Case 1:20-cv-00049 Document 1 Filed 01/07/20 USDC Colorado Page 1 of 7

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLORADO

Civil Action No.

Lightspeed Running & Rehabilitation System, LLC,

Plaintiff,

v.

Lever, LLC,

Defendant.

COMPLAINT FOR PATENT INFRINGEMENT

Plaintiff, Lightspeed Running & Rehabilitation Systems, LLC, for its complaint

against Defendant, Lever, LLC, states and alleges as follows:

THE PARTIES

1. Plaintiff Lightspeed Running & Rehabilitation Systems, LLC (hereinafter

“Plaintiff” or “Lightspeed”) is a Minnesota Limited Liability Company with its registered

office located at 707 Jasper Street, Cloquet, Minnesota, 55720. Lightspeed manufactures

and sells a bodyweight support system branded as the ‘LightSpeed Lift’, which is designed

to relieve impact forces and enhance natural movement and balance while running on a

treadmill.

2. Upon information and belief, Lever, LLC (hereinafter “Defendant” or

“Lever”) is a Colorado Limited Liability Company with its principal office address of 4450

-1-
 Case 1:20-cv-00049 Document 1 Filed 01/07/20 USDC Colorado Page 2 of 7

- 9th Street, Boulder CO 80304. Upon information and belief, Defendant makes and sells

a bodyweight support system designed to relieve impact forces and enhance natural

movement and balance while running on a treadmill.

JURISDICTION AND VENUE

3. This is an action for patent infringement under the patent laws of the United

States of America, specifically 35 U.S.C. §1 et seq., and particularly 35 U.S.C. § 271.

4. This Court has subject matter jurisdiction under 28 U.S.C. §1331 and 28

U.S.C. §1338(a).

5. The court has personal jurisdiction over Defendant because Defendant is

organized, domiciled and transacts business within Colorado, and has committed acts

within Colorado that caused injury to Plaintiff.

6. Venue is proper in this district under 28 U.S.C. §1391(c) because Defendant

is subject to personal jurisdiction in this district.

FACTUAL BACKGROUND

7. On June 21, 2016, U.S. Patent No. 9,370,680 entitled “Body Weight Support

System for Therapeutic and Physical Training, And Method of Use Thereof” (hereinafter

“the ’680 patent”) was duly and legally issued in the name of the inventors, Malcolm R.

Macaulay, Vernon R. Johnsen and Daniel J. Stein. A copy of the ’680 patent is attached

as Exhibit A to the Complaint.

-2-
 Case 1:20-cv-00049 Document 1 Filed 01/07/20 USDC Colorado Page 3 of 7

8. Plaintiff Lightspeed is the owner by assignment of the entire right, title, and

interest in the ’680 patent.

9. Plaintiff Lightspeed’s technological innovations in its ‘Lightspeed Lift’

bodyweight support system is protected by the ’680 patent.

10. Upon information and belief, Defendant is in the business of manufacturing

and selling fitness and rehabilitation products. In particular, Defendant manufactures and

sells a bodyweight support system under the trade names of “Lyte-V Package” and

“LEVER Package” (hereinafter “the Accused Product”).

11. On June 4, 2019, attorney for Plaintiff Lightspeed sent Defendant a letter

informing Lever of the existence of the ’680 patent, along with providing Lever with a

courtesy copy of the ’680 patent.

12. Upon information and belief, on or about July 1, 2019, after receiving the

aforementioned letter of June 4, Defendant began selling the Accused Product.

13. Upon information and belief, Defendant presently offers the Accused

Product for sale via the internet at the following URL:

https://www.leverrunning.com/product-page/lever-pro. A copy of webpage from the URL

is attached as Exhibit B to the Complaint.

14. On August 23, 2019, attorney for Plaintiff Lightspeed sent Defendant another

letter, this time informing Lever of its infringement of the ’680 patent in connection with

-3-
 Case 1:20-cv-00049 Document 1 Filed 01/07/20 USDC Colorado Page 4 of 7

the Accused Product, including a claim chart and another courtesy copy of the ’680 patent.

A copy of this Letter is attached as Exhibit C.

15. Defendant has had pre-suit knowledge of the ’680 patent since at least receipt

of Plaintiff Lightspeed’s letter dated June 4, 2019, and no later than receipt of the letter

dated August 23, 2019.

16. Since learning of the ’680 patent through either of the aforementioned letters,

Defendant has continued to infringe the ’680 patent.

17. As appropriate, Plaintiff Lightspeed has consistently marked its products

with the ’680 patent since its issuance.

COUNT I
INFRINGEMENT OF U.S. PAT. NO. 9,370,680
18. Plaintiff Lightspeed realleges and incorporates by this reference the

foregoing paragraphs as though fully set forth herein.

19. Defendant has been infringing the ’680 patent under 35 U.S.C. § 271(a) by

making, using or selling, without license or authority from Lightspeed, in this district and

elsewhere in the United States, the Accused Product, which infringes at least one claim of

the ’680 patent.

20. Upon information and belief, Defendant will continue to infringe the ’680

patent unless enjoined by the Court.

-4-
 Case 1:20-cv-00049 Document 1 Filed 01/07/20 USDC Colorado Page 5 of 7

21. Plaintiff Lightspeed has been damaged by Defendant’s infringement of the

’680 patent, and will continue to be damaged by that infringement, unless Defendant’s

infringement is enjoined by this Court.

22. Plaintiff Lightspeed is entitled to recover damages sustained as a result of

Defendant’s wrongful acts in an amount to be proven at trial.

23. Upon information and belief, Defendant has long had actual knowledge of

the ’680 patent, and their prior and continuing infringement of the ’680 patent was and

continues to be willful and deliberate.

24. As a result of Defendant’s willful infringement, Plaintiff Lightspeed is

entitled to increased damages under 35 U.S.C. § 284 and to attorney’s fees and costs

incurred in prosecuting this action under 35 U.S.C. § 285.

25. Alternatively, Plaintiff Lightspeed is entitled to Defendant’s total profits

from its sales of the Accused Product under 35 U.S.C. § 289.

COUNT II
ACTIVE INDUCEMENT OF INFRINGEMENT OF
U.S. PAT. NO. 9,370,680

26. Plaintiff Lightspeed incorporates the allegations of the preceding paragraphs

as though fully restated herein in their entirety.

27. Upon information and belief, as evinced by Defendant’s description and sale

of the Accused Product at the aforementioned website, a copy of which is attached herewith

as Exhibit B to the Complaint, Defendant has been and is actively inducing the

-5-
 Case 1:20-cv-00049 Document 1 Filed 01/07/20 USDC Colorado Page 6 of 7

infringement of the ’680 patent under 35 U.S.C. §271(b) by knowingly calculating to

induce third parties to directly infringe the ’680 patent.

28. Upon information and belief, Defendant will continue to actively induce

infringement of the ’680 patent unless enjoined by the Court.

29. Plaintiff Lightspeed has been damaged by Defendant actively inducing

infringement of the ’680 patent, and will continue to be damaged by that active inducement

of infringement, unless Defendant’s active inducement of infringement is enjoined by this

Court.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff Lightspeed prays for the following relief:

(a) That Defendant, its officers, agents, servants, employees and attorneys and

all person in active concert or participation, be permanently enjoined from

making, using and selling products which infringe U.S. Pat. No. 9,370,680;

(b) That Plaintiff Lightspeed be compensated for the damages caused by

Defendants’ infringement under 35 U.S.C. § 284;

(c) That the award for damages be trebled as provided by 35 U.S.C. § 284 for

willful infringement;

(d) That Plaintiff Lightspeed be awarded its costs and attorneys fees incurred in

prosecuting this action, as provided by 35 U.S.C. § 285, (plus interest); and

-6-
 Case 1:20-cv-00049 Document 1 Filed 01/07/20 USDC Colorado Page 7 of 7

(e) That this Court award such other and further relief as shall be deemed just.

Dated: Respectfully submitted,

By: /s/Yiu F. Au
Scott J. Hawranek
Yiu F. Au
Aspire IP, LLC
2 N Tejon Ave, Suite 400
Colorado Springs, CO 80903
Tel: (719) 359-9695
Fax: (719) 213-2928
scott@aspireip.com
yiu@aspireip.com

ATTORNEYS FOR PLAINTIFF

Lightspeed Running &
Rehabilitation Systems, LLC

-7-
 Case 1:20-cv-00049 Document 1-1 Filed 01/07/20 USDC Colorado Page 1 of 2
JS 44 (Rev. 06/17) District of Colorado CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS DEFENDANTS

Lightspeed Running & Rehabilitation System, LLC Lever, LLC

(b) County of Residence of First Listed Plaintiff Carlton, MN County of Residence of First Listed Defendant Boulder, CO
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
Aspire IP, LLC
6 N. Tejon St., Suite 400
Colorado Springs, CO 80903

II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
’ 1 U.S. Government ’ 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State ’ 1 ’ 1 Incorporated or Principal Place ’ 4 ’ 4
of Business In This State

’ 2 U.S. Government ’ 4 Diversity Citizen of Another State ’ 2 ’ 2 Incorporated and Principal Place ’ 5 ’ 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of a ’ 3 ’ 3 Foreign Nation ’ 6 ’ 6

Foreign Country
IV. NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions.
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
’ 110 Insurance PERSONAL INJURY PERSONAL INJURY ’ 625 Drug Related Seizure ’ 422 Appeal 28 USC 158 ’ 375 False Claims Act
’ 120 Marine ’ 310 Airplane ’ 365 Personal Injury - of Property 21 USC 881 ’ 423 Withdrawal ’ 376 Qui Tam (31 USC
’ 130 Miller Act ’ 315 Airplane Product Product Liability ’ 690 Other 28 USC 157 3729(a))
’ 140 Negotiable Instrument Liability ’ 367 Health Care/ ’ 400 State Reapportionment
’ 150 Recovery of Overpayment ’ 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS ’ 410 Antitrust
& Enforcement of Judgment Slander Personal Injury ’ 820 Copyrights ’ 430 Banks and Banking
’ 151 Medicare Act ’ 330 Federal Employers’ Product Liability ’ 830 Patent ’ 450 Commerce
’ 152 Recovery of Defaulted Liability ’ 368 Asbestos Personal ’ 835 Patent - Abbreviated ’ 460 Deportation
Student Loans ’ 340 Marine Injury Product New Drug Application ’ 470 Racketeer Influenced and
(Excludes Veterans) ’ 345 Marine Product Liability ’ 840 Trademark Corrupt Organizations
’ 153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR SOCIAL SECURITY ’ 480 Consumer Credit
of Veteran’s Benefits ’ 350 Motor Vehicle ’ 370 Other Fraud ’ 710 Fair Labor Standards ’ 861 HIA (1395ff) ’ 490 Cable/Sat TV
’ 160 Stockholders’ Suits ’ 355 Motor Vehicle ’ 371 Truth in Lending Act ’ 862 Black Lung (923) ’ 850 Securities/Commodities/
’ 190 Other Contract Product Liability ’ 380 Other Personal ’ 720 Labor/Management ’ 863 DIWC/DIWW (405(g)) Exchange
’ 195 Contract Product Liability ’ 360 Other Personal Property Damage Relations ’ 864 SSID Title XVI ’ 890 Other Statutory Actions
’ 196 Franchise Injury ’ 385 Property Damage ’ 740 Railway Labor Act ’ 865 RSI (405(g)) ’ 891 Agricultural Acts
’ 362 Personal Injury - Product Liability ’ 751 Family and Medical ’ 893 Environmental Matters
Medical Malpractice Leave Act ’ 895 Freedom of Information
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS ’ 790 Other Labor Litigation FEDERAL TAX SUITS Act
’ 210 Land Condemnation ’ 440 Other Civil Rights Habeas Corpus: ’ 791 Employee Retirement ’ 870 Taxes (U.S. Plaintiff ’ 896 Arbitration
’ 220 Foreclosure ’ 441 Voting ’ 463 Alien Detainee Income Security Act or Defendant) ’ 899 Administrative Procedure
’ 230 Rent Lease & Ejectment ’ 442 Employment ’ 510 Motions to Vacate ’ 871 IRS—Third Party Act/Review or Appeal of
’ 240 Torts to Land ’ 443 Housing/ Sentence 26 USC 7609 Agency Decision
’ 245 Tort Product Liability Accommodations ’ 530 General ’ 950 Constitutionality of
’ 290 All Other Real Property ’ 445 Amer. w/Disabilities - ’ 535 Death Penalty IMMIGRATION State Statutes
Employment Other: ’ 462 Naturalization Application
’ 446 Amer. w/Disabilities - ’ 540 Mandamus & Other ’ 465 Other Immigration
Other ’ 550 Civil Rights Actions
’ 448 Education ’ 555 Prison Condition
’ 560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an “X” in One Box Only)
’ 1 Original ’ 2 Removed from ’ 3 Remanded from ’ 4 Reinstated or ’ 5 Transferred from ’ 6 Multidistrict ’ 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
35 U.S.C. §1 et seq.
VI. CAUSE OF ACTION Brief description of cause: AP Docket
Patent infringement
VII. REQUESTED IN ’ CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. JURY DEMAND: ’ Yes ’ No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
01/07/2020 /s/Yiu F. Au
FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

Print Save As... Reset

 Case 1:20-cv-00049 Document 1-1 Filed 01/07/20 USDC Colorado Page 2 of 2
JS 44 Reverse (Rev. 06/17)

INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44

Authority For Civil Cover Sheet

The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as
required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is
required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of
Court for each civil complaint filed. The attorney filing a case should complete the form as follows:

I.(a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and
then the official, giving both name and title.
(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land
condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)
(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
in this section "(see attachment)".

II. Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X"
in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment
to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes
precedence, and box 1 or 2 should be marked.
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the
citizenship of the different parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversity
cases.)

III. Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this
section for each principal party.

IV. Nature of Suit. Place an "X" in the appropriate box. If there are multiple nature of suit codes associated with the case, pick the nature of suit code
that is most applicable. Click here for: Nature of Suit Code Descriptions.

V. Origin. Place an "X" in one of the seven boxes.

Original Proceedings. (1) Cases which originate in the United States district courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441.
When the petition for removal is granted, check this box.
Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the filing
date.
Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.
Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or
multidistrict litigation transfers.
Multidistrict Litigation – Transfer. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C.
Section 1407.
Multidistrict Litigation – Direct File. (8) Check this box when a multidistrict case is filed in the same district as the Master MDL docket.
PLEASE NOTE THAT THERE IS NOT AN ORIGIN CODE 7. Origin Code 7 was used for historical records and is no longer relevant due to
changes in statue.

VI. Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional
statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service

VII. Requested in Complaint. Class Action. Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.

VIII. Related Cases. This section of the JS 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docket
numbers and the corresponding judge names for such cases.

Date and Attorney Signature. Date and sign the civil cover sheet.
 Case 1:20-cv-00049 Document 1-2 Filed 01/07/20 USDC Colorado Page 1 of 15

EXHIBIT A

To The Complaint of:

Lightspeed Running & Rehabilitation Systems, LLC v. Lever LLC
Case 1:20-cv-00049 Document 1-3 Filed 01/07/20 USDC Colorado Page 1 of 2

EXHIBIT B
To The Complaint of:

Lightspeed Running & Rehabilitation Systems, LLC v. Lever LLC

LEVER Package | LEVER https://www.leverrunning.com/product-page/lever-pro
Case 1:20-cv-00049 Document 1-3 Filed 01/07/20 USDC Colorado Page 2 of 2

1 of 1 1/1/2020, 2:08 PM
Case 1:20-cv-00049 Document 1-4 Filed 01/07/20 USDC Colorado Page 1 of 22

EXHIBIT C
To The Complaint of:

Lightspeed Running & Rehabilitation Systems, LLC v. Lever LLC

 Case 1:20-cv-00049 Document 1-4 Filed 01/07/20 USDC Colorado Page 2 of 22

DuFault
Law Firm, P.C.
Office (by appointment only): Correspondence:
5200 Willson Road PO Box 1219
Suite 150 Minnetonka MN 55345
Edina MN 55424
Dustin R. DuFault
(952) 935-4392
Dustin@DuFault-Law.com

Friday, August 23, 2019

Sent Via Priority Mail

Lever, LLC
c/o Mr. Ryan Ognibene, Registered Agent
4450 9th Street
Boulder CO 80301

Re: Infringement of U.S. Pat. No. 9,370,680

Mr. Ognibene:

I write in follow-up to my letter of June 4, 2019, to which I received no response.

If you recall, I represent Lightspeed Running & Rehabilitation Systems, LLC, based out
of Duluth, Minnesota (“Lightspeed”). Lightspeed is the owner by assignment of U.S.
Pat. No. 9,370,680, which issued on June 21, 2016, entitled “Bodyweight Support System
for Therapeutic and Physical Training, and Method of Use Thereof” (hereinafter “the
’680 patent”). Lightspeed maintains the right to enforce the ’680 patent, a copy of which
we enclose for your review.

As previously reported, it has come to our attention that Lever, LLC, is making,
using, selling and/or offering for sale a product described as “Lyte-V Package.” Based
upon our investigation, it appears that the “Lyte-V Package” product infringes at least
two claims of the ’680 patent. An exemplary claim chart detailing how the “Lyte-V
Package” product infringes at least claims 9 and 15 of the ’680 patent is enclosed for your
review. You are probably aware that an infringer can be enjoined by court order from
further infringement, and may also be required to pay damages suffered by the patent
owner as a result of the infringement, including lost profits. Willful infringement can
result in an award of treble damages and attorney’s fees. Given that you were put on
actual notice of the ’680 patent this past June, prior to Lever, LLC, having any sales of
the “Lyte-V Package” product, we believe we will have a good case for the finding of
willful infringement.

www.DuFault-Law.com
 Case 1:20-cv-00049 Document 1-4 Filed 01/07/20 USDC Colorado Page 3 of 22

Mr. Ryan Ognibene DuFault Law Firm, P.C.

8/23/2019

Demand is hereby made for you to immediately stop infringing the ’680 patent,
and for you to provide written assurance that you have terminated all manufacture, use,
sale, and/or offers for sale of the “Lyte-V Package” product in the United States. If you
wish to resolve this matter outside of litigation, please contact us within twenty-one days
from the date of this letter. Otherwise, Lightspeed will assume that you intend to
continue infringing the ’680 patent and will therefore pursue all legal remedies available.

We are hopeful that an early and amicable resolution of this matter may be
reached.

DuFAULT LAW FIRM, P.C.

Dustin R. DuFault

Enclosures

2
 Case 1:20-cv-00049 Document 1-4 Filed 01/07/20 USDC Colorado Page 4 of 22

9. A body weight support system for

use with an exercise machine, the body
weight support system comprising:

a pair of front vertical posts configured

to extend vertically adjacent to a front
section of the exercise machine;

a pair of rear vertical posts configured to

extend vertically adjacent to a rear
section of the exercise machine;

a front horizontal member securable to

the pair of front vertical posts, the front
horizontal member comprising at least
one front connection mechanism;
 Case 1:20-cv-00049 Document 1-4 Filed 01/07/20 USDC Colorado Page 5 of 22

a rear horizontal member securable to

the pair of rear vertical posts, the rear
horizontal member comprising at least
one rear connection mechanism;

a pair of biasing cords connectable to the

at least one front connection mechanism
and to the at least one rear connection
mechanism such that the biasing cords
are suspendable between the front
horizontal member and the rear
horizontal member;

a pair of support straps suspendable

from the pair of biasing cords;
 Case 1:20-cv-00049 Document 1-4 Filed 01/07/20 USDC Colorado Page 6 of 22

a leg apparel wearable by a user

an having opposing outer
lateral sides;

and a pair of engagement strips secured

to the opposing outer lateral sides of the
leg apparel, wherein each engagement
strip is configured to engage one of the
support straps such that the engaged
support strap is substantially aligned
with a greater trochantor of a leg of the
user wearing the leg apparel;

wherein the suspension of the biasing

cords between the front horizontal
member and the rear horizontal member
biases the leg apparel upward to
generate a lifting force that extend
through a femoral head axis of motion of
the user.
 Case 1:20-cv-00049 Document 1-4 Filed 01/07/20 USDC Colorado Page 7 of 22

15. A method for using an exercise

machine, the method comprising:
suspending a first biasing cord and a second
biasing cord each between a front horizontal
bar and a rear horizontal bar, wherein the
front horizontal bar is positioned above a
front section of the exercise machine, and
wherein the rear horizontal bar is
positioned above a rear section of the
exercise machine;

securing a first support strap that is

suspended from the first biasing cord to a
first engagement strip that is connected to a
first outer lateral side of a leg apparel worn
by a user such that the first support strap is
substantially aligned with a greater
trochantor of a first leg of the user;

securing a second support strap that is

suspended from the second biasing cord to a
second engagement strip that is connected
to a second outer lateral side the leg apparel
such that the second support strap is
substantially aligned with a greater
trochantor of a second leg of the user;

generating a lifting force by the biasing cord

that extends through a femoral head axis of
motion of the user, and
Case 1:20-cv-00049 Document 1-4 Filed 01/07/20 USDC Colorado Page 8 of 22

operating the exercise machine while

generating the lift force.