Case 2:20-cv-00382-JRG Document 1 Filed 12/14/20 Page 1 of 36 PageID #: 1
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`MAD DOGG ATHLETICS, INC.
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`Plaintiff,
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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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`v.
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`Defendant.
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Plaintiff Mad Dogg Athletics, Inc. (“MDA”) hereby alleges, for its Complaint against
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`Defendant Peloton Interactive, Inc. (“Peloton”), on personal knowledge as to MDA’s own actions
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`and on information and belief as to the actions of others, as follows:
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`OVERVIEW OF THE ACTION
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`1.
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`MDA created the indoor cycling market with the introduction of its Spinning® bikes
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`and programs in the early 1990s and has been a source of continuous innovation in the fitness
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`industry over the past 25 years. In 1994, cyclists and entrepreneurs John Baudhuin and Johnny
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`Goldberg (affectionately known as “Johnny G” in the Spinning® community) founded MDA to
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`develop the Spinning® indoor cycling program and the Spinner® line of bikes. When John and
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`Johnny G started manufacturing bikes in a garage a few years earlier, they never imagined their
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`cycling-based program and indoor cycling bikes would one day become a global fitness
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`phenomenon and create an entirely new market in the fitness industry. As cyclists, the two were
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`looking to build a better stationary bike for cycling training, and together they built the first
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`Spinner® indoor cycling bike using the ergonomics, feel and geometry of a real road bike. Unlike
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`traditional stationary bikes that were ridden in a seated position, the frame geometry of the
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`Spinner® indoor cycling bikes allowed riders to alternate seated and standing positions as they
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`would when riding out on the road. By incorporating a high-quality rigid steel frame and
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`components found on traditional road bikes like aluminum cranks, shift levers to adjust resistance,
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`clipless pedals, aerodynamic handlebars and racing saddles, John and Johnny created the first
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`indoor cycling experience for riders that simulated the feel of riding out on the road.
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`An original Spinner® bike from 1993
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`2.
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`Between 1991 and 1994, the two manufactured approximately 150 indoor cycling
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`bikes that went to select studios and gyms in Los Angeles and New York. With John running the
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`business and Johnny G tirelessly promoting the Spinning® program, the pair realized that their
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`indoor cycling program was quickly becoming a mainstream fitness craze. In 1993, Rolling Stone
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`named “Spinning” the “hot exercise” in the magazine’s annual “hot list.” With the success of their
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`indoor bikes and cycling program, John and Johnny officially incorporated MDA on April 14,
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`1994, and shortly thereafter registered and trademarked the Spin®, Spinning® and Spinner® names
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`for its extended range of bikes, programs and products.
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`3.
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`As demand for Spinner® bikes rapidly increased, MDA licensed its technology and
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`trademarks and outsourced manufacturing to Schwinn to help commercialize the Spinning® indoor
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`cycling bikes and concept. From the very beginning, MDA was not only focused on manufacturing
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`its bikes, but also incorporating the science of cycling and performance training into its programs
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`and classes. In 1995, MDA launched the Spinning® Instructor Certification Program to train the
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`growing number of fitness professionals interested in teaching indoor cycling classes. The
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`Spinning® Instructor Certification Program quickly became the gold standard for indoor cycling
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`education and certification. To date, MDA has trained over 300,000 instructors and has reached
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`millions of enthusiasts in over 80 countries through a worldwide network of thousands of fitness
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`studios and gyms.
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`Spinning Event, Italy 2020
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`4.
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`After Schwinn filed for bankruptcy in 2001, MDA created a new line of Spinner®
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`bikes that incorporated the latest advances in manufacturing technology. The Spinner® NXT
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`became the first indoor cycling bike to incorporate corrosion-resistant aluminum into its designs.
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`Not satisfied with having Spinning® bikes, classes and programs available only in studios and
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`clubs, MDA embarked on an ambitious program to make indoor cycling available to fitness
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`enthusiasts in their homes. In 2003, MDA launched its first Spinner® indoor cycling bike and video
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`series focused on bringing the same expert coaching found in Official Spinning® Facilities to riders
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`at home. Shortly thereafter, Johnny G retired from the business to pursue other interests.
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`5.
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`Realizing that there was an increasing demand for home-based Spinning® indoor
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`cycling bikes, programs and content, MDA expanded its line of indoor cycling bikes for the home
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`and its library of instructor-led classes on DVD. In 2008, MDA forever changed the indoor cycling
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`world with the introduction of the eSpinner®—the world’s first touch-screen display-controlled
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`indoor cycling bike. The eSpinner® finally brought instructor-led coaching and heart rate training
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`straight to riders in the comfort of their own home. MDA was awarded patent protection on the
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`core functionality of this revolutionary product.
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`The eSpinner®
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`6.
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`For the home market, MDA currently manufactures a line of connected Spinner®
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`bikes and a complete line of Spinning-branded apparel and accessories. In 2018, MDA unveiled
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`the new Active and Performance Series lines of Spinner® bikes, all high-quality bikes designed for
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`the home that provide studio-grade quality, ergonomics and functionality. Each of the bike models
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`in the Active and Performance Series was carefully designed and meticulously engineered to
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`provide authentic studio experience for riders at home. In addition, the Spinning Digital and
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`Spinning Digital+ apps provide users at home with the ability to access studio quality classes from
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`top Spinning instructors from around the world with classes in both English and Spanish.
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`7.
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`In the commercial market, MDA works with Precor® to manufacture and distribute
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`the Spinning® line of commercial indoor cycling bikes. The collaboration leverages Precor’s global
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`operations and MDA’s expertise in indoor cycling bikes, programs and education to provide gyms
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`and studios with everything they need to offer great classes and expert instruction.
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`The Spinner Chrono® manufactured by Precor®
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`5
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`8.
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`Peloton is a fitness company founded in 2012 to exploit the indoor cycling market
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`that MDA created. The Peloton Bike, its first commercial product, was released in 2014. Like the
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`eSpinner® bike that MDA released four years earlier, the Peloton Bike features a touch-screen that
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`displays on-demand classes which provide the rider with instructor-led coaching, including
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`instructions to adjust pedaling resistance and vary cadence and riding positions, thereby simulating
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`an instructor-led exercise class in the rider’s home.
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`9.
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`The Peloton Bike and the recently released Bike+ (collectively, the “Peloton
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`Bikes”) incorporate MDA’s patented technology covering core features of a stationary exercise
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`bike designed to simulate an instructor-led class in the rider’s home, without the right or authority
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`to do so. Without permission from or compensation to MDA, Peloton has built a multi-billion
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`dollar business based in large part on MDA’s pioneering patented inventions in the indoor cycling
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`market that MDA founded over 25 years ago. MDA brings this action under 35 U.S.C. § 271 to
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`right these wrongs and remedy Peloton’s infringement of United States Patent Nos. 9,694,240 and
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`10,137,328.
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`THE PARTIES
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`10. MDA is a corporation organized and existing under the laws of the state of
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`California, having a principal place of business at 2111 Narcissus Court, Venice, CA 90291.
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`11.
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`Peloton is a corporation organized and existing under the laws of the state of
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`Delaware, having a principal place of business at 125 W. 25th Street, New York, NY 10001.
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`JURISDICTION AND VENUE
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`12.
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`This is an action for patent infringement arising under the patent laws of the United
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`States, 35 U.S.C. § 1, et seq. This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331
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`and 1338(a) because this is a civil action arising under the Patent Act.
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`13.
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`This Court has personal jurisdiction over Peloton. Peloton has continuous and
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`systematic business contacts with the State of Texas, including with the Eastern District of Texas.
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`Peloton, directly or through subsidiaries or intermediaries (including distributors, retailers, and
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`others), conducts its business extensively throughout Texas, by shipping, distributing, offering for
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`sale, selling, and advertising (including through interactive web pages) the Peloton Bikes in the
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`State of Texas and the Eastern District of Texas.
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`14.
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`Peloton has been registered to do business in Texas since at least May 27, 2015,
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`has been assigned Texas Taxpayer No. 32057346739, and has a Texas registered agent,
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`Corporation Service Company d/b/a CSC-Lawyers Incorporating Service Company, located at 211
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`East 7th Street, Suite 620, Austin, TX 78701.
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`15.
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`Peloton, directly and through subsidiaries or intermediaries (including distributors,
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`retailers, and others), has purposefully and voluntarily placed its infringing Peloton Bikes into this
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`District and into the stream of commerce with the intention and expectation that the Peloton Bikes
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`will be purchased for use in this District. Peloton has offered and sold and continues to offer and
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`sell the Peloton Bikes for delivery and use in this District.
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`16.
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`Venue is proper in this Court under 28 U.S.C. § 1400(b) because Peloton has a
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`regular and established place of business in this District and has committed acts of infringement
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`in this District.
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`17.
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`Peloton occupies permanent, physical spaces within this District from which it
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`conducts business. One such space is its campus of over 27,000 square feet located at 6600 Chase
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`Oaks Blvd., Plano, Texas 75023.
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`Peloton campus located
`at 6600 Chase Oaks
`Blvd., Plano, Texas
`75023
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`18.
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`Another example of a permanent, physical space occupied by Peloton within this
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`District is its showroom located at 7500 Windrose Avenue, Plano, Texas 75024. Peloton provides
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`personalized demonstrations of, and sells and offers to sell, the Peloton Bikes at this location.
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`Peloton showroom at
`7500 Windrose Avenue,
`Plano, Texas 75024
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`19.
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`Peloton has committed acts of infringement in this District by offering for sale and
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`selling the Peloton Bikes in this District, including from the Peloton showroom located in Plano,
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`Texas. Pursuant to these sales, Peloton has delivered (either itself or through authorized agents)
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`Peloton Bikes for use in this District.
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`20.
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`Peloton has also induced infringement in this District by providing manuals and
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`documentation to owners and/or users of Peloton Bikes located in this District that teach them to
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`use, and with the intent that they use, the Peloton Bikes in an infringing manner. Peloton has further
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`induced infringement in this District by providing software to owners and/or users of Peloton Bikes
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`located in this District that enable them to use, and with the intent that they use, the Peloton Bikes
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`in an infringing manner.
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`COUNT I
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`(Infringement of U.S. Patent No. 9,694,240)
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`21. MDA incorporates herein by reference paragraphs 1 through 20 above as if set forth
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`in full.
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`22.
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`On July 4, 2017, the United States Patent and Trademark Office duly issued U.S.
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`Patent No. 9,694,240, entitled “PROGRAMMED EXERCISE BICYCLE WITH COMPUTER
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`AIDED GUIDANCE” (the “’240 patent”). A true and correct copy of the ’240 patent is attached
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`hereto as Exhibit A. The ’240 patent is directed to a stationary exercise bike along with a display
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`that provides instructions to lead a rider through an exercise program.
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`23.
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`The ’240 patent has been in full force and effect since its issuance. MDA owns by
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`assignment the entire right, title, and interest in and to the ’240 patent, including the right to seek
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`damages for past, current, and future infringement thereof.
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`24.
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`Peloton began selling and offering to sell the Peloton Bike in or about January 2014
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`and the Peloton Bike+ in or about September 2020.
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`25.
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`Peloton has infringed and continues to infringe the ’240 patent, including at least
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`claim 1, pursuant to 35 U.S.C. § 271(a), literally or under the doctrine of equivalents, by making,
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`using, offering to sell, selling, exporting from, and/or importing into the United States the Peloton
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`Bikes, without authority or license.
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`26.
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`Peloton indirectly infringes the ’240 patent, including at least claim 1, pursuant to
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`35 U.S.C. § 271(b), by (among other things) and with specific intent or willful blindness, actively
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`aiding and abetting infringement by others, such as Peloton’s partners, customers and end-users,
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`in this District and elsewhere in the United States. For example, Peloton’s partners, customers and
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`end-users directly infringe through their use of the inventions claimed in the ’240 patent. Peloton
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`induces this direct infringement through its affirmative acts of manufacturing, selling, distributing,
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`and/or otherwise making available the Peloton Bikes, and providing instructions, documentation,
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`and other information to customers and end-users instructing them to use the Peloton Bikes in an
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`infringing manner, including (i) instruction, technical support and services, (ii) training, marketing,
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`product manuals, and advertisements, and (iii) software and mobile applications providing the
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`foregoing and enabling customers and end-users to use the Peloton Bikes in an infringing manner.
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`As a result of Peloton’s inducement, Peloton’s partners, customers and end-users use the Peloton
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`Bikes in the way that Peloton intends and that directly infringes the ’240 patent. Peloton has known
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`of the ’240 patent, and that the Peloton Bikes infringe the ’240 patent, or has been willfully blind
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`to such infringement, since at least the filing of this Complaint. Despite this knowledge of the ’240
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`patent and that the Peloton Bikes infringe the ’240 patent, Peloton has continued to perform these
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`affirmative acts with the intent, or willful blindness, that the induced acts directly infringe the ’240
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`patent.
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`27.
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`Peloton also indirectly infringes the ’240 patent, including at least claim 1, pursuant
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`to 35 U.S.C. § 271(c), by contributing to direct infringement committed by others, such as
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`customers and end-users, in this District and elsewhere in the United States. Peloton’s affirmative
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`acts of selling and offering to sell, in this District and elsewhere in the United States, the Peloton
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`Bikes and causing the Peloton Bikes to be manufactured, used, sold, and offered for sale, contribute
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`to Peloton’s customers’ and end-users’ use of the Peloton Bikes, such that the ’240 patent is
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`directly infringed. The Peloton Bikes are a material part of the invention of the ’240 patent, are not
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`a staple article or commodity of commerce, have no substantial non-infringing use, and are known
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`by Peloton to be especially made or adapted for use in the infringement of the ’240 patent. Peloton
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`has known of the ’240 patent, and that the Peloton Bikes infringe the ’240 patent, or has been
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`willfully blind to such infringement, since at least the filing of this Complaint. Despite this
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`knowledge of the ’240 patent and that the Peloton Bikes infringe the ’240 patent, Peloton has
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`continued to perform these affirmative acts with knowledge of the ’240 patent and with intent, or
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`willful blindness, that they cause the direct infringement of the ’240 patent.
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`28.
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`Claim 1 of the ’240 patent is reproduced below with the addition of labels [a], [b],
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`[c], [d], [e], [f], and [g] corresponding to limitations of the claim.
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`1.
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`An exercise bike, comprising:
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`[a]
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`a frame that is configured to allow a rider to ride in sitting and
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`standing positions;
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`[b]
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`a direct drive mechanism that couples a pedal assembly and a
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`flywheel and that facilitates a smooth transition between sitting and
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`standing positions;
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`[c]
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`a set of handlebars that is coupled to the frame and that provides the
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`rider with at least one hand position;
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`[d]
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`a mechanism that provides resistance to the flywheel and that is
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`manually adjustable by the rider to vary the pedaling resistance;
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`[e]
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`a computer that is coupled to the stationary bike, that is configured
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`to connect with the internet or other computer network to access a collection
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`of exercise routines, wherein the exercise routines include instructions
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`regarding cadence, pedaling resistance, and riding positions including
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`sitting and standing positions, and that stores power exerted by the rider;
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`[f]
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`a display that is coupled to the computer, that displays an exercise
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`routine from the collection of exercise routines so that the rider is provided
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`with instructions for the rider to manually adjust pedaling resistance, and
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`instructions for the rider to vary cadence and riding positions including
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`sitting and standing positions, thereby simulating an instructor-led exercise
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`class, and that displays power exerted by the rider; and
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`[g]
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`an input device that is coupled to the computer and that enables the
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`rider to input data into the computer.
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`29.
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`The Peloton Bikes embody each and every limitation of at least claim 1 of the ’240
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`patent, literally or under the doctrine of equivalents, as described in the non-limiting examples set
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`forth below from the Peloton Bike. The Peloton Bike+ has the same features described below and
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`embodies each and every limitation of at least claim 1 of the ’240 patent for the same reasons as
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`does the Peloton Bike. These non-limiting examples are preliminary and are not intended to limit
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`MDA’s right to modify these non-limiting examples or allege that other aspects of the Peloton
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`Bikes infringe the identified claim, or any other claims, of the ’240 patent.
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`“1.
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`30.
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`An exercise bike, comprising:”
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`The Peloton Bike is an exercise bike as shown in the image below. (The excerpted
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`images in this Complaint are from the Peloton Bike Manual, Peloton Support + Bike + Getting
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`Started With Your Bike
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`(2018), available at https://support.onepeloton.com/hc/en-
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`us/articles/218134663-Peloton-Manuals.)
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`“[a]
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`a frame that is configured to allow a rider to ride in sitting and standing
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`positions;”
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`31.
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`As annotated in red in the image below, the Peloton Bike includes a frame that is
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`configured to allow a rider to ride in sitting and standing positions.
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`“[b]
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`a direct drive mechanism that couples a pedal assembly and a flywheel and
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`that facilitates a smooth transition between sitting and standing positions;”
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`32.
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`As annotated in red in the image below, the Peloton Bike includes a direct drive
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`mechanism that couples pedals to a flywheel.
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`33.
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`The direct drive mechanism facilitates a smooth transition between siting and
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`standing positions.
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`“[c]
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`a set of handlebars that is coupled to the frame and that provides the rider
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`with at least one hand position;”
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`34.
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`As annotated in red in the image below, the Peloton Bike includes handlebars that
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`are coupled to the frame and provide the rider with at least one hand position.
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`“[d]
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`a mechanism that provides resistance to the flywheel and that is manually
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`adjustable by the rider to vary the pedaling resistance;”
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`35.
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`As annotated in red in the image below, the Peloton Bike includes an adjustable
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`mechanism that provides pedaling resistance.
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`“[e]
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`a computer that is coupled to the stationary bike, that is configured to connect
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`with the internet or other computer network to access a collection of exercise routines,
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`wherein the exercise routines include instructions regarding cadence, pedaling
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`resistance, and riding positions including sitting and standing positions, and that
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`stores power exerted by the rider;”
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`36.
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`As set forth in the excerpt below, a computer is coupled to the Peloton Bike.
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`37.
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`As set forth in the excerpt below, the computer is configured to connect with the
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`internet or other computer network.
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`38.
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`As set forth in the excerpt below, connection to the internet or other computer
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`network allows the rider to access “UP TO 14 DAILY LIVE RIDES” and “4,000+ ON-DEMAND
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`RIDES.” (This excerpt is available on Peloton’s website. See “Ride Now With Peloton,” available
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`at https://www2.onepeloton.com/bike/classes.)
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`During a ride the instructor instructs the rider to vary cadence, pedaling resistance
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`39.
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`and riding positions, including siting and standing positions.
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`40.
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`After a ride, a user can look at the user’s ride history on the Peloton Bike or using
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`the Peloton phone app or website and see the user’s power and position on the leaderboard for
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`each ride.
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`“[f]
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`a display that is coupled to the computer, that displays an exercise routine
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`from the collection of exercise routines so that the rider is provided with instructions
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`for the rider to manually adjust pedaling resistance, and instructions for the rider to
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`vary cadence and riding positions including sitting and standing positions, thereby
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`simulating an instructor-led exercise class, and that displays power exerted by the
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`rider; and”
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`41.
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`As annotated in red in the image below, the Peloton Bike includes a display that is
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`coupled to the computer.
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`42.
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`The display displays an exercise routine from the collection of rides so that the rider
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`is provided with instructions for the rider to manually adjust pedaling resistance, and instructions
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`for the rider to vary cadence and riding positions including sitting and standing positions, thereby
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`simulating an instructor-led exercise class.
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`43.
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`As annotated in red in the image below, the display displays the power exerted by
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`the rider.
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`“[g]
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`an input device that is coupled to the computer and that enables the rider to
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`input data into the computer.”
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`44.
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`As shown in the excerpt below, the Peloton Bike includes a touch screen that
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`enables the rider to input data into the computer.
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`45. MDA has satisfied all statutory obligations required to collect pre-filing damages
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`for the full period allowed by law for the infringement of the ’240 patent.
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`Case 2:20-cv-00382-JRG Document 1 Filed 12/14/20 Page 22 of 36 PageID #: 22
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`COUNT II
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`(Infringement of U.S. Patent No. 10,137,328)
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`46. MDA incorporates herein by reference paragraphs 1 through 19 above as if set forth
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`in full.
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`47.
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`On November 27, 2018, the United States Patent and Trademark Office duly issued
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`U.S. Patent No. 10,137,328, entitled “PROGRAMMED EXERCISE BICYCLE WITH
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`COMPUTER AIDED GUIDANCE” (the “’328 patent”). A true and correct copy of the ’328 patent
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`is attached hereto as Exhibit B. The ’328 patent is directed to a stationary exercise bike along with
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`a display that provides instruction to lead a rider through an exercise program.
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`48.
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`The ’328 patent has been in full force and effect since its issuance. MDA owns by
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`assignment the entire right, title, and interest in and to the ’240 patent, including the right to seek
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`damages for past, current, and future infringement thereof.
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`49.
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`Peloton began selling and offering to sell the Peloton Bike in or about January 2014
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`and the Peloton Bike+ in or about September 2020.
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`50.
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`Peloton has infringed and continues to infringe the ’328 patent, including at least
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`claim 1, pursuant to 35 U.S.C. § 271(a), literally or under the doctrine of equivalents, by making,
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`using, offering to sell, selling, exporting from, and/or importing into the United States the Peloton
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`Bikes, without authority or license.
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`51.
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`Peloton indirectly infringes the ’328 patent, including at least claim 1, pursuant to
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`35 U.S.C. § 271(b), by (among other things) and with specific intent or willful blindness, actively
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`aiding and abetting infringement by others, such as Peloton’s partners, customers and end-users,
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`in this District and elsewhere in the United States. For example, Peloton’s partners, customers and
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`end-users directly infringe through their use of the inventions claimed in the ’328 patent. Peloton
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`Case 2:20-cv-00382-JRG Document 1 Filed 12/14/20 Page 23 of 36 PageID #: 23
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`induces this direct infringement through its affirmative acts of manufacturing, selling, distributing,
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`and/or otherwise making available the Peloton Bikes, and providing instructions, documentation,
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`and other information to customers and end-users instructing them to use the Peloton Bikes in an
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`infringing manner, including (i) instruction, technical support and services, (ii) training, marketing,
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`product manuals, and advertisements, and (iii) software and mobile applications providing the
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`foregoing and enabling customers and end-users to use the Peloton Bikes in an infringing manner.
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`As a result of Peloton’s inducement, Peloton’s partners, customers and end-users use the Peloton
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`Bikes in the way that Peloton intends and that directly infringes the ’328 patent. Peloton has known
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`of the ’328 patent, and that the Peloton Bikes infringe the ’328 patent, or has been willfully blind
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`to such infringement, since at least the filing of this Complaint. Despite this knowledge of the ’328
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`patent and that the Peloton Bikes infringe the ’328 patent, Peloton has continued to perform these
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`affirmative acts with the intent, or willful blindness, that the induced acts directly infringe the ’328
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`patent.
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`52.
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`Peloton also indirectly infringes the ’328 patent, including at least claim 1, pursuant
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`to 35 U.S.C. § 271(c), by contributing to direct infringement committed by others, such as
`
`customers and end-users, in this District and elsewhere in the United States. Peloton’s affirmative
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`acts of selling and offering to sell, in this District and elsewhere in the United States, the Peloton
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`Bikes and causing the Peloton Bikes to be manufactured, used, sold, and offered for sale, contribute
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`to Peloton’s customers’ and end-users’ use of the Peloton Bikes, such that the ’328 patent is
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`directly infringed. The Peloton Bikes are a material part of the invention of the ’328 patent, are not
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`a staple article or commodity of commerce, have no substantial non-infringing use, and are known
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`by Peloton to be especially made or adapted for use in the infringement of the ’328 patent. Peloton
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`has known of the ’328 patent, and that the Peloton Bikes infringe the ’328 patent, or has been
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`Case 2:20-cv-00382-JRG Document 1 Filed 12/14/20 Page 24 of 36 PageID #: 24
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`willfully blind to such infringement, since at least the filing of this Complaint. Despite this
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`knowledge of the ’328 patent and that the Peloton Bikes infringe the ’328 patent, Peloton has
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`continued to perform these affirmative acts with knowledge of the ’328 patent and with intent, or
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`willful blindness, that they cause the direct infringement of the ’328 patent.
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`53.
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`Claim 1 of the ’328 patent is reproduced below with the addition of labels [a], [b],
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`[c], [d], [e], [f], [g], and [h] corresponding to limitations of the claim.
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`1.
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`A stationary bike, comprising:
`
`[a]
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`a frame that is configured to allow a rider to ride in sitting and
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`standing positions;
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`[b]
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`a direct drive mechanism that couples a pedal assembly and a
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`flywheel and that facilitates a smooth transition between sitting and
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`standing positions;
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`[c]
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`a set of handlebars that is coupled to the frame and that provides the
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`rider with at least one hand position;
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`[d]
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`a mechanism that provides resistance to the flywheel and that is
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`manually adjustable by the rider to vary the pedaling resistance;
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`[e]
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`a computer that is coupled to the stationary bike, that is configured
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`to connect with the internet or other computer network to access a collection
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`of exercise routines, wherein the exercise routines include instructions
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`regarding cadence, pedaling resistance, and riding position including sitting
`
`and standing positions;
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`[f]
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`wherein the computer is configured to measure the pedaling
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`resistance and the rider's cadence and is configured to calculate power
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`Case 2:20-cv-00382-JRG Document 1 Filed 12/14/20 Page 25 of 36 PageID #: 25
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`exerted by the rider based on the pedaling resistance and the rider's cadence;
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`and
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`[g]
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`a display that is coupled to the computer, that displays an exercise
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`routine from the collection of exercise routines so that the rider is provided
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`with instructions for the rider to manually adjust pedaling resistance, and
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`instructions for the rider to vary cadence and riding positions including
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`sitting and standing positions;
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`[h]
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`wherein the display displays cadence, pedaling resistance and the
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`power exerted by the rider.
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`54.
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`The Peloton Bikes embody each and every limitation of at least claim 1 of the ’328
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`patent, literally or under the doctrine of equivalents, as described in the non-limiting examples set
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`forth below from the Peloton Bike. The Peloton Bike+ has the same features described below and
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`embodies each and every limitation of at least claim 1 of the ’240 patent for the same reasons as
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`does the Peloton Bike. These non-limiting examples are preliminary and are not intended to limit
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`MDA’s right to modify these non-limiting examples or allege that other aspects of the Bike
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`infringe the identified claims, or any other claims, of the ’328 patent.
`
`“1.
`
`55.
`
`A stationary bike, comprising”
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`The Peloton Bike is a stationary bike as shown in the image below.
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`
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`Case 2:20-cv-00382-JRG Document 1 Filed 12/14/20 Page 26 of 36 PageID #: 26
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`“[a]
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`a frame that is configured to allow a rider to ride in sitting and standing
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`
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`positions;”
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`56.
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`As annotated in red in the image below, the Peloton Bike includes a frame that is
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`configured to allow a rider to ride in sitting and standing positions.
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`Case 2:20-cv-00382-JRG Document 1 Filed 12/14/20 Page 27 of 36 PageID #: 27
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`“[b]
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`a direct drive mechanism that couples a pedal assembly and a flywheel and
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`that facilitates a smooth transition between sitting and standing positions;”
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`57.
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`As annotated in red in the image below, the Peloton Bike includes a direct drive
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`mechanism that couples pe