World Champ Tech LLC v. Peloton Interactive, Inc.

CourtDistrict Court, N.D. California
DecidedFebruary 16, 2024
Docket3:21-cv-03202
StatusUnknown

This text of World Champ Tech LLC v. Peloton Interactive, Inc. (World Champ Tech LLC v. Peloton Interactive, Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
World Champ Tech LLC v. Peloton Interactive, Inc., (N.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 San Francisco Division 11 WORLD CHAMP TECH LLC, Case No. 21-cv-03202-LB

12 Plaintiff, ORDER GRANTING SUMMARY 13 v. JUDGMENT TO THE DEFENDANT

14 PELOTON INTERACTIVE, INC., Re: ECF Nos. 134, 135 15 Defendant. 16 17 INTRODUCTION 18 The plaintiff World Champ Tech, which offers a mobile-fitness app called “Bike+” and owns a 19 trademark registration for the same name, sued the defendant Peloton Interactive for trademark 20 infringement and other claims after the defendant launched a new line of interactive stationary 21 bicycles under the name “Peloton Bike+.” The defendant raised various affirmative defenses — 22 such as that the plaintiff abandoned its mark by not updating its app and by showing other signs of 23 inactivity — and counterclaimed for trademark cancellation due to abandonment and fraud on the 24 USPTO (in the form of misrepresentations about the continued operability of the app). The parties 25 each moved for summary judgment: the defendant contends that consumers are not likely to be 26 confused and the plaintiff cannot show damages, and the plaintiff contends that the defendants’ 27 affirmative defenses and counterclaims are not viable. The court grants the defendant’s motion for 1 STATEMENT 2 1. The Plaintiff and its Apps 3 The plaintiff is a fitness-technology company that was founded in 2012 by professional cyclist 4 || James Mattis and professional cyclist and Olympic windsurfer Ted Huang. Mr. Mattis is now the 5 || plaintiffs sole member. He developed the Biket+ app, which was first released in February 2014 6 || for the Apple iPhone and Pebble Watch. The 2014 app was a metric-tracking cycling app that was 7 || designed to “track speed, distance, altitude, and grade.” It also “allowed users to capture photos or 8 video along a ride, activate interval timers during a ride, and post details to Facebook, Twitter, or 9 || other services.” Mr. Mattis testified that the app was “more focused on outdoor activities” but was 10 || always “available for indoor bike riding.” The app name was displayed as “Bike+” on the iPhone 11 home screen and as “Bike+ [bike more]” on the Apple App Store, as follows: g — _ Bike+ [bike more] & € 13 : World Champ Tech & @ ‘tee? o

17 || The app was marketed through the Apple App Store, the plaintiff's website, social media

18 including Facebook advertising, and sponsorships and endorsements. ! 19 Mr. Mattis described the 2014 app’s lifecycle. The app, according to Mr. Mattis, “enjoyed 20 || moderate success in the early years after its release, producing tens of thousands of downloads and 21 some revenue” in the form of in-app subscriptions. Then some changes happened: for example, 22 || Mr. Huang left the company in late 2014, the Apple Watch was released in fall 2014 and achieved 23 commercial success, and downloads declined after a 2015 peak. By the end of 2016, Mr. Mattis 24 || “became convinced the company needed an alternative direction.” He then focused on developing 25 a new app dedicated to the Apple Watch. Facebook advertising for the 2014 app — which 26 27 ' Mattis Decl. — ECF No. 137-3 at 1-4 (4 1-12); Mattis Dep. — ECF No. 136-10 at 8 (p. 106:17-22); App Store Preview — ECF No. 136-9 at 2. Citations refer to material in the Electronic Case File (ECF); 28 pinpoint citations are to the ECF-generated page numbers at the top of documents.

1 required payment only “based on impressions or conversions to downloads” — continued until 2 2019. The app also remained available for download, including for Pebble Watch users; even 3 though the Pebble Watch was discontinued in late 2016, “there remains a loyal following among 4 the Pebble Watch community.” But the app was not updated after 2016 because Mr. Mattis 5 considered focusing on the new app to be the best use of his resources.2 6 The defendant also offered evidence about the plaintiff from this time period. Certain 2014 7 projections and comments by the plaintiff differed from what later happened.3 At his deposition, 8 Mr. Mattis testified that: it may have been in 2016 that he last funded Facebook advertising or 9 created a new Facebook ad; the plaintiff has removed the 2014 app from its website; the plaintiff 10 does not have data sufficient to indicate how many bike rides have been tracked using the app; Mr. 11 Mattis could not recall opening the 2014 app since 2019 (though he often works with the latest 12 unreleased build of the app); and Mr. Mattis doesn’t know from personal use how functional the 13 2014 app is (though he receives crash reports from the Apple App Store).4 Also, by the end of 14 2016, the plaintiff had not paid taxes since 2015 and its certificate of incorporation was therefore 15 suspended.5 (This changed after the defendant launched its Bike+ product in 2020, as discussed 16 below.) 17 Mr. Mattis continued developing a new version of the Bike+ app from 2017 until 2020, writing 18 “over 2.4 million lines of code,” or about 1,500 lines per day. Apple announced new machine- 19 learning tools in June 2017 and he sought to use them to create an “on-device coaching system” 20 featuring “fatigue detection.” He “spent substantial amounts of time coding and testing this 21 innovation and applying for a patent . . . that has been since implemented in the Bike+ app.” He 22 started collecting real-world test data in August 2018. Around June 2019, he was nearing 23 completion of a new app, but Apple announced a new Apple Watch operating system that enabled 24

25 2 Mattis Decl. – ECF No. 137-3 at 3 (¶ 8), 4–5 (¶¶ 14–15), 6 (¶ 22). 26 3 Def.’s Opp’n – ECF No. 147-2 at 12 (citing evidence under seal). 27 4 Mattis Dep. – ECF No. 148-3 at 21 (p. 192:13–15), 30–32 (pp. 254:9–256:5), 37–38 (pp. 299:15– 300:25), 40–42 (pp. 328:3–330:9). 1 apps to run independently of a companion iPhone. This required a change in development for Mr. 2 Mattis. He again neared completion by late 2019, but in early 2020 Apple released “StoreKit for 3 Watch apps,” which “would at least theoretically permit World Champ Tech to alter its distribution 4 model to provide for an in app coaching feature for which subscription fees could be charged.” Mr. 5 Mattis began incorporating StoreKit and then “the COVID pandemic struck, impacting 6 development productivity.” He made certain other source-code edits in February 2020. As he 7 prepared for final testing in mid-July 2020, Apple released a new operating system that introduced a 8 bug; on September 2, 2020, he reported this bug to Apple. Another operating-system release 9 occurred in November 2020, and after an inquiry from Mr. Mattis, Apple confirmed on December 10 3, 2020 that the bug was fixed. Mr. Mattis completed final testing and submitted the new Bike+ app 11 to Apple for review on December 21, 2020. The new app then launched in January 2021.6 12 Aside from developing the new app, Mr. Mattis declares that the plaintiff engaged in other 13 commercial activities during the period from 2016 to 2020. This included (1) “[w]ebsite 14 promotion of the app,” (2) Facebook accounts and advertising campaigns until 2019, (3) 15 “agreement to the Apple Developer Program License Agreement and payment of the required, 16 annual $99 developer license fee,” (4) agreement to “the Apple Paid Applications Agreement, 17 which allowed [the plaintiff] to include paid features in [its] apps” and entailed periodic pricing 18 updates (for example, due to changes in currency-exchange rates), (5) “[c]ompliance with the 19 requirements for export under U.S. Department of Commerce policy for software using 20 encryption,” (6) membership in “the Apple App Store Small Business Program,” under which 21 “Apple provides marketing support to small developers, including presentation of apps in 22 responses to Internet search engines,” and (7) “[p]ayment of a $450 monthly service fee . . .

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Bluebook (online)
World Champ Tech LLC v. Peloton Interactive, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/world-champ-tech-llc-v-peloton-interactive-inc-cand-2024.