Tonal Systems Inc v. Oxefit Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Tonal Systems, Inc. (Delaware)
  • Defendant: OxeFit, Inc. (Texas)
  • Plaintiff's Counsel: Morrison & Foerster LLP
• Case Identification: 2:26-cv-00691, E.D. Tex., 08/13/2026
• Venue Allegations: Venue is alleged to be proper in the Eastern District of Texas because Defendant OxeFit, Inc. has its principal place of business and headquarters in Plano, Texas, within the district, and a majority of its employees are based in Texas.
• Core Dispute: Plaintiff alleges that Defendant's XS1 and XP1 digital strength training systems infringe four patents related to dynamic resistance, repetition counting, and safety features for smart exercise equipment.
• Technical Context: The lawsuit concerns the smart home gym market, where companies compete to replace traditional physical weights with digitally controlled electromagnetic resistance systems.
• Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of the '112 and '351 patents on May 28, 2026. Subsequently, on July 27, 2026, Defendant filed a declaratory judgment action for non-infringement and invalidity in the District of Delaware concerning a different, non-asserted patent from Plaintiff's portfolio, but did not seek judgment on any of the patents asserted in this action.

Case Timeline

Date	Event
2015-01-01	Tonal founded
2016-07-25	Priority Date for '112, '351, '687 Patents
2017-07-20	'112 Patent filed
2019-01-01	OxeFit founded
2020-05-26	'112 Patent issued
2021-02-18	'351 and '687 Patents filed
2022-03-29	'351 Patent issued
2022-07-19	'687 Patent issued
2024-05-09	'612 Patent filed (Priority Date)
2026-02-10	'612 Patent issued
2026-05-28	Tonal sends notice letter to OxeFit for '112 and '351 Patents
2026-07-27	OxeFit files declaratory judgment action in Delaware on a non-asserted patent
2026-08-13	Complaint filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 10,661,112 - "Digital Strength Training"

• Issued: May 26, 2020.

The Invention Explained

• Problem Addressed: The patent's background section describes the difficulty of achieving complex and asymmetric training protocols (e.g., eccentric loading) with traditional physical weights, which are limited by the laws of physics and cannot spontaneously change resistance levels '112 Patent, col. 3:45-54
• The Patented Solution: The invention proposes a digital strength trainer using an electric motor coupled to a cable and actuator, where a "filter" (a software-based control algorithm) dynamically adjusts the motor's torque '112 Patent, abstract This system receives information about the actuator's position and uses the filter to implement a "strength curve" relative to that position, allowing for precise control over the resistance felt by the user throughout a movement '112 Patent, col. 7:31-44 '112 Patent, FIG. 1A
• Technical Importance: This technology enabled the development of compact, digitally-controlled exercise machines capable of simulating and improving upon traditional weight training by offering dynamic resistance modes Compl. ¶14

Key Claims at a Glance

• The complaint asserts at least independent claim 1 Compl. ¶36
• The essential elements of claim 1 include:
  • An exercise machine with an actuator, a "pancake style" motor, a cable, and a motor controller.
  • A filter configured to receive position information of the actuator.
  • The filter provides input to the motor controller to adjust torque and implement a strength curve.
  • Implementing the strength curve comprises comparing the current relative position between the motor and actuator.
  • It also comprises sending pulses to the motor to adjust its position based on that comparison.
• The complaint reserves the right to assert additional claims Compl. ¶33

U.S. Patent No. 11,285,351 - "Digital Strength Training"

• Issued: March 29, 2022.

The Invention Explained

• Problem Addressed: The patent addresses the challenge of accurately counting exercise repetitions, particularly distinguishing between full, valid movements and partial, incomplete ones, which is crucial for effective training but difficult when a user is fatigued Compl. ¶16 '351 Patent, col. 24:1-20
• The Patented Solution: The invention uses a processor to analyze a series of position updates from the exercise cable's motion. It detects a change in direction but ignores it if the movement does not comply with a "threshold position." A repetition is only counted as complete when a second change in direction does comply with the threshold, effectively filtering out partial reps '351 Patent, claim 1
• Technical Importance: This system provides for more intelligent and accurate workout tracking by ensuring only quality repetitions are counted, making training more precise and effective Compl. ¶16

Key Claims at a Glance

• The complaint asserts at least independent claim 1 Compl. ¶70
• The essential elements of claim 1 include:
  • An exercise machine with an actuator, motor, cable, and a processor.
  • The processor is configured to receive a series of position updates from the cable's motion.
  • It detects a first change in the direction of travel.
  • It ignores the first change if it does not comply with a "threshold position."
  • It determines a repetition is complete only when a second detected change in direction does comply with the threshold position.
• The complaint reserves the right to assert additional claims Compl. ¶67

U.S. Patent No. 11,389,687 - "Digital Strength Training"

• Issued: July 19, 2022.

Technology Synopsis

The '687 Patent describes a "virtual spotter" safety feature. The invention uses a processor to detect when a user is struggling by determining the "persistence" of a low-velocity, high-tension state for a pre-determined time. In response, it reduces the motor's torque, allowing the user to safely complete the repetition '687 Patent, claim 1 Compl. ¶15

Asserted Claims

At least independent claim 1 Compl. ¶99

Accused Features

The complaint alleges that OxeFit's "virtual spotter" feature infringes the '687 Patent Compl. ¶¶114-119

U.S. Patent No. 12,544,612 - "Enhancing Concentric Load Experienced By User"

• Issued: February 10, 2026.

Technology Synopsis

The '612 Patent discloses a method for enhancing the concentric (outward) phase of an exercise. It describes a torque controller that, during the outward movement, increases the amount of torque requested from the motor based at least in part on the actuator's velocity, making the exercise more challenging as the user moves faster '612 Patent, claim 1 Compl. ¶131

Asserted Claims

At least independent claim 1 Compl. ¶126

Accused Features

The complaint alleges that OxeFit's "Reactive" weight setting infringes the '612 Patent by increasing or decreasing the load based on the user's concentric velocity Compl. ¶132

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are the OxeFit XS1 and XP1 digital strength training machines Compl. ¶1

Functionality and Market Context

The complaint alleges that the OxeFit XS1 and XP1 are "All-in-One" smart home gyms that use digital weight systems with electric motors to provide resistance Compl. ¶¶19, 21 They are alleged to include features purportedly similar to Tonal's, such as adaptive weight modes (e.g., "Chains," "Burnout," "Reactive"), interactive video content, and safety features like a "Virtual Spotter" Compl. ¶¶19, 21 The complaint provides an image of the compact, "pancake style" motors allegedly used in the accused products to achieve a low-profile design Compl. ¶42, p. 17

IV. Analysis of Infringement Allegations

10,661,112 Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
an actuator	The accused products include actuators such as hand grips, a barbell, and a hex bar that a user can use to move the cables.	¶40	col. 5:35-39
a motor, wherein the motor is of pancake style and the machine is of low relative depth	The XS1 and XP1 allegedly utilize two compact, pancake style motors that are greater in diameter and lower in depth.	¶42	col. 15:58-64
a cable coupled between the actuator and the motor	The accused products include a cable coupled to the actuator on one end and to the motor on the other end.	¶44	col. 5:31-35
a motor controller coupled to the motor	The motors are part of a system with digital controls effectuated through one or more controller circuits coupled to the motors.	¶46	col. 5:27-30
a filter coupled to the motor controller, configured to: receive an information related to the position of the actuator	The accused products incorporate a filter that receives information related to the actuator's position to determine the user's range of motion.	¶52	col. 7:51-55
and provide an input to the motor controller to adjust torque on the motor such that a strength curve is implemented relative to the position of the actuator, comprising to:	The filter provides input to the motor controller to adjust torque when a user chooses an advanced resistance setting like "chains," implementing a strength curve dependent on actuator position.	¶54	col. 7:31-44
compare a current relative position between the motor and the actuator	The accused products allow for this comparison by providing a range of motion visualization on the user interface.	¶¶56-57	col. 13:30-43
and send an appropriate number of pulses to the motor to adjust a position of the motor based on the current relative position between the motor and the actuator.	The filters allegedly instruct the controller circuit to send pulses to the brushless motors to adjust their position and generate the appropriate resistance.	¶59	col. 13:39-43

• Identified Points of Contention:
  • Scope Question: A potential dispute may arise over the term "pancake style." The complaint alleges OxeFit's motors are "greater in diameter and lower in depth" (Compl. ¶42), which may raise the question of whether this general description meets the specific definition, if any, required by the patent.
  • Technical Question: The complaint alleges the accused products use "brushless motors" (Compl. ¶59), while the patent describes the "send[ing] an appropriate number of pulses" limitation in the context of stepper motors '112 Patent, col. 13:56-61 This suggests a possible mismatch in technical operation and raises the question of whether a torque-controlled brushless motor can be said to "send... pulses... to adjust a position" in the manner claimed.

11,285,351 Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
an actuator; a motor; a cable coupled between the actuator and the motor	The accused products include an actuator, motor, and coupled cable.	¶¶73-78	col. 5:31-39
and a processor configured to: receive a series of position updates...	The processor in the accused products tracks the user's range of motion and displays it visually.	¶¶79-82	col. 24:21-23
based at least in part on an evaluation of the series of position updates, detect a first change in direction of travel	The functionality for tracking repetitions requires the processor to detect a first change in the direction of travel to know when a repetition has begun.	¶84	col. 24:23-25
ignore the first change in direction of travel based at least in part on a determination that the first change in direction does not comply with a threshold position	The accused products allegedly do not count a movement as a completed repetition if the user fails to complete the full range of motion. An image in the complaint shows the repetition counter remaining at 4 after a failed attempt at a fifth rep (Compl. ¶¶85-86, p. 35).	¶¶85-86	col. 24:26-30
and determine that a repetition of a movement has been completed based at least in part on a determination that a second detected change in direction complies with the threshold position.	The accused products are alleged to count completed repetitions when the user performs a sufficient portion of both the concentric and eccentric phases of the movement.	¶¶87-88	col. 24:30-34

• Identified Points of Contention:
  • Scope Question: The central dispute will likely focus on the meaning of "threshold position." The infringement allegation rests on the idea that OxeFit's method for distinguishing full reps from partial reps is equivalent to the patent's claimed method of checking for compliance with a "threshold position."
  • Technical Question: What evidence does the complaint provide that the accused product's rep-counting algorithm performs the specific logical steps of detecting a first direction change, determining non-compliance with a "threshold position," ignoring it, and then determining compliance on a second direction change? The complaint's visual evidence shows the outcome (an uncounted partial rep) but not the underlying process Compl. ¶86, p. 35

V. Key Claim Terms for Construction

For the '112 Patent

• The Term: "pancake style"
• Context and Importance: This term appears in the independent claim and is not a standard technical term, making its definition critical. Infringement may depend on whether OxeFit's motors, described as "compact" and having a high diameter-to-depth ratio (Compl. ¶42), fall within the scope of "pancake style."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes pancake style motors as being "higher in diameter and lower in depth than most motors," a relatively general physical description that could encompass a wide range of compact motors '112 Patent, col. 15:58-61
  • Evidence for a Narrower Interpretation: The same section links "pancake style" motors to "hub motors" and "out-runner" configurations '112 Patent, col. 15:50-58 A party could argue these specific configurations narrow the meaning of the term beyond just general dimensions.

For the '351 Patent

• The Term: "threshold position"
• Context and Importance: This term is the core of the claimed method for distinguishing valid repetitions from partial ones. Practitioners may focus on this term because the infringement case depends on whether the logic in OxeFit's devices for ignoring failed reps constitutes a determination that a movement "does not comply with a threshold position."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself does not define what constitutes a "threshold position," leaving it open to cover any positional condition used to validate or invalidate a repetition '351 Patent, claim 1
  • Evidence for a Narrower Interpretation: The detailed description includes sample pseudo-code that uses specific variables like 'g_ReHighThreshold' and 'g_ReLowThreshold' to implement hysteresis logic '351 Patent, col. 25:11-16 A party could argue this detailed implementation informs a narrower construction of what qualifies as a "threshold position."

VI. Other Allegations

• Indirect Infringement: The complaint alleges that OxeFit actively induces infringement by "distributing instructions on its website, on Amazon, on its YouTube channel, and in its user manuals" that advise and direct customers on how to use the infringing features of the accused products Compl. ¶24 Compl. ¶35 Compl. ¶69
• Willful Infringement: The willfulness allegations are based on pre-suit knowledge. The complaint states that Tonal sent OxeFit a notice letter on May 28, 2026, specifically identifying the '112 and '351 patents Compl. ¶30 Compl. ¶34 Compl. ¶60 Compl. ¶68 The complaint further alleges that OxeFit subsequently filed a declaratory judgment action on a different patent but "did not seek a judgment of non-infringement or invalidity on any of the Asserted Patents," which may be presented as evidence of deliberate disregard of Tonal's rights Compl. ¶31 Compl. ¶61

VII. Analyst's Conclusion: Key Questions for the Case

• A core issue will be one of technical and definitional scope: For the '112 patent, can the claim language "send... pulses... to adjust a position," which is described in the context of stepper motors, be construed to read on the accused torque-controlled brushless motor systems? Similarly, can the non-technical term "pancake style" be defined to encompass the accused motors?
• A key evidentiary question will be one of operational equivalence: For the '351, '687, and '612 patents, does the software in OxeFit's products perform the specific logical steps required by the claims-such as checking for compliance with a "threshold position" or determining "persistence" of a low-velocity/high-tension state-or do the accused "repetition detection" and "virtual spotter" features operate on fundamentally different principles, despite having similar names?
• The case will also present a significant question of willfulness: Did OxeFit's decision to file a declaratory judgment action on a non-asserted patent, after receiving explicit notice of the '112 and '351 patents, constitute objective recklessness and a deliberate disregard of a known risk of infringement, potentially justifying enhanced damages?