Case 4:21-cv-00215-MW-MAF Document 1 Filed 05/25/21 Page 1 of 14
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`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF FLORIDA
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`RASHAD GREENE and JASMINE GREENE,
`Individually, and as Guardians of his minor
`child, R.G.,
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`Plaintiff, Case No. ____________________
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`v.
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`PELOTON INTERACTIVE, INC., a
`Delaware Corporation,
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`Defendant.
` /
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`COMPLAINT AND DEMAND FOR JURY TRIAL
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`Plaintiff, RASHAD GREENE and JASMINE GREENE, Individually and as Guardians of
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`their minor child, R.G., brings this action against Defendant, PELOTON INTERACTIVE, INC.
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`(hereinafter “PELOTON”), and alleges as follows:
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`INTRODUCTION
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`1.
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`This action is brought on behalf of Plaintiffs, RASHAD GREENE and JASMINE
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`GREENE individually, and as legal guardians of their minor child, R.G. against Defendant, Peloton,
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`for violations of applicable consumer protection laws, unfair business practice laws and breaches
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`of warranties in connection with the manufacture, marketing, sale, and failure to honor warranties
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`of Peloton’s “Tread” and “Tread+” (formerly known as the “Tread”) treadmills (hereinafter
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`referred to as “Tread”).
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`2.
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`The Peloton Tread machine—manufactured and sold by Peloton—retails for $2,495.
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`But consumers do not just pay the purchase price. Owners of these devices must pay subscription
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`fees on top of the purchase price in order to have full use of the machine.
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`Case 4:21-cv-00215-MW-MAF Document 1 Filed 05/25/21 Page 2 of 14
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`3.
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`Peloton’s website boasts that its Tread machines have a “well-constructed” belt
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`designed to avoid “stretching and slipping,” thereby preventing injury to the user.1 Many loyal
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`Peloton consumers, like Plaintiff, once agreed. But a recent chain of events confirms that, while
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`the Tread belt design may prevent injury to the user of the treadmill, it creates an unreasonable
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`risk of danger to children (and pets) who may be near the Tread.
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`4.
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`Defendant further markets its treadmills as appropriate for family use by creating
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`and displaying advertisements of a mother and child working out next to a Peloton Tread+
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`together. These advertisements, however, are misleading given that the unforgiving design of the
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`Tread and Tread+ present a uniquely dangerous threat to children—namely, because the design is
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`extremely susceptible to children (and pets) getting trapped underneath the machine while
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`operating, leading to injuries that range from bruising and abrasion, to broken bones, to permanent
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`brain injury, and even death.
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`5.
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`On April 17, 2021, after receiving many complaints and becoming the subject of an
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`investigation by the Consumer Product Safety Commission (“CPSC”), the CPSC issued a direct
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`warning to consumers: “Stop using the Peloton Tread+ if there are small children or pets at home.”2
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`According to the CPSC, there is no safe and practical way to have this device in a home where
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`there are children. Despite being informed of these incidents, Peloton initially rejected the CPSC’s
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`warning, maintaining the machine is perfectly safe, in defiance of the clear evidence that
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`demonstrating the unreasonable dangers the treadmills present to small children and pets.
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`1 https://www.onepeloton.com/tread-plus (last visited Apr. 22, 2021).
`2 CPSC Warns Consumers: Stop Using the Peloton Tread+, CONSUMER PROD. SAFETY COMM’N (Apr. 17,
`2021),
`https://www.cpsc.gov/Newsroom/News-Releases/2021/CPSC-Warns-Consumers-Stop-Using-the-
`Peloton-Tread+.
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`2
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`Case 4:21-cv-00215-MW-MAF Document 1 Filed 05/25/21 Page 3 of 14
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`6.
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`On May 5, 2021, the CPSC and Peloton announced the Recall of the Tread and
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`Tread+ treadmills.3 Under the “Incidents/Injuries” section, Peloton reports that in addition to the
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`death of a 6-year-old child, “Peloton has received 72 reports of adult users, children, pets, and/or
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`objects being pulled under the rear of the treadmill, including 29 reports of injuries to children
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`such as second- and third-degree abrasions, broken bones, and lacerations.”4
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`7.
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`Unfortunately, Plaintiffs’ minor child, R.G., was harmed by Peloton’s Tread
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`machine in the very same way that the CPSC warned. Plaintiffs’ six-year-old son was dragged
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`underneath the treadmill and suffered burns to his shoulder and face. Plaintiffs bring this lawsuit
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`to redress the injuries sustained by their six-year-old son.
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`PARTIES, JURISDICTION, AND VENUE
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`8.
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`Plaintiffs, RASHAD GREENE and JASMINE GREENE, are citizens of
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`Tallahassee, Florida. Plaintiffs purchased the Peloton Tread in the Summer of 2020. At all
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`relevant times, Plaintiffs were unaware of the dangerous characteristics of this product. Had
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`Plaintiffs known the true dangers that could result from purchase and use of the Peloton Tread,
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`Plaintiffs would not have purchased it.
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`9.
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`Defendant, PELOTON INTERACTIVE, INC., is, upon information and belief, a
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`corporation organized and existing under the laws of the State of Delaware and having its principal
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`place of business at 125 West 25th Street, New York, NY 10001. At all relevant times, PELOTON
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`was, and is, in the business of designing, creating, manufacturing, assembling, testing, labeling,
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`3 CPSC and Peloton Announce: Recall of Tread+ Treadmills After One Child Death and 70 Incidents; Recall of
`Tread Treadmills Due
`to Risk of Injury, CONSUMER PROD. SAFETY COMM’N (May 5, 2021),
`https://www.cpsc.gov/Newsroom/News-Releases/2021/CPSC-and-Peloton-Announce-Recall-of-Tread-Plus-
`Treadmills-After-One-Child-Death-and-70-Incidents-Recall-of-Tread-Treadmills-Due-to-Risk-of-Injury#.
`4 Peloton Recalls Tread+ Treadmills After One Child Died and More Than 70 Incidents, CONSUMER PROD.
`SAFETY COMM’N (May 5, 2021), https://www.cpsc.gov/Recalls/2021/peloton-recalls-tread-plus-treadmills-
`after-one-child-died-and-more-than-70-incidents.
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`3
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`Case 4:21-cv-00215-MW-MAF Document 1 Filed 05/25/21 Page 4 of 14
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`supplying, packaging, warning, promoting, marketing, developing, and/or selling the Tread+.
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`These products are sold throughout the United States.
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`10. The Court has subject matter jurisdiction over this action because it exceeds fifteen
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`thousand dollars ($15,000.00), exclusive of fees and costs.
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`11. The Court has personal jurisdiction over Defendant because it does business in the
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`Northern District of Florida and has sufficient minimum contacts with Tallahassee, Florida.
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`Defendant intentionally avails itself of the markets in this State through the promotion, marketing,
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`distribution, and sale of Peloton Tread and Tread+ machines to render the exercise of jurisdiction
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`by this Court permissible under Florida law and the U.S. Constitution.
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`12. Venue is proper in the Northern District of Florida pursuant to 28 U.S.C. §
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`1391(b)(2) and (3) because a substantial part of the events or omissions giving rise to the claims
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`at issue in this Complaint arose in this District and Defendant is subject to the Court’s personal
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`jurisdiction with respect to this action.
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`GENERAL FACTUAL ALLEGATIONS
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`13. The Peloton Tread machine designed, manufactured, marketed, promoted, and sold
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`by Peloton. It retails for $2,495 and is sold directly to consumers by Peloton. However, consumers
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`do not just pay the purchase price. Owners of these devices must pay subscription fees on top of
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`the purchase price to have full use of the machine.
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`14. The Peloton Tread is a treadmill, designed for walking, running, or climbing while
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`staying in the same place on an endless belt.
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`Case 4:21-cv-00215-MW-MAF Document 1 Filed 05/25/21 Page 5 of 14
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`15. Defendant marketed the Tread as “next level total body training” that “empowers”
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`you to “step on for miles, jump off for strength, [and] achieve every goal.”5 Defendant similarly
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`marketed the Tread+ as “Your hardest training session. Your softest road. The shock-absorbing
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`belt, built with 59 individual slats, adds support under every step and maximum comfort to your
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`toughest workouts.” Defendant’s website further boasts that its Tread+ has a “well-constructed”
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`belt designed to avoid “stretching and slipping,” thereby preventing injury to the user.6
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`16. Peloton’s Tread and Tread+ machines contain significant design flaws that make
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`them defective, unfit for use in a home with children, and unreasonably dangerous for their
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`intended purpose—namely, because the design is extremely susceptible to children (and pets)
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`getting trapped underneath the machine while it is operating.
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`17. This risk does not extend only to children using the machine without being
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`supervised. Parents, while using the treadmills, have had their children approach the machine, out
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`of eyesight of the parent, and those children been trapped and injured by the machines.
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`18. Unlike other treadmills, Peloton’s treadmills have a large space under the belt of the
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`machine—and no safety bar, belt guard, or other safety feature that could prevent a child (or pet)
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`from being sucked underneath the machine while in use (as depicted by the Figures below).
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`5 https://www.onepeloton.com/tread (last visited May 19, 2021).
`6 https://www.onepeloton.com/tread-plus (last visited Apr. 22, 2021).
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`5
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`Case 4:21-cv-00215-MW-MAF Document 1 Filed 05/25/21 Page 6 of 14
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`Figure 1: Peloton Tread+
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`Figure 2: Treadmill with Safety Bar
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` Figure 3: Treadmill with Belt Guard
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`19. Unfortunately, the ‘unique’ and ‘sleek’ design of Peloton’s treadmills make these
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`machines uniquely susceptible to children (and pets) getting trapped underneath the machine while
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`they are operating, making them unreasonably dangerous.
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`20. Worse, Defendant marketed the treadmills as appropriate with family use,
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`advertising the product with pictures like the one below, featuring a woman with a young girl—
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`presumably her daughter—working out with the device, using its screen to follow along while the
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`exercise immediately next to the machine:
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`6
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`Case 4:21-cv-00215-MW-MAF Document 1 Filed 05/25/21 Page 7 of 14
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`Chillingly, the child featured in the picture is exactly the sort of victim that Peloton’s treadmills
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`are uniquely capable of killing or maiming.
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`21. On April 17, 2021, the Consumer Product Safety Commission (“CPSC”) issued the
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`following the Warning to consumers: “Stop Using the Peloton Tread+”.7
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`22. According to the CPSC’s investigation: “To date, CPSC is aware of 39 incidents
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`including one death. CPSC staff believes the Peloton Tread+ poses serious risks to children for
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`abrasions, fractures, and death. In light of multiple reports of children becoming entrapped,
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`pinned, and pulled under the rear roller of the product, CPSC urges consumers with children at
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`home to stop using the product immediately.”8
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`23. The CPSC further noted that its investigation has led the CPSC to believe “that at
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`least one incident occurred while a parent was running on the treadmill, suggesting that the hazard
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`cannot be avoided simply by locking the device when not in use.”9 Reports of domestic pets and
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`7 CPSC Warns Consumers: Stop Using the Peloton Tread+, CONSUMER PROD. SAFETY COMM’N (Apr. 17,
`2021),
`https://www.cpsc.gov/Newsroom/News-Releases/2021/CPSC-Warns-Consumers-Stop-Using-the-
`Peloton-Tread+ (emphasis added).
`8 Id.
`9 Id.
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`Case 4:21-cv-00215-MW-MAF Document 1 Filed 05/25/21 Page 8 of 14
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`objects being sucked beneath the machine have also been made.
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`24. The April 17, 2021 Warning also contains the link to a disturbing video of a child
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`being dragged underneath the treadmill in order to “demonstrate[] the hazard to children posed by
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`the Tread+.”10 This video is horrifically similar to what happened to Plaintiffs’ six-year-old son,
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`R.G.
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`25. On April 17, 2021, Peloton published a News Release titled, “CPSC Publishes
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`Misleading, Inaccurate Bulletin on Tread+ Product Safety.”11
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`26.
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`In the News Release, Peloton openly rejected the CPSC’s warning, maintaining that
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`its machine is perfectly safe, in defiance of the evidence that its treadmills are pose a uniquely
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`dangerous threat to children.
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`27. On May 5, 2021, the CPSC and Peloton announced the Recall of the Tread and
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`Tread+ treadmills.12 Under the “Incidents/Injuries” section, Peloton reports that in addition to the
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`death of a 6-year-old child, “Peloton has received 72 reports of adult users, children, pets, and/or
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`objects being pulled under the rear of the treadmill, including 29 reports of injuries to children
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`such as second- and third-degree abrasions, broken bones, and lacerations.”13
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`28. Upon recalling the treadmills, John Foley—Chief Executive Officers of Peloton—
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`stated that the company had “made a mistake” by fighting the CPSC’s request to recall the
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`treadmills, and apologized for not engaging “more productively with them from the outset.”14
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`10 Id. (citing https://www.youtube.com/watch?v=onXNnlCYJ4Y).
`11 https://investor.onepeloton.com/news-releases/news-release-details/peloton-refutes-consumer-product-
`safety-commission-claims (last visited Apr. 22, 2021).
`12 See supra note 3.
`13 See supra note 4.
`14 See supra note 3.
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`Case 4:21-cv-00215-MW-MAF Document 1 Filed 05/25/21 Page 9 of 14
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`29. As a direct result of the defective design/warnings and Defendant’s negligence,
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`Plaintiffs’ minor child was harmed by the Peloton Tread.
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`30. Plaintiffs, RASHAD GREENE and JASMINE GREENE, purchased the Peloton
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`Tread in the Summer of 2020.
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`31. Upon purchasing Defendant’s Peloton Tread for the purchase price of $2,495 and
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`cost of ongoing subscriptions, Plaintiffs understood the product to be safe for use in a home with
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`children.
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`32.
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`In November of 2020, Plaintiffs six-year old son, R.G., was dragged by his clothing
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`underneath the Tread. Upon being dragged underneath the treadmill, R.G.’s face and shoulder
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`were burned.
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`33. As a result, Plaintiffs’ minor child sustained discoloration and scarring to his face as
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`well as mental and emotional trauma.
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`CAUSES OF ACTION
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`COUNT I
`Strict Products Liability – Design Defect
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`34. Plaintiffs incorporate by reference paragraphs 1–33 above as if fully set forth herein
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`and further declare:
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`35. At all material times, Defendant sold, distributed, manufactured, marketed, and/or
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`promoted the Peloton Tread.
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`36. The Tread contains significant design flaws that makes it defective, unfit for use in
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`a home with children, and unreasonably dangerous for its intended purpose—namely, because the
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`design is extremely susceptible to children (and pets) getting trapped underneath the machine while
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`it is operating.
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`9
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`Case 4:21-cv-00215-MW-MAF Document 1 Filed 05/25/21 Page 10 of 14
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`37. Unlike other treadmills, the Peloton Tread has a large space under the belt of the
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`machine—and no safety bar, belt guard, or other safety feature that can prevent and child (or pet)
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`from being sucked underneath the machine while in use (as depicted by Figures 1–3 supra).
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`38. At all material times, Defendant’s Tread was expected to reach, and did reach,
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`consumers in the State of Florida, including Plaintiff, without substantial change in the condition
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`it was sold.
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`39. At all material times, Defendant sold, distributed, manufactured, marketed, and/or
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`promoted the Tread in a defective and unreasonably dangerous condition at the time they were
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`placed in the stream of commerce in ways that include:
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`40. As a direct and proximate result of Defendant’s defectively designed treadmills,
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`Plaintiffs and their minor child, R.G., suffered and will continue to suffer severe and permanent
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`physical and emotional injuries.
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`COUNT II
`Strict Products Liability – Failure to Warn
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`41. Plaintiffs incorporate by reference paragraphs 1–33 above as if fully set forth herein
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`and further declare:
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`42. Defendant sold, distributed, manufactured, marketed, and/or promoted the Peloton
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`Tread to consumers.
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`43. Defendant placed its product, the Peloton Tread, into the stream of commerce.
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`44. Defendant expected the Tread to reach to reach (and it did reach) consumers,
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`including Plaintiffs, without substantial alteration in the condition in which it was sold.
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`45. Peloton’s Tread and Tread+ treadmills were not reasonably safe for their intended
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`use and were defective as described herein due to their lack of appropriate and necessary warnings.
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`46. At all material times, Defendant had a duty to warn the public, including Plaintiffs,
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`how to use its treadmills in a reasonably safe manner and properly label the treadmills to give
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`reasonable warning of the dangers of the treadmills, including by:
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`a. warning or instructing of the treadmills’ dangerous and defective characteristics;
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`b. adequately warning Plaintiffs that the use of the Tread and Tread+ carried a risk
`of pulling children, pets, or other objects underneath the treadmill while in
`motion;
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`c. warning or instructing that the Tread and Tread+ do not have a safety feature
`that prevents children, pets, or other objects from being dragged underneath the
`treadmill while in motion;
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`d. providing adequate post-marketing warnings or instructions after Defendant
`knew or should have known of the significant risks associated with the use of its
`Tread and Tread+ treadmills; and
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`e. adequately and timely informing Plaintiffs and the public of the risks of serious
`personal injury from the Tread and Tread+ as described herein.
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`47. As a direct and proximate result of Defendant’s failure to warn, Plaintiffs were not
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`adequately warned of the harms that could occur with use of Peloton treadmills as discussed in
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`this complaint. As a direct and proximate result, Plaintiffs and their minor child, R.G., suffered
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`and will continue to suffer severe and permanent physical and emotional injuries.
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`48. Defendant is, therefore, strictly liable to Plaintiffs for designing, manufacturing,
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`marketing, labeling, packaging, and selling a defective product(s).
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`49. Further, to the extent the warnings provided with the Tread and Tread+ were
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`adequate, they were nullified by Defendant’s conduct. The Nester® warning was nullified due to
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`the rejecting and downplaying of the risks of serious risks associated with the Tread and Tread+
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`as identified by the CPSC. See supra at ¶ 5, 26.
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`COUNT III
`Negligence
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`50. Plaintiffs incorporate by reference paragraphs 1–33 above as if fully set forth herein
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`and further declare:
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`51. Defendant had a duty to individuals, including Plaintiffs, to use reasonable care in
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`designing, manufacturing, marketing, labeling, packaging, and selling its treadmills to consumers.
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`52. Defendant was negligent in failing to use reasonable care as described herein in
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`designing, manufacturing, marketing, labeling, packaging, and selling the Tread and Tread+.
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`53. At the time it designed the Tread and Tread+, Defendant had the duty to design the
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`treadmills in a reasonably safe manner including by:
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`a. adequately and properly designing, developing, implementing, administering,
`supervising, and/or monitoring testing of the Tread and Tread+;
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`b. performing appropriate testing of the Tread and Tread+;
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`c. adequately and properly testing the Tread and Tread+ before and after placing
`it on the market;
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`d. conducting sufficient testing on the Tread+ and Tread+ which, if properly
`performed, would have shown the risks it presents to children, pets, and objects
`that may be dragged underneath;
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`e. incorporate reasonable safety features that prevent children, pets, or other
`objects from being dragged underneath the treadmill while in motion; and
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`f. adequately and timely informing Plaintiffs and the public of the risks of serious
`personal injury from the Tread and Tread+ as described herein.
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`54. Defendant breached the aforementioned duties in the following ways:
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`a. failing to adequately and properly design, develop, implement, administer,
`supervise, and/or monitor testing of the Tread and Tread+;
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`b. failing to perform appropriate testing of the Tread and Tread+;
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`c. failing to adequately and properly test the Tread and Tread+ before and after
`placing it on the market;
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`12
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`d. failing to conduct sufficient testing on the Tread+ and Tread+ which, if properly
`performed, would have shown the risks it presents to children, pets, and objects
`that may be dragged underneath;
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`e. failing to incorporate a safety feature that prevents children, pets, or other
`objects from being dragged underneath the treadmill while in motion; and
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`f. failing to adequately and timely inform Plaintiffs and the public of the risks of
`serious personal injury from the Tread and Tread+ as described herein.
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`55. Defendant also negligently failed to warn or instruct Plaintiffs, including but not
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`limited to, the following:
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`a. warning or instructing of the treadmills’ dangerous and defective characteristics;
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`b. adequately warning Plaintiffs that the use of the Tread and Tread+ carried a risk
`of pulling children, pets, or other objects underneath the treadmill while in
`motion;
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`c. warning or instructing that the Tread and Tread+ do not have a safety feature
`that prevents children, pets, or other objects from being dragged underneath the
`treadmill while in motion;
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`d. providing adequate post-marketing warnings or instructions after Defendant
`knew or should have known of the significant risks associated with the use of its
`Tread and Tread+ treadmills; and
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`e. adequately and timely informing Plaintiffs and the public of the risks of serious
`personal injury from the Tread and Tread+ as described herein.
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`56. Defendant breached the aforementioned duties in the following ways:
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`a. failing to warn or instruct of the treadmills’ dangerous and defective
`characteristics;
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`b. failing to adequately warn Plaintiffs that the use of the Tread and Tread+ carried
`a risk of pulling children, pets, or other objects underneath the treadmill while in
`motion;
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`c. failing to warn or instruct that the Tread and Tread+ do not have a safety feature
`that prevents children, pets, or other objects from being dragged underneath the
`treadmill while in motion;
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`d. failing to provide adequate post-marketing warnings or instructions after
`Defendant knew or should have known of the significant risks associated with
`the use of its Tread and Tread+ treadmills; and
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`e. failing to adequately and timely inform Plaintiffs and the public of the risks of
`serious personal injury from the Tread and Tread+ as described herein.
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`57. As a direct and proximate cause of Defendant’s negligence, Plaintiffs were not
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`adequately warned of the harms that could occur with use of Peloton treadmills as discussed in
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`this complaint. As a direct and proximate result, Plaintiffs and their minor child, R.G., suffered
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`and will continue to suffer severe and permanent physical and emotional injuries.
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`DEMAND FOR JURY TRIAL
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`58. Plaintiffs hereby demand a trial by jury on all issues so triable.
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`Dated: May 25, 2021
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`Respectfully submitted,
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`SCHLESINGER LAW OFFICES, P.A.
`Attorneys for Plaintiffs
`1212 S.E. 3rd Ave.
`Fort Lauderdale, FL 33316
`(954) 467-8800
`
`/s/ Jonathan R. Gdanski
`Jonathan R. Gdanski
`Florida Bar No.: 0032097
`Jeffrey L. Haberman
`Florida Bar No.: 98522
`Sarah Schultz
`Florida Bar No.: 1018179
`jonathan@schlesingerlawoffices.com
`Jhaberman@schlesingerlaw.com
`sarah@schlesingerlaw.com
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`14
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