IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 
STRAVA, INC.,
Plaintiff,
v. 
GARMIN LTD., and GARMIN INTERNATIONAL, INC., 
Defendants. 
COMPLAINT AND JURY DEMAND
Strava, Inc. (“Strava” or “Plaintiff”), by and through its undersigned counsel, hereby 
submits this Complaint for Patent Infringement, Breach of Contract, and Damages against 
Defendants Garmin Ltd. and Garmin International, Inc. (collectively “Garmin” or “Defendants”): 
NATURE OF THE CASE
1. Strava is a pioneer at the intersection of exercise, technology, and community. From 
its earliest days, Strava has enabled users to log GPS-based activities, analyze performance, 
discover routes, compete, and participate in a community built around data-driven, innovative 
features.
2. These features have helped Strava become one of the world’s most popular 
software platforms relating to fitness, with more than 170 million users worldwide. In 2024 alone, 
Strava users recorded billions of activities.
3. Strava’s success is due in large part to its sustained investment in original 
technology. Over more than a decade, Strava designed and refined, among other innovations: 
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segments—user-defined stretches of road or trail that let users compare performance on the same 
route; leaderboards—rankings that let users see how their efforts stack up against friends, locals, 
or the global community; heatmaps—visual depictions aggregating billions of activities to show 
where people run, ride, or hike most frequently; and specialized routing features—such as 
recommending popular routes based on community data, prioritizing dirt trails, or maximizing 
elevation gain between two points rather than simply identifying shortest route between them. 
These systems power the core features utilized by millions of users across disciplines.
4. Strava owns the inventions that make these features possible, including U.S. Patent 
Nos. 9,116,922 (defining and matching segments) and 9,297,651 and 9,778,053 (user‑preference 
activity maps and popularity‑based routing). These patents protect the techniques that transform 
raw GPS readings into meaningful performance comparisons and commonly traveled, 
preference‑aware route suggestions.
5. The raw GPS readings on Strava’s platform come either through recording on 
Strava’s mobile application or through third-party hardware compatible with the Strava platform. 
6. The Strava app records GPS directly from a phone’s sensors, but its broader 
platform also supports activity files and data synced from third‑party hardware—such as fitness 
watches and bike computers—so users can use Strava’s analysis and social features regardless of 
the device used to capture the activity.
7. Garmin develops, manufactures, and sells a variety of such GPS-enabled devices. 
It is a leading provider of wearables, bike computers, and other devices that users use to capture 
their activities. 
8. Garmin has tried to leverage its hardware success to establish a social network to 
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rival Strava. Those efforts have not borne fruit.
9. For instance, in 2014, Garmin rolled out its own “segment” feature within its 
Garmin Connect web and mobile application, aiming to compete with Strava. But Garmin’s 
approach did not achieve comparable adoption, engagement, or data quality to Strava’s segment 
ecosystem. 
10. To meet user demand for Strava’s segments on Garmin devices, Garmin 
approached Strava to collaborate on an official integration of Strava’s segments on Garmin’s 
devices, culminating in a Master Cooperation Agreement (“MCA”) between the parties in 2015. 
11. Pursuant to the MCA, the companies collaborated to deliver a Strava‑quality 
experience on certain Garmin devices while establishing careful guardrails to protect Strava’s 
intellectual property. The MCA granted Garmin a narrow license to use Strava Segments only as 
required to implement the user experience specified in the agreement. 
12. That user experience was explicitly exclusive to Strava users, reserving all other 
rights to Strava. The MCA further prohibited adaptation, reverse engineering, copying, or 
distribution of Strava Segments by Garmin except as expressly permitted. 
13. Rather than honor the MCA’s limits, Garmin subsequently expanded its own 
“Garmin segments” feature, apparently relying on Strava’s segment technology and know‑how 
gained through the collaboration, while exceeding the scope of the limited license and restrictions 
in the MCA.
14. Independent of that breach, Garmin’s products and services—including Garmin 
Connect and various Garmin fitness devices—practice Strava’s patented segment matching and 
popularity‑based routing inventions claimed in U.S. Patent Nos. 9,116,922; 9,297,651; and
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9,778,053.1
15. Strava brings this action for patent infringement and breach of contract, and seeks 
damages and injunctive and declaratory relief. 
THE PARTIES
16. Plaintiff Strava, Inc. (“Strava”) is a Delaware corporation with its principal place 
of business at 181 Fremont St, Floor 27, San Francisco, California 94105. 
17. Defendant Garmin Ltd. is a company organized under the laws of Switzerland, with 
U.S. operations through subsidiaries, including Garmin International, Inc. and Garmin USA, Inc. 
18. Defendant Garmin International, Inc. (“Garmin International”) is a corporation 
organized and existing under the laws of Kansas. Garmin International may be served with process 
through its registered agent, the Corporation Service Company d/b/a CSC-Lawyers Incorporating 
Service Company. 
JURISDICTION AND VENUE
19. This Court has subject-matter jurisdiction over Strava’s patent claims under 28 
U.S.C. §§ 1331 and 1338(a). The Court has supplemental jurisdiction over Strava’s contract and 
related state-law claims under 28 U.S.C. § 1367(a) because they form part of the same case or 
controversy. 
20. Garmin International, Inc. is subject to personal jurisdiction in this District because 
it conducts continuous and systematic business operations in Colorado, including maintaining 
offices, facilities, and personnel in this District.
21. The Court also has specific personal jurisdiction over Garmin Ltd. On information 
1
 True and correct copies of the Patents-in-Suit are attached as Exhibits 1-3. 
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and belief, Garmin Ltd. purposefully directed activities at and into this forum by overseeing, 
authorizing, and benefiting from the design, development, marketing, and sale of the accused 
products and services carried out through Garmin’s U.S.-based operations, including those in 
Colorado; and by deriving substantial revenue from sales of the accused systems and features to 
customers in this District. Strava’s claims arise out of and relate to those forum-directed contacts.
22. Venue is proper in this District for Strava’s contract claims under 28 U.S.C. § 
1391(b)(2) because, on information and belief, a substantial part of the events giving rise to those 
claims occurred here, including Garmin’s product-management, engineering, and business￾decision activities in Colorado as well as sales and marketing decisions made and/or carried out in 
this District.
23. Venue is proper in this District for Strava’s patent claims against Garmin 
International, Inc. under 28 U.S.C. § 1400(b) because, on information and belief, it has committed 
acts of infringement in this District and maintains a regular and established place of business here, 
including its facilities in Boulder, Colorado. 
24. Venue is proper in this District for Strava’s patent claims against Garmin Ltd. under 
28 U.S.C. § 1391(c)(3) because Garmin Ltd. is an alien corporation and may be sued in any judicial 
district.
25. Accordingly, this action is properly filed in the United States District Court for the 
District of Colorado. 
FACTUAL BACKGROUND
Strava’s platform is built on innovation 
26. Strava helps runners, cyclists, and other users track GPS‑based activities, analyze 
performance, discover routes, and compete—together and asynchronously—using features like 
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leaderboards, heatmaps, suggested routes, training insights, and challenges. 
27. Strava is accessed via web, mobile application, and/or wearable device. Users can 
record physical activities such as running, cycling, hiking, and swimming, either directly through 
Strava’s mobile application or by syncing data from connected third-party devices and sensors. 
Strava processes and organizes this data to provide users with detailed analytics on performance 
metrics such as distance, pace, and elevation.
28. Strava’s systems are device‑agnostic; they ingest activity data from phones and 
third‑party devices (e.g., bike computers and fitness watches), apply normalization and error 
correction, and deliver comparable, repeatable performance metrics for millions of users.
29. Strava was founded in 2009 by Michael Horvath and Mark Gainey, two former 
Harvard rowing teammates. Swedish for “strive,” Strava embodied from the start a vision of 
creating a virtual team: an online space where users anywhere could connect, share their efforts, 
and compete in real time. 
30. Initially, Strava found success with outdoor cyclists and runners. But over time, 
Strava has added support for dozens more activity types including swimming, hiking, skiing, 
climbing, and gym workouts—broadening its appeal to a wide spectrum of users.
31. Strava’s success owes in large part to its technological innovations, enabling users 
not only to record GPS‑tracked activities and analyze their performance, but also to compete 
asynchronously on user‑defined segments, to explore user-preference maps, and to design their 
own routes.
32. “Segments” are user-defined stretches of a GPS-tracked activity—such as a run or 
ride—delineated by selecting a start and end point on a map or an existing recorded effort. Once 
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defined, the system converts that geographic track into an abstracted form—e.g., minimum 
bounding rectangles (MBRs)—and stores it in a spatial index—e.g., an R-tree database—for 
efficient search and comparison. 
33. The following is an image of a segment on the Strava website:
34. When a new user activity (“effort”) is uploaded, the system similarly converts its 
GPS data into MBRs and queries the segment database to find overlapping segments. If the overlap 
meets a threshold—determined by how much the effort’s MBRs overlap with the segment’s—it’s 
identified as a match. Once matched, associated performance data like time, speed, heart rate, and 
power are aggregated and used to produce leaderboards or visual comparisons. These techniques 
allow fair, repeatable comparisons on the same piece of ground across devices, time, and 
conditions. Additionally, by leveraging GPS data, segments can be defined with minimal effort on 
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the part of the user. 
35. The following is an image of the leaderboard for the same segment depicted above 
on the Strava website:
36. To determine whether an individual activity has completed a given segment, Strava 
developed a proprietary algorithmic process called “segment matching.” 
37. Segment matching relies on geometric abstractions of GPS data and 
threshold‑based decision logic to ensure accuracy at scale. Once created, these segments trigger 
automatic detection when users replay those GPS tracks. Whenever a user’s activity path overlaps 
with a segment’s coordinates—which can be determined, in part, by defining a virtual starting 
line—Strava includes that effort on leaderboards that allow the user to compete with their own 
prior efforts and those of every Strava user ever to attempt the same segment. 
38. At the same time, Strava applies user-selected privacy controls to this process: users 
can limit whether their activities are visible to the public, to followers only, or to no one at all, and 
can use privacy zones to obscure the GPS start and end points of activities. These privacy settings 
govern which efforts appear on leaderboards and how location data is displayed, allowing users to 
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benefit from Strava’s segment features without sacrificing control over sensitive personal 
information.
39. These leaderboards drive engagement through friendly rivalry, and Strava 
rigorously manages the integrity of results by offering both reporting and analytical tools for 
flagging and removing suspicious or anomalous performances. 
40. Strava segments are powered by patented technology, including spatial indexing 
(to detect overlaps quickly) and temporal sorting and filtering to compare performances accurately 
across thousands—even millions—of segment attempts.
41. Beyond segments, Strava’s patented technology employs other concepts for turning 
real-world data into software structures, such as traversals and edges. Edges are the core building 
blocks of Strava’s basemap, representing sections of a road, path, or trail. Metadata associated with 
each edge is aggregated from all the activities that have passed over it, such as trip counts (the 
number of times people have traveled it), the direction of travel, the time of day, etc. A traversal 
is a crossing of an edge by a Strava user. 
42. Strava has developed large‑scale pipelines that process GPS activities, aggregate 
traversals to a base map, and store per‑edge metadata—popularity counts, directionality, 
traversal‑time distributions, and barometrically normalized elevation profiles—while weighting 
by device accuracy and recency. Those data power heatmaps, suggested routing, and other 
features. 
43. Strava’s heatmaps leverage color gradients—e.g., with reds and oranges indicating 
high-traffic routes, and greens/blues showing lesser-used paths—to communicate usage intensity 
intuitively. For instance, this image reflects all sports on Strava across the Denver metro area:
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: 
44. These visualizations serve multiple purposes. Among other things, they highlight 
popular paths and act as the backbone of route discovery and route building for users. 
45. To counter GPS noise and heterogeneous device quality, Strava assigns confidence 
scores to traversals based on factors such as reported horizontal accuracy, sampling interval, and 
the presence of a barometric altimeter. Strava also performs elevation normalization so that edge 
profiles are comparable across devices and conditions, and rejects outliers (e.g., spurious points or 
implausible speeds) before any aggregate is computed.
46. From these cleaned traversals, Strava generates a user‑preference activity map by 
aggregating to base‑map edges and computing edge‑level metadata. That metadata includes, for 
example, popularity counts (optionally by sport), directionality, typical traversal‑time distributions 
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(with time‑of‑day and day‑of‑week slices), and barometrically normalized elevation profiles. The 
system can apply recency weighting so that emerging usage patterns influence routing sooner than 
stale ones.
47. When users request a route between endpoints (with preferences such as surface, 
elevation, or effort), Strava’s systems consult the stored user‑preference map to produce one or 
more candidate routes that reflect how users actually move through the world. 
Garmin sought out Strava technology to improve its users’ experience
48. Strava integrates with major hardware providers in the fitness space—including 
Garmin—so users can capture activities on the device of their choice and still benefit from Strava’s 
analysis, segments, routing, and social features. To deliver a consistent, high‑quality user 
experience, Strava collaborates with device makers on APIs, data formats, and integration 
approaches that enable seamless and reliable syncing and presentation of Strava features on 
third‑party hardware.
49. On information and belief, Garmin has long sought to leverage its hardware 
footprint to build its own social and competitive fitness experiences, but those efforts have failed 
to match Strava’s adoption, engagement, or network effects. 
50. Given the low popularity of Garmin’s internally-built features, Garmin sought to 
collaborate with Strava to directly integrate Strava’s segments into Garmin’s devices.
51. To provide Garmin users with segment features that met Strava’s quality bar, the 
parties cooperated and entered into the MCA on April 8, 2015. The MCA—signed by Garmin, 
Ltd. and Strava—permitted Garmin to use defined “Strava Segments” solely to implement the user 
experience set forth in Exhibit A to that agreement. 
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52. Exhibit A describes a user experience built by Strava and delivered to Strava users 
through Garmin devices. Among other things, Exhibit A requires a device setting allowing a Strava 
user to enable real‑time competition on either Strava Segments or Garmin segments—not both at 
once—and forbids commingling results. The MCA and Exhibit A preserve Strava’s control over 
the segment experience and data, including requirements that the Strava‑built experience be 
identifiable as such and limited to Strava users.
53. The MCA includes strict restrictions and safeguards: Garmin receives a limited, 
revocable, non‑sublicensable license; may not adapt, reverse engineer, use, copy, modify, or 
distribute Strava Segments except as expressly licensed; and must comply with confidentiality and 
use‑of‑materials limits. The MCA also contains remedies and a carve‑out from limitations for 
breaches of these restrictions, along with fee‑shifting in specified circumstances. Strava performed 
under the MCA, including by delivering Strava Segments and integration materials, providing 
updates, and supporting Garmin’s implementation of the agreed user experience.
54. During the parties’ collaboration, Strava supplied segment definitions and 
integration materials—including code artifacts, APIs/SDKs, documentation, and test assets—
necessary to implement the agreed Strava‑built experience. 
55. Despite the MCA’s clear limits, Garmin expanded well beyond that agreement’s 
scope. Garmin built, branded, and widely deployed Garmin‑branded segments outside the 
Strava‑built experience and to non‑Strava users; enabled segment competition and leaderboards 
across Garmin Connect (web and mobile) and on devices; and surfaced segment results 
independent of the Exhibit A constraints. 
56. Garmin has also rolled out popularity‑based routing and heatmap features 
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(including Trendline/Popularity Routing and related functionality) that practice Strava’s patented 
user‑preference map inventions. 
57. Representative accused instrumentalities include Garmin Connect (web and 
mobile); Garmin’s Popularity/Trendline routing and heatmaps; and Garmin wearables and bike 
computers that support segments and popularity routing, including but not limited to the Edge, 
Forerunner, Fenix, and Epix product lines.
58. Garmin’s conduct breached the MCA’s express restrictions and, independently, 
infringed Strava’s U.S. Patent No. 9,116,922. Among other things, Garmin’s segment 
implementation performs the claimed techniques for defining segments, generating virtual 
start/finish lines based on path and orientation, detecting crossings (including via associated 
performance data), and determining matches.
59. Garmin also infringes Strava’s U.S. Patent Nos. 9,297,651 and 9,778,053 through 
its popularity‑based routing and heatmap features. 
60. Strava provided written notice of infringement and breach at least by June 30, 2025, 
and again in July 2025, yet Garmin has continued its conduct, causing ongoing harm to Strava. 
Additionally, Garmin was on notice, as a result of its collaboration with Strava and the 2015 MCA, 
that at least Strava’s segment technology was protected by Strava’s intellectual property rights. 
Nevertheless, Garmin continued to use Strava’s technology in ways that Strava has never 
authorized or licensed.
61. Strava has complied with 35 U.S.C. § 287(a) with respect to the Asserted Patents, 
to the extent applicable, or the asserted claims are directed to methods not subject to marking.
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COUNT ONE
(Infringement of the ’922 Patent)
62. Strava repeats and re-alleges the allegations in the preceding paragraphs as if fully 
set forth herein. 
63. On August 25, 2015, the United States Patent and Trademark Office duly and 
legally issued the ’922 Patent entitled “Defining and matching segments.” See Exhibit 1. Strava 
owns all right, title, and interest in and to the ’922 Patent, including the right to assert all causes 
of action under the ’922 Patent and the right to sue and obtain any remedies for past, present, or 
future infringement. 
64. The ’922 Patent claims a computer-implemented method for matching a previously 
defined route segment to an effort by receiving a user-submitted definition of the segment, 
associating the segment with a first set of GPS data, and generating a virtual start line for the 
segment by determining a path through a user-selected segment start point, determining an 
orientation of the path, and setting the virtual start line in relation to the orientation. The patent 
claims specific improvements that include comparing a second set of GPS data associated with an 
effort to the virtual start line, determining that the second set crosses the virtual start line—
including generating an extrapolation from at least a portion of the second set based at least in part 
on associated data comprising one or more types of performance metrics—determining that the 
extrapolation crosses the virtual start line, determining that the effort matches the segment based 
at least in part on the crossing, and accessing information associated with the matched segment.
65. The asserted claims of the ’922 Patent recite concrete data-structuring and control 
logic. For example, the claims require generating a virtual start line for a user-defined segment by 
deriving a path through the user-selected start point from recorded GPS data, determining the 
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path’s orientation, and setting the start line in relation to that orientation; they then require 
determining a match by comparing the effort’s GPS data to that start line and finding a crossing 
using an extrapolation computed from associated performance metrics (e.g., speed/time). Those 
are claim-level, processor-executed steps that constrain how the data is processed and when a 
match is recorded.
66. The asserted dependent claims further tighten that logic with threshold matching—
including a higher second (tight-match) threshold than the first (looser) threshold—and with a 
finish-line crossing requirement before a tight match is recorded; and the asserted system claim 
requires performing the matching using a spatially indexed query (e.g., an R-tree) to scale lookups 
over stored segments. At the time of the invention, these claim-recited techniques—individually 
and in their ordered combination—were not well-understood, routine, or conventional, and they 
significantly improve the functioning of GPS devices and matching systems by reducing false 
positives, tolerating GPS jitter and sampling variability, and scaling server-side processing.
67. Figure 9 of the ’922 Patent, reproduced below, is a flow diagram showing an 
illustrative embodiment of converting a series of GPS information into a set of minimum bounding 
rectangles (“MBRs”) in accordance with some embodiments. As shown in FIG. 9, the system maps 
a series of GPS points to tiles, optionally fills gaps to ensure a contiguous path, optionally expands 
the set of tiles, and then groups the tiles into minimum bounding rectangles, which are stored and 
queried against an R-Tree–indexed segment database to identify overlaps for matching:
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’922 Patent, Fig. 9.
68. Figure 11B of the ’922 Patent, reproduced below, is a flow diagram showing an 
illustrative embodiment of the segment-matching decision process. The system first determines 
whether an effort’s overlap with a stored segment exceeds a first threshold; if so, it records a loose 
match. When the overlap exceeds a higher threshold and the effort crosses the segment’s virtual 
start and finish lines, the system records a tight match, operationalizing when a user truly 
completed the segment.
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’922 Patent, Fig. 11B.
69. Defendants have directly infringed and continue to directly infringe one or more 
claims of the ’922 Patent, including at least Claims 1, 11, 12, and 15 (“Asserted ’922 Claims”), by 
making, using, offering to sell, selling, and importing products and services that perform the 
patented methods and/or employ the patented systems in the United States, without license or 
authority, including but not limited to Garmin Connect and Garmin devices—including Edge bike 
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computers, Forerunner, Fenix, and Epix watches—that support segments (the “’922 Accused 
Instrumentalities”).
70. Defendants have directly infringed and continue to directly infringe at least one 
claim of the ’922 Patent, including the Asserted ’922 Claims, in violation of 35 U.S.C. § 271(a).
71. For instance, Defendants’ Garmin Connect platform and Garmin devices practice 
the steps of the claimed method of defining and matching user-created segments. In particular, 
Garmin invites users to create segment definitions and stores them for later comparison against 
users’ recorded efforts. When a user’s path approaches a stored segment, Garmin devices detect 
the segment start and present a segment screen; when the user’s path crosses the segment start and 
proceeds along the segment, the device records and reports the result, including automatically 
signaling completion at the finish. These functionalities satisfy the limitations of Claim 1, 
including receiving a user-defined segment, generating and using a segment start line aligned to 
the path, and determining a match by comparing activity GPS data to that start line using 
performance data the device tracks during the effort. The ’922 Patent describes this method, 
including generating a virtual start line from the user-selected start and the segment path 
orientation and then determining a match when the extrapolated effort crosses that start line. The 
following screenshots from Garmin’s website are illustrative:
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72. Defendants directly infringe by performing one or more steps of the asserted 
methods on their servers and devices; alternatively, any steps performed by end users are 
performed under Defendants’ direction or control and/or as part of a joint enterprise, including 
because Defendants condition participation in and benefits from Garmin Segments on performance 
of those steps and dictate the manner or timing of such performance through device firmware, 
defaults, and instructions.
73. On information and belief, Defendants also practice the additional limitations of 
dependent claims addressing matching thresholds. In particular, Garmin employs distinct 
tolerances for (i) initial/looser detection used to alert on segment approach and (ii) tighter detection 
used to record a completed match—satisfying the two-threshold scheme and the requirement that 
the second threshold exceed the first in Claim 11. Device behavior and documentation reflect this 
separation between approach alerts and completed-segment determinations.
74. Defendants further practice the additional “finish-line” requirement of Claim 12: 
Garmin devices determine that a tight match occurs only when the user’s recorded GPS data 
traverses the segment from start to finish, and they display a completion message when the finish 
is crossed. The following screenshot from Garmin’s website is illustrative:
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75. Defendants also infringe the asserted system claim. Garmin’s servers and devices 
comprise a system with processors and memory configured to perform the foregoing matching 
operations at scale, including storing large numbers of segments and efficiently querying them 
against uploaded activities to determine matches and populate leaderboards. On information and 
belief, Garmin implements these queries using a spatial index (e.g., an R-tree or equivalent) as 
recited in Claim 15, which the ’922 Patent discloses for scalable segment matching; Garmin’s own 
materials confirm segment storage and leaderboard operations integral to these queries.
76. To the extent any limitation is not literally present, infringement occurs under the 
doctrine of equivalents because the Accused Products perform substantially the same function, in 
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substantially the same way, to achieve substantially the same result.
77. Garmin also indirectly infringes by inducing and contributing to users’ 
infringement, with knowledge of the ’922 Patent at least as of June 30, 2025, and specific intent 
that customers use the ’922 Accused Instrumentalities in an infringing manner. Defendants’ 
affirmative acts include, by way of example, providing detailed instructions on their website and 
in product manuals, showing users how to create and “race” infringing Garmin Segments. Such 
acts have induced and continue to induce direct infringement of the Asserted Claims.
78. Defendants’ infringement has been and continues to be willful. Despite their 
knowledge of the ’922 Patent and their infringement since at least June 30, 2025, Defendants have 
intentionally or recklessly continued their infringing acts, making this an exceptional case, 
warranting enhanced damages and reasonable attorneys’ fees under 35 U.S.C. §§ 284-285.
79. Plaintiff has complied with 35 U.S.C. § 287. The Asserted ’922 Claims include 
method claims that are not subject to § 287’s marking requirement. To the extent § 287 applies to 
the asserted system claim, Plaintiff has not made, sold, or authorized the sale of any patented 
articles practicing that claim in the United States prior to suit, or, alternatively, Defendants had 
actual notice of the ’922 Patent and the basis for infringement no later than June 30, 2025; 
therefore, § 287 does not bar recovery of pre-suit damages.
80. Plaintiff has been damaged by Defendant’s infringement in an amount to be proven 
at trial and is entitled to no less than a reasonable royalty and/or lost profits pursuant to 35 U.S.C. 
§ 284.
81. Monetary relief alone is inadequate. Garmin’s continued infringement of the ’922 
Patent causes irreparable harm to Strava, including loss of network effects, erosion of platform 
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differentiation and goodwill, and brand loyalty that cannot be fully measured or compensated in 
money. There is a causal nexus between the accused segment-identification, matching, and ranking 
and consumer demand for Garmin’s devices and services. Strava is therefore entitled to a 
permanent injunction prohibiting Garmin from making, using, offering to sell, selling, or importing 
the accused implementations (and any colorable variations) of the patented technology, and Strava 
has no adequate remedy at law; the balance of hardships and the public interest favor injunctive 
relief.
COUNT TWO
(Infringement of the ’651 Patent)
82. Strava repeats and re-alleges the allegations in the preceding paragraphs as if fully 
set forth herein. 
83. On March 29, 2016, the United States Patent and Trademark Office duly and legally 
issued the ’651 Patent entitled “Generating user preference activity maps.” See Exhibit 2. Strava 
owns all right, title, and interest in and to the ’651 Patent, including the right to assert all causes 
of action under the ’651 Patent and the right to sue and obtain any remedies for past, present, or 
future infringement. 
84. The ’651 Patent claims computer-implemented systems, methods, and computer 
program products that transform massive GPS activity datasets into a “user‑preference map” and 
use that map to compute route suggestions. The asserted claims recite concrete, processor‑executed 
steps and data structures including (i) mining user activities according to an ordered hierarchy of 
GPS recording device types to prioritize higher‑accuracy sources; (ii) aggregating traversals to 
edges of a base map and storing edge‑level metadata in the user‑preference map; and (iii) 
determining one or more suggested routes between user‑input endpoints based at least in part on 
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the user‑preference map, including by receiving user‑input route preferences and presenting route 
candidates. These are claim‑recited mechanisms that improve the way computer systems process 
and query geospatial data at scale, not mere data display.
85. At the time of the invention, the ordered‑device mining and edge‑level aggregation 
used to generate and query the user‑preference map—individually and in their ordered 
combination—were not well‑understood, routine, or conventional. Implementing the claimed
pipelines materially improves functionality by reducing noise from heterogeneous devices, 
increasing the accuracy and robustness of edge statistics (including barometrically normalized 
elevation profiles), and enabling efficient server‑side route computation across large activity 
corpora. 
86. Figures of the ’651 Patent (e.g., Figs. 5 and 10A–10E) depict exemplary flows that 
match traversals to base‑map edges and normalize barometric elevation profiles for storage as edge 
metadata in the user‑preference map; those disclosures support and illustrate, but do not limit, the 
asserted claims:
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’651 Patent, Fig. 5. 
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’651 Patent, Fig. 10E.
87. Defendants have directly infringed and continue to directly infringe one or more 
claims of the ’651 Patent, including at least Claims 1, 2, 8, 9, 11, 18, and 23 (the “Asserted ’651 
Claims”), by making, using, offering to sell, selling, and importing products and services that 
practice the patented technology in the United States, without license or authority, including 
Garmin Connect and Garmin devices—such as Edge cycling computers and Forerunner, Fenix, 
and Epix watches—that implement Trendline/Popularity routing, heatmaps, Courses, and related 
features (the “’651 Accused Instrumentalities”).
88. By way of non‑limiting example, the ’651 Accused Instrumentalities collect and 
prioritize activities recorded on different device types (including settings such as Every‑Second 
Recording), aggregate those activities to a base map to generate a user‑preference map (e.g., 
popularity/heatmap datasets) with edge‑level metadata, and determine one or more suggested 
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routes between user inputs, identifying endpoints based at least in part on that user‑preference 
map—while also receiving user route preferences and presenting route candidates to the user. 
These implementations satisfy the limitations of at least the Asserted ’651 Claims.
89. Defendants directly infringe by performing one or more steps of the asserted 
methods on their servers and devices; alternatively, any steps performed by end users are 
performed under Defendants’ direction or control and/or as part of a joint enterprise, including 
because Defendants condition participation in and benefits from the accused features on 
performance of those steps and dictate the manner or timing of such performance through device 
firmware, defaults, and instructions.
90. On information and belief, Defendants further practice dependent limitations 
requiring, for example, that the base map comprise GIS datasets; that the system present a 
user‑preference map and/or the suggested routes at a user interface; that route computation 
incorporate user‑provided preferences; and that the system select barometric‑data candidate 
activities for edges and normalize recorded elevations based on obtained edge elevation data, 
storing the normalized profile as edge metadata—all as recited in the Asserted ’651 Claims.
91. The following screenshots from Defendants’ publicly available pages and manuals 
are illustrative of the accused functionality, including a user-preference map, and allowing users 
to create routes prioritizing popularity, distance, time, or elevation based on user datasets:
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92. To the extent any limitation is not literally present, infringement occurs under the 
doctrine of equivalents because the ’651 Accused Instrumentalities perform substantially the same 
function, in substantially the same way, to achieve substantially the same result.
93. Defendants also induce and contribute to infringement of the Asserted ’651 Claims, 
with knowledge of the ’651 Patent at least as of July 25, 2025, and specific intent that customers 
use the ’651 Accused Instrumentalities in an infringing manner. Defendants’ affirmative acts 
include, by way of example, publishing user guides, support articles, marketing pages, and 
in‑device prompts instructing users how to enable and use Trendline/Popularity routing, heatmaps, 
Courses, and related features.
94. Defendants’ infringement has been and continues to be willful. Despite their 
knowledge of the ’651 Patent and their infringement since at least July 25, 2025, Defendants have 
intentionally or recklessly continued their infringing acts, making this an exceptional case and 
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warranting enhanced damages and reasonable attorneys’ fees under 35 U.S.C. §§ 284–285. 
95. Plaintiff has complied with 35 U.S.C. § 287. The Asserted ’651 Claims include 
method claims that are not subject to § 287’s marking requirement. To the extent § 287 applies to 
any asserted system or computer‑readable‑medium claims, Plaintiff has not made, sold, or 
authorized the sale of any patented articles practicing those claims in the United States prior to 
suit, or, alternatively, Defendants had actual notice of the ’651 Patent and the basis for 
infringement no later than July 25, 2025; therefore, § 287 does not bar recovery of pre‑suit 
damages.
96. Strava has suffered and will continue to suffer damages as a result of Defendants’ 
infringement of the ’651 Patent. Strava is entitled to recover damages adequate to compensate for 
such infringement, including no less than a reasonable royalty and, where proven, lost profits, 
together with pre‑ and post‑judgment interest and costs. Monetary relief alone is inadequate; 
Garmin’s continued infringement causes irreparable harm, including loss of network effects, 
erosion of platform differentiation and goodwill, and brand loyalty. There is a causal nexus 
between the accused mapping/routing implementations and consumer demand for Garmin’s 
products and services. Strava is therefore entitled to a permanent injunction prohibiting Defendants 
from making, using, offering to sell, selling, or importing the accused implementations (and any 
colorable variations) of the patented technology. 
COUNT THREE
(Infringement of the ’053 Patent)
97. Strava repeats and re-alleges the allegations in the preceding paragraphs as if fully 
set forth herein. 
98. On October 3, 2017, the United States Patent and Trademark Office duly and 
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legally issued the ’053 Patent entitled “Generating user preference activity maps.” See Exhibit 3. 
Strava owns all right, title, and interest in and to the ’053 Patent, including the right to assert all 
causes of action under the ’053 Patent and the right to sue and obtain any remedies for past, present, 
or future infringement.
99. The ’053 Patent is a continuation of the ’651 Patent and claims concrete, 
computer‑implemented pipelines executed by a processor and memory. The asserted claims 
require collecting activities recorded by a plurality of GPS devices; mining those activities 
according to an order associated with device‑type accuracy; aggregating the activities to a base 
map to generate a user‑preference map; and, in the same claimed system, receiving user inputs and 
generating one or more suggested routes between user‑specified endpoints based on that 
user‑preference map. These claim‑recited techniques significantly improve the functioning of 
computer systems that process and route over large‑scale geospatial datasets, and they are not 
directed to mere data display.
100. At the time of the invention, the combination of device‑type‑ordered mining with 
edge‑based aggregation and user‑preference‑driven routing—implemented as a 
processor‑configured pipeline with memory storing instructions—was not well‑understood, 
routine, or conventional. The claimed architecture reduces noise, increases the accuracy and 
robustness of the map‑derived statistics used for routing, and scales computation of route 
candidates across large activity corpora. Any contrary contention raises fact issues that cannot be 
resolved on the pleadings.
101. Defendants have directly infringed and continue to directly infringe one or more 
claims of the ’053 Patent, including at least Claims 1, 3, 9, 10, and 21 (the “Asserted ’053 Claims”), 
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by making, using, offering to sell, selling, and importing products and services that practice the 
patented technology in the United States, without license or authority, including Garmin Connect 
and Garmin devices—such as Edge cycling computers and Forerunner, Fenix, and Epix watches—
that implement Trendline/Popularity routing, heatmaps, Courses, and related features (the “’053 
Accused Instrumentalities”).
102. By way of non‑limiting example, the ’053 Accused Instrumentalities collect and 
prioritize activities recorded on different device types; aggregate those traversals to a base map to 
generate a user‑preference map with edge‑level metadata; receive user inputs specifying endpoints 
and route preferences; and generate one or more suggested routes between those endpoints based 
at least in part on the user‑preference map, presenting the route candidates to the user. These 
implementations satisfy the limitations of at least the Asserted ’053 Claims.
103. Defendants directly infringe by performing one or more steps of the asserted 
methods on their servers and devices; alternatively, any steps performed by end users are 
performed under Defendants’ direction or control and/or as part of a joint enterprise, including 
because Defendants condition participation in and benefits from the accused features on 
performance of those steps and dictate the manner or timing of such performance through device 
firmware, defaults, and instructions.
104. The following screenshots from Defendants’ publicly available pages and manuals 
are illustrative of the accused functionality:
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105. To the extent any limitation is not literally present, infringement occurs under the 
doctrine of equivalents because the ’053 Accused Instrumentalities perform substantially the same 
function, in substantially the same way, to achieve substantially the same result.
106. Defendants also induce and contribute to infringement of the Asserted ’053 Claims, 
with knowledge of the ’053 Patent at least as of July 25, 2025, and specific intent that customers 
use the ’053 Accused Instrumentalities in an infringing manner. Defendants’ affirmative acts 
include, by way of example, publishing user guides, support articles, marketing pages, and 
in‑device prompts instructing users how to enable and use Trendline/Popularity routing, heatmaps, 
Courses, and related features.
107. Defendants’ infringement has been and continues to be willful. Despite their 
knowledge of the ’053 Patent and their infringement since at least July 25, 2025, Defendants have 
intentionally or recklessly continued their infringing acts, making this an exceptional case and 
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warranting enhanced damages and reasonable attorneys’ fees under 35 U.S.C. §§ 284–285. 
108. Plaintiff has complied with 35 U.S.C. § 287. The Asserted ’053 Claims include 
method claims that are not subject to § 287’s marking requirement. To the extent § 287 applies to 
any asserted system or computer‑readable‑medium claims, Plaintiff has not made, sold, or 
authorized the sale of any patented articles practicing those claims in the United States prior to 
suit, or, alternatively, Defendants had actual notice of the ’053 Patent and the basis for 
infringement no later than July 25, 2025; therefore, § 287 does not bar recovery of pre‑suit 
damages.
109. Strava has suffered and will continue to suffer damages as a result of Defendants’ 
infringement of the ’053 Patent. Strava is entitled to recover damages adequate to compensate for 
such infringement, including no less than a reasonable royalty and, where proven, lost profits, 
together with pre‑ and post‑judgment interest and costs. Monetary relief alone is inadequate; 
Garmin’s continued infringement causes irreparable harm, including loss of network effects, 
erosion of platform differentiation and goodwill, and brand loyalty. There is a causal nexus 
between the accused mapping/routing implementations and consumer demand for Garmin’s 
products and services. Strava is therefore entitled to a permanent injunction prohibiting Defendants 
from making, using, offering to sell, selling, or importing the accused implementations (and any 
colorable variations) of the patented technology. 
COUNT FOUR
(Breach of Contract)
110. Strava repeats and re-alleges the allegations in the preceding paragraphs as if fully 
set forth herein. 
111. The MCA is a valid, enforceable contract between Strava and Garmin Ltd. Strava 
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performed or was excused from performing all obligations.
112. The MCA grants Garmin a limited, revocable, non‑sublicensable license to Strava 
Segments “solely” to incorporate Strava Segment functionality into compatible Garmin devices 
and “solely” as required to fulfill the Strava‑built user experience described in Exhibit A for Strava 
users. All other rights were reserved to Strava and the MCA explicitly stated that Garmin could 
not “modify, adapt, translate, create derivative works of, reverse engineer, decompile, or 
disassemble” Strava Segments.
113. Garmin breached the MCA by, among other things: (a) building, branding, 
marketing, and distributing Garmin segments beyond the Strava‑built user experience and to 
non‑Strava users; (b) adapting and using Strava Segments and related know‑how to develop and 
deploy Garmin Segments; (c) copying, modifying, and distributing Strava Segments or portions 
thereof outside the scope of the limited license; and (d) failing to comply with Exhibit A’s 
constraints on user‑choice and non‑commingling.
114. Garmin’s breaches caused Strava harm, including lost revenue and market 
opportunities, erosion of Strava’s competitive differentiation, and unjust gains to Garmin. The 
MCA provides a carve‑out from damages limitations for breaches of the Section 8(E) restrictions, 
and provides for prevailing‑party attorneys’ fees. Strava seeks the full measure of contractual 
damages and equitable relief, including injunctive relief compelling Garmin’s compliance with the 
MCA.
115. Garmin’s breaches also conferred unjust benefits on Garmin, including accelerated 
development and deployment of Garmin Segments and popularity-based routing built on Strava￾provided materials and know-how, warranting disgorgement as permitted by law and equity.
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COUNT FIVE
(Breach of the Implied Covenant of Fair Dealing) 
116. Strava repeats and re-alleges the allegations in the preceding paragraphs as if fully 
set forth herein. 
117. The MCA is a valid and enforceable contract that governs the parties’ collaboration 
and is subject to New York law. Under New York law, every contract includes an implied covenant 
of good faith and fair dealing that prohibits a party from doing anything that would destroy or 
injure the other party’s right to receive the benefits of the contract. 
118. The MCA allocates to Strava the right to control the Strava‑built segment 
experience for Strava users on compatible Garmin devices, reserves to Strava all rights not 
expressly granted, and restricts Garmin’s use of Strava Segments and related materials to what is 
required to implement the Exhibit A, Strava‑built user experience. The benefits of this bargain to 
Strava include, among other things, maintaining Strava’s control and differentiation of the segment 
experience; protecting Strava’s segment technology and goodwill; and avoiding the unauthorized 
use of collaboration access to replicate Strava functionality in Garmin’s own stack. 
119. Under the MCA, Garmin possessed some degree of discretion in implementing 
device features and integrations. However, Garmin exercised that discretion in bad faith and 
contrary to Strava’s justified expectations by, among other things: (a) using collaboration access 
to implement substantially similar segment functionality in Garmin‑branded software and device 
firmware outside the Strava‑built experience and for non‑Strava users; (b) surfacing segment 
competition and leaderboards in Garmin Connect and on devices in ways that bypass, dilute, or 
undermine the Exhibit A constraints and Strava’s control; and (c) leveraging Strava‑provided 
materials and know‑how for purposes not required to implement the Exhibit A experience.
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120. Even if Garmin’s conduct were found not to violate any single express provision of 
the MCA, Garmin’s course of dealing and use of the collaboration access to supplant Strava’s 
segment experience and divert the benefits of the bargain to itself breached the implied covenant 
by depriving Strava of its fruits under the MCA. 
121. As a direct and proximate result of Garmin’s breach of the implied covenant, Strava 
has suffered damages, including lost revenue and business opportunities, erosion of competitive 
differentiation and network effects, harm to goodwill, and unjust gains to Garmin. Strava is entitled 
to compensatory damages, equitable relief, and attorneys’ fees pursuant to the MCA. 
122. This claim is pled in the alternative to, and not as a duplication of, Strava’s express 
breach claim. To the extent the trier of fact concludes that Garmin did not breach any express 
provision of the MCA, Garmin’s conduct nonetheless breached the implied covenant under New 
York law.
FEES AND COSTS
123. To the extent that Defendants’ willful and deliberate infringement or litigation 
conduct supports a finding that this is an “exceptional case,” an award of attorney’s fees and 
costs to Strava is justified pursuant to 35 U.S.C. § 285. 
PRAYER FOR RELIEF
WHEREFORE, Strava respectfully requests that the Court enter judgment and order: 
A. that Defendants have infringed the ’922, ’651, and ’053 Patents; 
B. that Defendants’ infringement has been and is willful; 
C. awarding damages adequate to compensate Strava for Defendants’ infringement, 
with pre‑ and post‑judgment interest, and trebling for willfulness under 35 U.S.C. § 284;
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D. permanently enjoining Defendants, their officers, agents, servants, employees, 
attorneys, and those in active concert or participation with them, from further infringement of the 
Asserted Patents, including but not limited to permanently enjoining any and all sales of Garmin 
hardware with functionality that infringes on the Asserted Patents, including but not limited to 
permanently enjoining any and all sales of Garmin hardware with functionality that infringes on 
the Asserted Patents and the use of infringing software (e.g., Garmin Connect); 
E. awarding Strava its contract damages, including those available for breaches of the 
MCA’s Section 8(E) restrictions, and equitable relief; 
F. awarding Strava its costs and reasonable attorneys’ fees under 35 U.S.C. § 285 and 
the MCA; and
G. awarding such other and further relief as the Court deems just and proper. 
DEMAND FOR JURY TRIAL
Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plaintiff hereby demands a 
jury trial on all issues triable by jury.
Dated: September 30, 2025 Respectfully submitted,
/s/ Joel D. Sayres
Joel D. Sayres (#41926)
Faegre Drinker Biddle & Reath LLP
1144 15th Street, Suite 3400 
Denver. CO 80202 
Tel.: (303) 607-3500 
Fax: (303) 607-3600 
joel.sayres@faegredrinker.com 
Attorneys for Plaintiff Strava, Inc.
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Of Counsel:
Ryan Wong
Andrew Bruns
J.D. Schneider
Keker, Van Nest, & Peters LLP
633 Battery Street
San Francisco, CA 94111-1809
Tel: (415) 391-5400 
Fax: (415) 397-7188
rwong@keker.com
abruns@keker.com
jschneider@keker.com
Plaintiff’s Address:
181 Fremont Street
San Francisco, CA 94105
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