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TMCase: World Champ Tech. LLC v. Peloton Interactive, Inc., 2024 U.S. Dist. LEXIS 27975
- 06 June, 2024
- Nyall Engfield
World Champ Tech. LLC v. Peloton Interactive, Inc., 2024 U.S. Dist. LEXIS 27975 | United States District Court for the Northern District of California, San Francisco Division | Feb 16, 2024 |
Key Legal Holdings
- The defendant was entitled to summary judgment because there was no likelihood of confusion between its "Peloton Bike+" product and the plaintiff's "Bike+" app.
- The plaintiff's "Bike+" mark was descriptive as a matter of law.
- The plaintiff's 2021 app was a bona fide commercial use of its mark.
Material Facts
- The plaintiff offered a cycling metric tracking app called "Bike+" starting in 2014.
- The plaintiff's app was not updated after 2016 but a new version was in development from 2017-2020.
- The defendant launched a stationary bike product called "Peloton Bike+" in September 2020.
- The plaintiff filed suit for trademark infringement in April 2021.
Controlling Law
The Lanham Act, 15 U.S.C. Sections 1114 and 1125(a), for the federal trademark claims. California state law for the state law claims.
Court Rationale
The plaintiff's mark was descriptive and weak. The plaintiff's app had very little strength for the defendant's product launch to overtake, so reverse confusion was unlikely despite some factors weighing in the plaintiff's favor.
Procedural Outcome
The court granted the defendant's motion for summary judgment and denied the plaintiff's motion as moot
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