F45 fitness studio patent revoked by Delaware court

Law360 (November 23, 2022, 6:53 PM EST) – A federal court in Delaware has dismissed gym chain F45’s patent lawsuit against a rival after determining the fitness studio’s patent was invalid under Alice.

In an unsealed Nov. 17 opinion on Wednesday, Senior U.S. Circuit Judge William Bryson — sitting by designation — granted personal training company Body Fit Training USA Inc. summary judgment in the lawsuit brought by Australian company F45 Training Pty. ltd. concerning a patent on operating technology for fitness studios. Judge Bryson found that the asserted claims are invalid under the 2014 US Supreme Court decision in Alice vs. CLS Corp.which prevents abstract technology from being patented without an added inventive element.

According to the filing, “the problem for F45” is that the claimed patent claims “use only generic computing and networking components to implement the computing features of the claims.”

“Ultimately, F45 provided no evidence that the specific limitations found in the claims, or any combination of those limitations, add an inventive concept to the underlying abstract idea,” Judge Bryson said.

F45 filed suit in September 2020 and argued that its rival infringed U.S. Patent No. 10,143,890, issued by the U.S. Patent and Trademark Office in December 2018. This claimed patent relates to a computer system that enables ” Quick studio setup, flow direction, and station-specific exercise instructions. »

“The claimed systems and methods have resolved technical issues that make it easier to manage and set up the studio and provide studio users with a unique training experience guided by live and virtual instructors,” F45 added in its complaint.

Body Fit sought summary judgment in a sealed motion in September. Body Fit, headquartered in Australia, argued in a redacted version of this petition that the claimed technology is directed to ineligible subject matter.

“On a fully developed record, the evidence establishes that the ‘890 patent does not contain any inventive concept that could salvage its validity,” Body Fit said. “Rather, it’s part of a long line of ineligible business method patents that do little more than purport to ‘computerize’ conventional, well-known, long-standing processes.”

Judge Bryson said in the recent opinion that “the evidence establishes that the physical redistribution or rearrangement of exercise stations in fitness studios was well known and conventional at the time of the invention of the ‘890 patent”.

“Although preferred embodiments of F45 may include significant variations in the nature of exercise programs between periods, none of these features are specifically claimed, and therefore cannot provide the required inventive concept”, said Judge Bryson.

F45, Body Fit and attorneys for both parties did not immediately respond to requests for comment Wednesday.

F45 is represented by Rodger Dallery Smith II and Cameron P. Clark of Morris Nichols Arsht & Tunnell LLP and Abby L. Parsons, Angela C. Tarasi, James P. Brogan, Jonathan Weinberg, Noah Stid and Thomas J. Friel Jr. of King & Spalding LLP.

Body Fit is represented by Adam W. Poff, Alexis Stombaugh and Robert M. Vrana of Young Conaway Stargatt & Taylor LLP and Eugene L. Chang, Indranil Mukerji and Stephen A. Marshall of Willkie Farr & Gallagher LLP.

The suit is F45 Training Pty. ltd. v. Body Fit Training USA Inc., Case Number 1:20-cv-01194, in the United States District Court for the District of Delaware.

–Edited by Andrew Cohen.

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