the company’s finances and growth strategy. All accepted,
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`and all three remain involved with the company to this day. Feng is Peloton’s Chief Technology
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`Officer; Kushi is Chief Legal Officer; and Stanton still advises Peloton in a consulting capacity.
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`39. With a strong team in place, Foley was able to raise an initial seed investment of
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`$350,000, along with $50,000 of Foley’s own savings. This allowed the young start-up to rent a
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`small office in New York City from which it could develop and create the first prototype of the
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`Peloton Bike.
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`40.
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`To create the product that Foley and his co-founders envisioned, Peloton
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`developed (1) a visually appealing, sturdy, and technologically advanced exercise bike; (2) a
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`large, sweatproof, wi-fi enabled, high-definition touchscreen tablet computer; (3) an attractive
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`graphical user interface and related software and backend systems to integrate the bike and tablet
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`and track, synchronize, and dynamically display metrics to connect a community of riders; and
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`(4) first-in-class cycling class content and the systems to deliver that content. All equipment
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`needed to be durable, lasting for years of use with minimal maintenance.
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`41.
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`Start-ups often partner with existing companies and products to custom build as
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`little as possible. Building one’s own hardware and software from the ground up, by contrast, is
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`expensive, time-consuming, and fraught with obstacles, known and unknown. However, Peloton
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`quickly discovered that no existing exercise bike had all the required characteristics: sturdiness,
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`durability, visual appeal, efficiency, and technological capability. Nor was there any touchscreen
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`tablet available on the market at the time that would suit its needs. In addition, Peloton realized
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`that no existing products could communicate with the bike hardware, or track and analyze rider
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`performance in the way they envisioned. In short, the Peloton team quickly realized that it
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`would need to create virtually the entire Peloton Bike from scratch, including the bike, tablet,
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`and software.
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`42. What’s more, to effectuate its vision of immersive studio cycling at home, Peloton
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`also needed to figure out how to integrate the hardware (the bike and tablet) with its own
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`software so that the software could communicate with the bike to track performance metrics,
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`store those metrics, communicate those metrics back to the rider, and transfer those metrics to a
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`server so that they could be synchronized and compared with other riders’ metrics.
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`43.
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`The technological challenges and unknowns faced by the Peloton team also
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`created a significant financial hurdle. Investors viewed Peloton’s plan to build its own hardware
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`and software as too costly and difficult, and were not convinced there was a viable market for the
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`product or that the technology would work. Dozens of investors declined the opportunity to
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`invest in Peloton because they were not willing to take the risk of investing up front in such a
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`new and challenging endeavor.
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`44.
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`Yet, through research, ingenuity, and persistence, Peloton pushed on, working
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`with two core manufacturing partners to design and produce the necessary high-tech, sleek bikes
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`and tablets. To build the first prototype, Feng, the Chief Technology Officer then and now,
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`created a proof-of-concept apparatus using a standard off-the-shelf stationary bike, then attaching
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`sensors with a stripped-down electronics board running the Android-based app that he developed
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`and a computer monitor rigged to the bike’s front. As reflected in the images below, Feng went
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`through a long, iterative process to develop a successful hardware-software integration.
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`Above: Testing the software with an early version of Peloton Bike
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`The early version of the Peloton Bike, left, compared with the version at launch, right:
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`The progression of hardware-software integration development for the Peloton Bike:
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`45.
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`This unique hardware-software integration would be the basis for Peloton’s
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`prototype. By the end of 2012, after a year of hard work, investment, and development, Peloton
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`finally had a prototype in hand to show investors.
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`46.
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`But even after the Peloton Bike prototype was created, Peloton struggled to raise
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`money. Foley was rejected by countless investment firms and was repeatedly told that the
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`Peloton Bike simply was not viable.
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`47.
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`Yet, despite these repeated rejections, Foley persisted—continuing to take risks,
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`making significant personal investments, and dedicating more time to developing the best
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`possible product. He did so because of his belief that at-home fitness equipment simply had not
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`evolved at the same pace that group exercise classes had. He continued to pitch potential
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`investors until, many rejections later, he found a group of investors who believed in Peloton and
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`invested the first $10 million that helped launch the Peloton Bike on a commercial scale.
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`III. Bringing the Peloton Bike to Market
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`48.
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`After additional troubleshooting and tinkering on the early prototype bikes,
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`Peloton was ready to take the important step of manufacturing the bike and selling it to its first
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`customers. Peloton held a Kickstarter campaign with the goal of raising enough capital to start
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`manufacturing the bike. As Peloton explained, “[t]his involves building the ‘tools’ required to
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`create each unique part (yes, we first have to build the machinery that will build the bike!) and
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`pre-purchasing lots of steel, aluminum, plastic, microchips (there are 17 in our console alone).”
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`The Kickstarter campaign raised more than $300,000 and generated initial orders for 188 bikes.
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`49.
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`Sales were initially slow—188 bikes was far from Peloton’s target, and far from
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`the demand Foley knew existed. Peloton was a new product, and people were wary of the
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`product and how useful it would be. Like every other phase of their journey, Peloton was not
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`going to become successful overnight—they were going to have to work for it. With intensive
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`and creative marketing efforts, including pop-up stores in choice locations, and as word of mouth
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`spread, sales began to pick up.
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`50.
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`In January 2014, two years after Peloton was founded, the first bikes were
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`delivered to customers.
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`51.
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`By now, Peloton has designed in-house almost everything that other companies
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`outsource to third parties: hardware, software, content, and logistics. As an Inc.com article
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`reported, “Peloton has defied every aspect of the prevailing startup ethos of doing it fast and
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`lean, buying off the shelf, partnering and, above all, custom-building as little as possible.”
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`IV. Continued Innovation with the Peloton Tread
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`52.
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`Encouraged by the groundswell of consumer support for the Peloton Bike, Foley
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`and the Peloton team wasted no time in bringing the Peloton experience to a new platform. In
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`2016, Peloton began developing a treadmill. The finished product, called the Peloton Tread, was
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`introduced to the public in 2018.
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`53.
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`The Peloton Tread is a natural extension of the Peloton Bike. Like the Peloton
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`Bike, the Peloton Tread is a sophisticated, internet-integrated exercise system that combines a
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`state-of-the-art treadmill featuring a customized, low-impact, shock-absorbing slat belt, with
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`Peloton’s patented interactive technology, allowing users to experience engaging live and on-
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`demand classes with others from the comfort of their own homes.
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`54. With its immersive, 32-inch full high-definition, sweat resistant tablet and a 20
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`watt soundbar, the Peloton Tread was designed to maximize and enhance the ultra-realistic,
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`competition-based, and interactive user interface that people have come to associate with the
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`Peloton experience. Just like on the Peloton Bike, the patented technology on the Peloton Tread
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`allows users to participate in exercise classes led by world-renowned fitness experts and view, on
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`a dynamically-updating leaderboard, how their performance stands, at any given point in a class,
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`against all other users who have taken the class, past or present.
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`55. With the Peloton Tread, Peloton dramatically reconceptualized the limits of
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`traditional treadmills in two ways. First, Peloton found a way to turn exercising on a treadmill—
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`usually a solitary enterprise—into a class form with competition. While competitive running has
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`long existed in the form of outdoor or indoor races, Peloton was the first to implement
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`competitive running on at-home treadmills by offering live and on-demand classes with a
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`leaderboard. Prior to the Peloton Tread, it was not well-known for treadmills to offer a
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`leaderboard or comparative display enabling multiple users to see, at every point during the run,
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`how their performance compares to all the other runners that have experienced, or are presently
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`experiencing, the same class.
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`56.
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`Second, the Peloton Tread also reimagined the types of workout classes that can
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`be adapted for a treadmill. In addition to classes conducted entirely on the machine, the Peloton
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`Tread offers a panoply of high-energy, instructor-led bootcamp and circuit training