IP Law Daily, PATENT—E.D.N.Y.: Treadmill maker defeats inventor’s claims over curved treadmill patent and settlement agreement, (Oct 27, 2026)

By Mandavi Singh, LL.M.

The inventor could enforce the assigned design patent without being named as its inventor, and the settlement agreement did not require the manufacturer to correct inventorship.

A treadmill manufacturer prevailed in a longstanding dispute with an inventor who claimed the company appropriated his curved, non-motorized treadmill design and later breached a settlement agreement by refusing to recognize him as an inventor. The federal district court in New York granted summary judgment to Woodway USA, Inc. on all claims brought by an individual, finding that the settlement transferred patent ownership without requiring correction of inventorship. The court also found that the individual breached the agreement’s confidentiality provision but rejected Woodway’s request for specific performance. Separately, it dismissed claims against Woodway’s president for lack of personal jurisdiction (Astilean v. Woodway USA, Inc., No. 2:22-cv-07993-EK-JAM (E.D.N.Y. Oct. 22, 2026)).

Background. Aurel Astilean is the president and sole member of Speedfit LLC, a company that sells curved, non-motorized treadmills. Woodway manufactures and sells similar exercise equipment. The dispute began when Astilean alleged he shared a treadmill prototype with Woodway about 18 years earlier, after which the manufacturer patented the design without recognizing or compensating him. Woodway disputed those allegations.

Astilean and Speedfit initiated separate lawsuits against Woodway in 2013 and 2017, seeking correction of patent inventorship and asserting related claims, including breach of contract, unjust enrichment, and conversion. The second lawsuit involved several patents, including U.S. Design Patent No. D736,866 (the ’866 design patent), protecting the ornamental design of Woodway’s curved treadmill.

Before trial in the earlier litigation, the parties executed a comprehensive settlement agreement resolving both lawsuits. Woodway agreed to assign the ’866 design patent to Speedfit, including enforcement rights concerning past infringement. The agreement also contained cooperation, confidentiality, non-disparagement, no-challenge, and release provisions intended to prevent renewed disputes over the parties’ respective rights.

Although Woodway completed the patent assignment, Astilean maintained that the cooperation provision obligated the company to identify him as an inventor. He subsequently sued Woodway and Bayerlein for breach of contract, rescission and injunctive relief, including an order preventing Woodway from manufacturing and selling curved treadmills. Woodway brought separate claims alleging breaches of contract, trademark infringement, and unfair competition. The lawsuits were subsequently consolidated.

Patent ownership distinguished from inventorship. Astilean argued that Woodway’s refusal to correct inventorship prevented him from enforcing the assigned patent against third parties. He maintained that the settlement’s cooperation provision required Woodway to undertake additional steps necessary to make the patent enforceable.

Judge Eric Komitee rejected that interpretation, emphasizing the legal distinction between inventorship and ownership.

Citing Beech Aircraft Corp. v. EDO Corp., 990 F.2d 1237 (Fed. Cir. 1993), the court explained that inventorship concerns who created the claimed invention, whereas ownership concerns legal title. Patent owners, including qualifying assignees, can pursue infringement actions without being identified as inventors.

The settlement expressly transferred the design patent and its enforcement rights to Speedfit. Consequently, the court found no additional obligation requiring Woodway to amend the inventorship designation.

The court acknowledged Astilean’s concern that an incorrect inventorship designation could expose the patent to validity challenges. Under Pannu v. Iolab Corp., 155 F.3d 1344 (Fed. Cir. 1998), failure to name an actual inventor can render a patent invalid when established by clear and convincing evidence.

Nevertheless, Woodway assigned the patent on an “as is” basis, without warranties as to validity or enforceability. Astilean therefore accepted the risk that inventorship disputes might complicate future enforcement. The general cooperation provision could not override that express allocation of risk.

His additional allegations of fraudulent concealment and economic duress also failed. Astilean alleged that Woodway concealed its acquisition of another company against which he intended to pursue infringement claims. However, he established no legal duty requiring disclosure. His financial difficulties at the time of settlement likewise did not establish wrongful coercion sufficient to invalidate the agreement.

Settlement breaches examined. Woodway sought summary judgment on allegations that Astilean violated the agreement by challenging its patents, disparaging the company, disclosing confidential settlement terms, and disregarding the release of existing claims.

The court declined to find a breach of the no-challenge provision. Astilean’s statements expressing an intention to contest patent inventorship did not constitute an actual legal challenge. Likewise, allegations made in another proceeding did not amount to a formal challenge to patent validity.

Relying on Diversey Lever, Inc. v. Ecolab, Inc., 191 F.3d 1350 (Fed. Cir. 1999), the court emphasized that contractual surrender of the right to challenge patent validity must be construed narrowly. Statements questioning a patent’s legitimacy outside proceedings seeking invalidation were insufficient to establish a breach.

The court also rejected summary judgment on non-disparagement. Under the applicable New York authorities, statements made during judicial proceedings could not support the contractual claim, and Woodway failed to substantiate allegations about statements supposedly published on Speedfit’s website.

Woodway’s release-based claim likewise failed because expressing an intention to bring future proceedings did not establish a present breach. A release of existing claims also differed from an affirmative covenant not to sue.

However, the confidentiality claim succeeded because Astilean had placed the settlement agreement on a publicly accessible court docket, contrary to its express confidentiality requirements.

Woodway nevertheless failed to establish entitlement to specific performance. The document had already been sealed, and further equitable relief would not reverse its earlier disclosure. The court also noted that contractual declarations of irreparable harm cannot dictate the exercise of judicial discretion.

Claims against company president dismissed. Bayerlein successfully challenged personal jurisdiction. Although he signed the settlement on Woodway’s behalf and allegedly initiated settlement discussions, the court found that his corporate role did not establish personal consent to New York jurisdiction.

The court distinguished New York’s doctrine binding closely related nonsignatories to forum-selection clauses from the constitutional requirements governing personal jurisdiction. Bayerlein’s participation in settlement negotiations, without sufficient personal contacts with New York, did not satisfy due process. His signature in a representative capacity could not automatically subject him to personal jurisdiction under the agreement.

Outcome. The court entered judgment for Woodway on Astilean’s claims for breach of contract, rescission, and injunctive relief. Bayerlein was dismissed from the action, while Woodway prevailed on its confidentiality claim without obtaining specific performance. The court also directed Woodway to explain why judgment should not be entered against it on the remaining contractual claims involving the no-challenge, non-disparagement, and release provisions. Woodway’s separate trademark infringement and unfair competition claims were not decided.

The Case is No. 2:22-cv-07993-EK-JAM.

Judge: Komitee, E.

Attorneys: Aurel A. Astilean, pro se. Kadie M. Jelenchick (Foley & Lardner LLP) for Woodway USA, Inc.

Companies: Woodway USA, Inc.

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