DCT
2:25-cv-09685
Eight Sleep Inc v. Orion Longevity Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Eight Sleep Inc. (Delaware)
- Defendant: Orion Longevity Inc. (Delaware) and Blue Fuzion Group Ltd. (Hong Kong)
- Plaintiff’s Counsel: Wilson Sonsini Goodrich & Rosati
- Case Identification: 2:25-cv-09685, C.D. Cal., 10/09/2025
- Venue Allegations: Venue for Orion Longevity Inc. is based on its alleged transaction of business and regular and established place of business within the district. Venue for Blue Fuzion Group Ltd., a foreign entity, is asserted as proper in any judicial district.
- Core Dispute: Plaintiff alleges that Defendants’ Orion Sleep System, a smart mattress cover, infringes three patents related to gathering biometric data and regulating bed temperature to improve sleep.
- Technical Context: The technology at issue falls within the "sleep fitness" market, involving systems that use embedded sensors to monitor a user's biological signals and dynamically adjust the thermal environment of a bed.
- Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or specific prosecution history related to the asserted patents.
Case Timeline
| Date | Event |
|---|---|
| 2014-06-05 | Earliest Priority Date for ’461, ’240, and ’339 Patents |
| 2014-01-01 | Eight Sleep Founded |
| 2019-01-01 | Eight Sleep Releases First "Eight Sleep Pod" |
| 2020-10-06 | U.S. Patent No. 10,792,461 Issues |
| 2025-06-12 | Orion Longevity Inc. Founded |
| 2025-07-29 | U.S. Patent No. 12,370,339 Issues |
| 2025-08-05 | U.S. Patent No. 12,377,240 Issues |
| 2025-10-09 | Complaint Filed |
| 2025-12-01 | Orion Sleep System Expected Delivery Start |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,792,461 - "Methods and Systems for Gathering and Analyzing Human Biological Signals," Issued October 6, 2020
The Invention Explained
- Problem Addressed: The patent's background describes conventional sleep aids, such as electric blankets, as rudimentary devices that require manual operation and offer no functionality beyond simple warming ('461 Patent, col. 1:59-2:4). It also notes the different physiological stages of sleep and the disorientation that can result from being woken during a deep sleep phase ('461 Patent, col. 1:31-58).
- The Patented Solution: The invention is a system that uses sensors embedded in a bed device to gather a user's biological signals (e.g., heart rate, temperature) and a processor to analyze these signals ('461 Patent, Abstract). Based on this analysis, the system can regulate the bed's temperature and control other home appliances. A core feature is the ability to distinguish between multiple users in the same bed and apply personalized settings to each ('461 Patent, col. 7:5-10; FIG. 1).
- Technical Importance: This technology represents a shift from static or manually controlled sleep environments to an automated, responsive system that personalizes thermal conditions based on real-time physiological feedback ('461 Patent, col. 2:7-24).
Key Claims at a Glance
- The complaint asserts at least exemplary independent Claim 1 (Compl. ¶36).
- The essential elements of Claim 1 include:
- A system for regulating the temperature of a bed device.
- At least one sensor within the bed device configured to detect a user's biological signal.
- A temperature control device coupled to the bed device to regulate its temperature.
- A processor coupled to the sensor and temperature control device, which is configured to:
- Identify the user from a plurality of users based on the biological signal.
- Regulate the temperature based on that user's identity.
- A stored set of biological signal data used by the processor to identify each user.
- The complaint states infringement of "one or more claims" of the patent, reserving the right to assert claims beyond Claim 1 (Compl. ¶¶20, 36).
U.S. Patent No. 12,377,240 - "Methods and Systems for Gathering and Analyzing Human Biological Signals," Issued August 5, 2025
The Invention Explained
- Problem Addressed: Similar to the '461 Patent, this patent addresses the limitations of non-responsive sleep environments ('240 Patent, col. 1:40-2:10). It specifically targets the scenario where two individuals sharing a bed have different thermal comfort needs that cannot be met by a single-zone temperature system.
- The Patented Solution: The patent describes a method and system for dual-zone temperature control. The system obtains separate biological signals from a first user in a first zone and a second user in an adjacent second zone ('240 Patent, Claim 1). It then generates distinct control signals to heat or cool each zone to a different temperature, with each temperature being based on the respective user's "user-specified preference" ('240 Patent, Claim 1).
- Technical Importance: The invention provides a technical framework for creating two independent "microclimates" within a single bed, allowing for simultaneous, personalized temperature regulation for two co-habitants ('240 Patent, col. 6:58-62).
Key Claims at a Glance
- The complaint asserts at least Claim 29, a system claim that depends on method Claim 1 (Compl. ¶¶50-52).
- The essential elements of the base method (Claim 1) include:
- Obtaining a first biological signal from a first user in a first zone of a bed device.
- Obtaining a second biological signal from a second user in an adjacent second zone.
- Generating control signals with separate instructions to set the temperatures of the first and second zones to different respective temperatures.
- The instruction for each zone is based at least in part on a "user-specified preference" of the user in that zone.
- Sending the signals to a temperature control device to heat or cool the zones differently.
- Asserted Claim 29 claims a sleep system with a processor and memory storing instructions to implement the method of Claim 1 (Compl. ¶52).
U.S. Patent No. 12,370,339 - "Methods and Systems for Gathering and Analyzing Human Biological Signals," Issued July 29, 2025
- Technology Synopsis: This patent addresses static sleep environments by teaching a method for dynamic, multi-stage temperature control. The invention involves obtaining a first biological signal (e.g., user presence) to turn a bed device on to an initial temperature, and later, while the device is on, obtaining a second, different biological signal (e.g., indicating a change in sleep stage) to adjust the bed to a new temperature ('339 Patent, Claim 1).
- Asserted Claims: At least Claim 29, a system claim which depends on method Claim 1 (Compl. ¶¶65-67).
- Accused Features: The complaint alleges that the Orion Sleep System's "AI powered thermoregulation" and its feature of maintaining a "perfect temperature through all sleep stages" infringe by determining a user's "thermoregulation set point" and using technology that "kicks in to cool or heat your body to your personal perfect temperature" during the night (Compl. ¶¶70, 29).
III. The Accused Instrumentality
Product Identification
- The "Orion Sleep System," which includes a "Smart Cover" mattress pad, a "Control Tower" base unit, and a "Smart Mode" software feature (Compl. ¶27).
Functionality and Market Context
- The Orion Sleep System is marketed as a product that "analyzes your sleep patterns to maintain your ideal temperature all night" (Compl. ¶27). Its functions allegedly include monitoring a user's biological signals via "embedded smart sensors," providing "dual-zone temperature control" for two sleepers, and using "AI powered thermoregulation" to adjust temperature based on sleep stage (Compl. ¶29). An image from Orion's website shows a checkout page with an option to deliver to the United States, indicating the product is offered for sale to U.S. customers (Compl. ¶30).
- The complaint alleges that Defendants position the Accused Product in direct competition with Plaintiff's products, citing a side-by-side feature comparison chart from Orion's website (Compl. ¶31).
IV. Analysis of Infringement Allegations
'461 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| at least one sensor that is a part of said bed device... configured to detect a biological signal of a user... | The Orion "Smart Cover" contains "Embedded smart sensors" that "track your sleep pattern and biometrics." An image shows these sensors are part of the bed pad. | ¶39 | col. 5:9-14 |
| a temperature control device operatively coupled to said portion of said bed device... configured to regulate said temperature... | The "Control Tower" is described as a hydro-cooling unit that works with the "Smart Cover" to adjust and maintain the user's ideal temperature. | ¶40 | col. 5:31-33 |
| a processor... configured to identify said user from a plurality of users... based on said biological signal, and regulate said temperature... based on said user's identity... | The system provides "Personalized cooling for each sleeper" and "Dual-zone temperature control," which allegedly requires identifying each user to apply their distinct settings. The "Orion App" is identified as the processor. | ¶¶41-42 | col. 7:5-10 |
| wherein biological signal data to identify each user of said plurality of users is stored for access by said processor... | The system is marketed as "Personalized to you based on your sleep data," suggesting that identifying user data is stored and accessed by the system to provide personalization. | ¶43 | col. 8:28-34 |
- Identified Points of Contention:
- Scope Questions: A potential point of contention may be the scope of the term "identify said user." The defense may argue that a system assigning different settings to the left and right sides of a bed does not "identify" a user in the manner required by the claim, which suggests a more specific, biometric-based differentiation between individuals.
- Technical Questions: The complaint alleges the system identifies users based on biological signals, but does not specify which signal (e.g., heart rate variability, weight, motion pattern) is used for identification. An evidentiary question will be what technical mechanism the Accused Product uses to distinguish between users and whether it aligns with the patent's teachings.
'240 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| obtaining at least one first biological signal from a first user... on a first zone of the bed device; | The Orion system's "embedded sensors sense where you are in your sleep cycle" and provide "Personalized cooling for each sleeper," which requires obtaining a biological signal from the first user in their zone. | ¶54 | col. 8:37-41 |
| obtaining at least one second biological signal from a second user... on a second zone of the bed device... | The "Dual-zone temperature control" functionality for two partners necessarily requires obtaining a biological signal from the second user in the adjacent zone. | ¶55 | col. 8:37-41 |
| generating a plurality of control signals... comprising (1) a first instruction to set the temperature of the first zone... and (2) a second instruction to set the temperature of the second zone... wherein the first instruction is based at least in part on a first user-specified preference... | The Accused Product allegedly "adjusts temperatures for the two users of the Accused Product, independently, based on each user's specified preferences." A marketing image illustrates this dual-zone functionality. | ¶56 | col. 8:7-14 |
| sending the plurality of control signals... such that the first and second zones are heated or cooled differently... | The system is advertised as allowing "separate sleep climates for you and your partner," demonstrating that the two zones are controlled to have different temperatures. | ¶57 | col. 6:58-62 |
- Identified Points of Contention:
- Scope Questions: The claim requires temperature settings to be based on a "user-specified preference." A central question may be whether the Accused Product's "AI-powered thermoregulation" relies on user specifications to a degree that meets this limitation, or if its automated adjustments are primarily system-determined, a potential falling outside the claim's scope.
- Technical Questions: What evidence does the complaint provide that the control signals are generated "in response to" the obtained biological signals from both users, as required by the claim? The infringement analysis will depend on demonstrating the technical link between the sensor data from each user and the corresponding temperature adjustments for that user's zone.
V. Key Claim Terms for Construction
"identify said user" ('461 Patent, Claim 1)
- Context and Importance: This term is critical because infringement of the '461 Patent hinges on whether the Accused Product does more than just apply settings to a location (e.g., the left side of the bed). The definition will determine if a biometric-based recognition of a specific person is required.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states that the system can identify a user based on "heart rate, breathing rate, body motion, or body temperature," alone or in combination ('461 Patent, col. 7:6-10). This list of diverse signals may support a broader interpretation that any method of reliably distinguishing between the two occupants meets the "identify" requirement.
- Evidence for a Narrower Interpretation: The claim requires that "biological signal data to identify each user... is stored for access by said processor" ('461 Patent, col. 20:2-4). This language suggests that the stored data itself contains identifying biometric information, pointing toward a narrower construction that requires a form of biometric authentication rather than simple positional tracking.
"user-specified preference" ('240 Patent, Claim 1)
- Context and Importance: The infringement theory for the '240 Patent relies on temperature adjustments being based on this user input. Practitioners may focus on this term because the accused "AI-powered" functionality could be argued to operate independently of any specific user preference.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification provides an example where "the desired temperature may be specified by the user" ('240 Patent, col. 8:14-15). This simple language could support an interpretation where any initial user input, such as selecting a general goal (e.g., "stay cool") or a baseline temperature, qualifies as a "specified preference" that the system then uses for its algorithm.
- Evidence for a Narrower Interpretation: The term "specified" suggests a concrete, explicit input from the user. A defendant may argue that this requires more than a general setting, such as a user-defined temperature schedule or a precise target temperature, and that an AI's autonomous decisions do not meet this limitation even if they originate from a vague user goal.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement for all asserted patents. The factual basis is that Defendants allegedly provide marketing materials, user guides, and product specifications that instruct and encourage customers to use the Orion Sleep System in a manner that directly infringes the patents' claims (Compl. ¶¶44, 59, 76).
- Willful Infringement: Willfulness is alleged for all asserted patents. The complaint bases this on a theory of willful blindness, asserting that a reasonable competitor would have investigated Eight Sleep's patent portfolio before launching a directly competing product and advertising it with a side-by-side comparison chart (Compl. ¶33). The complaint also establishes a basis for post-suit willfulness by stating Defendants have actual knowledge of the patents no later than the date of service (Compl. ¶¶46, 61, 78).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "identify said user," which is tied to stored biological data, be construed to cover a system that assigns settings to a physical location (e.g., the 'left side'), or does it require a more robust biometric recognition that distinguishes between specific individuals?
- A key evidentiary question will be one of operational control: does the accused "AI-powered thermoregulation" system function based on a "user-specified preference" as required by the claims, or is there a fundamental mismatch in technical operation where the system's algorithmic decisions supersede any direct user specification?
- The case may also present a question of pre-suit knowledge: did the act of creating and publishing a direct product comparison chart create an obligation for Defendants to investigate Plaintiff's patent portfolio, sufficient to support a finding of willful blindness if they failed to do so?