DCT

3:24-cv-03245

Samsung Electronics Corp Ltd v. Oura Health Oy

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:24-cv-03245, N.D. Cal., 05/30/2024
  • Venue Allegations: Venue is alleged to be proper in the Northern District of California because Defendant Ouraring Inc. maintains a principal place of business in San Francisco.
  • Core Dispute: Plaintiff Samsung seeks a declaratory judgment that its forthcoming Galaxy Ring smart ring product does not infringe five patents owned by Defendant Oura related to wearable health-monitoring technology and device construction.
  • Technical Context: The technology at issue involves wearable smart rings that integrate sensors to monitor physiological data, and the software algorithms used to translate that data into actionable health insights for consumers.
  • Key Procedural History: The complaint asserts that an actual controversy exists based on Oura's public statements and a documented pattern of litigation against competitors in the smart ring market. Samsung cites Oura’s lawsuits against *[Oura Health Oy](https://ai-lab.exparte.com/party/oura-health-oy) v. Circular SAS*, Ultrahuman, and RingConn, including an ongoing International Trade Commission (ITC) investigation, as evidence of Oura's intent to enforce its patent portfolio against new market entrants like Samsung.

Case Timeline

Date Event
2013-11-29 Earliest Priority Date for ’147, ’178, ’179 Patents
2015-02-26 Earliest Priority Date for ’429 Patent
2015-08-14 Earliest Priority Date for ’833 Patent
2020-11-24 ’429 Patent Issued
2021-01-19 ’833 Patent Issued
2023-03-07 ’147 Patent Issued
2024-01-09 ’178 Patent Issued
2024-01-09 ’179 Patent Issued
2024-01-17 Samsung Publicly Introduced the Galaxy Ring
2024-05-30 Complaint for Declaratory Judgment Filed
2024-06-15 Expected Mass Production Start for Galaxy Ring (approx.)
2024-08-01 Expected U.S. Sales Start for Galaxy Ring (approx.)

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 10,842,429 - "Method and System for Assessing a Readiness Score of a User"

The Invention Explained

  • Problem Addressed: The patent’s background section states that conventional health-monitoring devices do not provide users with information related to their recovery from mental and physical loads, nor do they offer a "readiness score" to help users manage future challenges (’429 Patent, col. 1:28-34). These devices are described as lacking the capability to analyze a user's historical data in detail or to provide suggestions for improving their state of readiness (’429 Patent, col. 1:35-46).
  • The Patented Solution: The invention provides a method and system for calculating a "readiness score" for a user. The system, which can comprise a ring, a mobile device, and a server, obtains user movement data to distinguish between "activity periods" and "rest periods" (’429 Patent, col. 2:8-21). It then measures biosignals (e.g., heart rate) during rest and determines a "rest summary" and an "activity summary" based on both current and historical data. These summaries are combined to determine a "body response summary," which is then used with a previous body response summary to calculate the final readiness score (’429 Patent, Abstract).
  • Technical Importance: The invention claims to distill complex physiological and activity data into a single, actionable score that quantifies a user’s preparedness for daily activities, thereby overcoming a noted deficiency in prior art devices (’429 Patent, col. 1:41-46).

Key Claims at a Glance

  • The complaint identifies independent claims 1 and 8 as the only independent claims of the patent (Compl. ¶62).
  • Independent Claim 1 (a method) includes the elements of:
    • Obtaining a user's movements and using them to distinguish between an activity period and a rest period.
    • Measuring at least one biosignal during the rest period.
    • Determining a rest summary based on the measured biosignal and a previous biosignal.
    • Determining an activity summary based on obtained movements and previous movements.
    • Determining a body response summary based on the rest and activity summaries.
    • Calculating a readiness score based on the body response summary and a previous body response summary.
  • Independent Claim 8 (a system) includes the elements of:
    • A ring for measuring a user's biosignal.
    • A mobile communication device.
    • Means for measuring user movements.
    • A server configured to perform the analytical steps recited in method claim 1.

U.S. Patent No. 11,868,178 - "Wearable Computing Device"

The Invention Explained

  • Problem Addressed: A related patent notes that many wearable electronics are bulky, intrusive, or uncomfortable for extended periods of daily use, which limits their effectiveness (’147 Patent, col. 1:31-39). The technical challenge is to package a power source, sensors, and processing electronics into the small form factor of a ring.
  • The Patented Solution: The invention describes a specific physical construction for a finger-worn device. It claims a structure comprising a distinct "external housing component" and an "internal housing component" that are coupled together (’178 Patent, cl. 1). A cavity is formed between these two components to house a specially shaped battery and a printed circuit board, which itself extends through different portions of the cavity (’178 Patent, cl. 1).
  • Technical Importance: This claimed two-part housing structure provides a method for arranging the necessary electronic components within the spatial constraints of a ring, potentially enabling a more comfortable and ergonomic wearable device (’147 Patent, col. 1:40-43).

Key Claims at a Glance

  • The complaint identifies independent claim 1 as the only independent claim of the patent (Compl. ¶78).
  • Independent Claim 1 (a device) includes the elements of:
    • An external housing component defining an outer surface.
    • An internal housing component defining an inner surface, which is coupled to the external component.
    • A battery positioned in a cavity formed between the two housing components.
    • The battery is shaped and sized to fit within said cavity.
    • A printed circuit board also disposed between the two housing components.
    • The printed circuit board extends through at least two different portions of the cavity.

U.S. Patent No. 11,868,179 - "Wearable Computing Device"

  • Technology Synopsis: This patent describes the physical construction of a wearable computing device, focusing on the optical sensor package. It claims a housing with an interior and exterior wall that contains light-emitting components for at least two different wavelengths and light-receiving components configured to receive that light.
  • Asserted Claims: Independent claim 1 (Compl. ¶101).
  • Accused Features: The complaint alleges the Galaxy Ring does not infringe because its structure does not meet the "housing comprising an interior wall and an exterior wall" limitation, and its optical system does not include "light-receiving components configured to receive the light associated with the two or more wavelengths" (Compl. ¶¶103, 105).

U.S. Patent No. 10,893,833 - "Wearable Electronic Device and Method for Manufacturing Thereof"

  • Technology Synopsis: This patent relates to the structure and manufacturing of a wearable electronic device. It claims a "body part" with at least one "cavity" formed on its inner surface, where the cavity extends toward the outer surface and contains an electronic part that is thinner than the cavity's depth.
  • Asserted Claims: Independent claim 1 (Compl. ¶117).
  • Accused Features: The complaint argues the Galaxy Ring does not have a cavity on its inner surface or an electronic part arranged within such a cavity as claimed (Compl. ¶¶119, 125).

U.S. Patent No. 11,599,147 - "Wearable Computing Device"

  • Technology Synopsis: This patent is described in the complaint as having claims that are "similar, and for many claim limitations, nearly verbatim, to the claims of the '833 Patent" (Compl. ¶135). The claims relate to a C-shaped body part with an internal cavity for housing electronics.
  • Asserted Claims: Independent claims 1, 10, 18, and 21 (Compl. ¶137).
  • Accused Features: Samsung alleges its Galaxy Ring does not meet the structural limitations, including the requirements for a cavity on the inner surface of a body part, an electronic part arranged therein, and a "C-shaped body part made of a material" (Compl. ¶¶139, 145, 149).

III. The Accused Instrumentality

Product Identification

  • The Samsung Galaxy Ring and the associated Samsung Health App (Compl. ¶¶12, 39).

Functionality and Market Context

  • The Galaxy Ring is a finger-worn electronic device designed to monitor physiological metrics including heart rate, sleep, movement, and blood oxygen (Compl. ¶12). It contains electronics, sensors, LEDs, and a battery (Compl. ¶38). The data is synchronized with the Samsung Health App, which calculates and displays an "Energy Score" based on factors such as sleep, activity, and heart rate (Compl. ¶39). The complaint positions the Galaxy Ring as an expansion of Samsung's wearables portfolio, building on its existing health and fitness technology (Compl. ¶12). The image provided in the complaint shows the Samsung Health App displaying a numerical "Energy score" with an accompanying qualitative assessment, such as "Well rested" (Compl. p. 16).

IV. Analysis of Infringement Allegations

Samsung’s complaint outlines its arguments for non-infringement rather than alleging infringement. The following tables summarize the core elements at issue, with the "Alleged Infringing Functionality" column describing the Galaxy Ring features that Oura would likely target in a counterclaim, based on the complaint's narrative.

U.S. Patent No. 10,842,429 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
determining a body response summary based on the rest summary and the activity summary The Samsung Health App's "Energy Score" algorithm, which processes sleep (rest) and activity data. ¶39, ¶64 col. 2:1-3
calculating a readiness score based on the body response summary and a previous body response summary... The final calculation step of the "Energy Score" feature in the Samsung Health App. ¶39, ¶66 col. 2:3-6

Identified Points of Contention

  • Algorithmic Questions: Samsung’s primary argument is that its "Energy Score" algorithm is functionally different from the patented method. It alleges that the Galaxy Ring "does not calculate a body response summary based on determined values for a rest summary and an activity summary" (Compl. ¶64). This raises the question of whether Samsung's algorithm omits the specific intermediate "body response summary" step required by the claim, even if it produces a similar final output.
  • System Architecture Questions: For system claim 8, Samsung contends that its product "does not use a server" to perform the claimed functions of determining summaries or calculating the final score (Compl. ¶68). The key question for the court will be where the specific computational steps of the "Energy Score" feature are performed and whether that architecture falls within the scope of the claim's "server configured to..." limitation.

U.S. Patent No. 11,868,178 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
an external housing component defining an outer circumferential surface... The outer structure of the physical Galaxy Ring device. ¶38, ¶80 col. 45:67-46:1
an internal housing component defining an inner circumferential surface... coupled with the external housing component The inner structure of the physical Galaxy Ring device. ¶38, ¶82 col. 46:2-6
a battery positioned within a cavity formed between the internal housing component and the external housing component The battery and its placement within the Galaxy Ring's body. ¶38, ¶84 col. 46:10-13
a printed circuit board disposed between the internal housing component and the external housing component The printed circuit board and its placement within the Galaxy Ring's body. ¶38, ¶88 col. 46:21-23

Identified Points of Contention

  • Structural Questions: Samsung's non-infringement arguments for the ’178 patent, as well as the related ’179, ’833, and ’147 patents, center on a fundamental assertion: that the Galaxy Ring does not have the specific multi-part construction recited in the claims. Samsung alleges its device lacks a distinct "external housing component" coupled to an "internal housing component" (Compl. ¶¶80, 82). This suggests the Galaxy Ring may have a more unitary or differently constructed body. The infringement analysis will depend on whether the Galaxy Ring's physical structure can be interpreted as having the claimed components.
  • Scope Questions: The dispute raises a key claim construction question: What constitutes an "internal housing component" versus an "external housing component," and what does it mean for them to be "coupled"? The court will need to determine if these terms require separate, physically distinct pieces or if different sections of a single integrated structure could satisfy the limitations.

V. Key Claim Terms for Construction

For the ’429 Patent

  • The Term: "body response summary"
  • Context and Importance: This term describes an intermediate data product that is a prerequisite for calculating the final "readiness score" in claim 1. Samsung's non-infringement defense is predicated on its allegation that its "Energy Score" algorithm does not generate this specific summary (Compl. ¶64). The construction of this term may be dispositive for the ’429 patent.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent states the term encompasses "physical and mental recovery from various kinds of stress" and summarizes "effects of earlier physical activity, previous night's sleep, and body responses measured lately" (’429 Patent, col. 4:41-49). This language could support a view that any algorithmic combination of rest and activity data into a unified metric meets the definition.
    • Evidence for a Narrower Interpretation: The claim language requires the summary to be based specifically "on the rest summary and the activity summary" (’429 Patent, cl. 1). This suggests a specific two-input calculation. Practitioners may focus on whether the specification discloses a particular formula or method for this combination that is absent from the accused product.

For the ’178 Patent

  • The Term: "internal housing component" and "external housing component"
  • Context and Importance: Samsung alleges its Galaxy Ring does not have these distinct components (Compl. ¶¶80, 82). The viability of this defense for the ’178 patent and other structural patents-in-suit depends entirely on whether the Galaxy Ring’s body is found to fall outside the scope of this two-component limitation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent does not appear to provide an explicit definition distinguishing the two components. Oura may argue that different regions of a single, complex part could be considered separate "components" for the purposes of the claim, especially if they perform distinct functions (e.g., one part provides the outer cosmetic surface while another provides internal mounting points).
    • Evidence for a Narrower Interpretation: The claim requires the two components to be "coupled," which may imply they are initially separate pieces that are joined during manufacturing (’178 Patent, cl. 1). The specification of a related patent refers to the challenges of devices with a "two part cover," suggesting the inventors contemplated physically separate pieces (’833 Patent, col. 1:36-39). Samsung may argue that an integrated, unitary body does not contain two distinct, "coupled" components.

VI. Other Allegations

  • Indirect Infringement: Samsung preemptively denies all forms of indirect infringement. Its primary argument is that because there is no direct infringement of any claim, there can be no secondary liability for induced or contributory infringement (Compl. ¶¶70-71, 92-93).
  • Willful Infringement: Willfulness is not alleged in the complaint, as Samsung is the plaintiff. However, the complaint extensively details Oura's public statements and litigation activity, which Oura could potentially use in a counterclaim to assert that Samsung had pre-suit knowledge of the patents-in-suit. Samsung's filing of this declaratory judgment action may be a strategic measure to counter any future allegations of willful infringement.

VII. Analyst’s Conclusion: Key Questions for the Case

  1. Justiciability: A threshold legal question will be whether Samsung has successfully pleaded an "actual and justiciable controversy" sufficient for a declaratory judgment action, given that the Galaxy Ring is not yet on the market. The case may turn on whether Oura's history of litigation and its CEO's public statements regarding its IP portfolio create an imminent threat of suit that justifies Samsung's preemptive filing.
  2. Algorithmic Equivalence: For the ’429 patent, the central dispute will be technical and definitional: does Samsung's "Energy Score" function in the same way as the claimed method? A key evidentiary question will be whether Samsung’s algorithm calculates an intermediate "body response summary" as required by the claims, or if it uses a non-infringing method to arrive at a similar user-facing score.
  3. Structural Scope: For the four hardware patents (’178, ’179, ’833, ’147), the case will likely focus on claim construction. The core issue is one of definitional scope: can the claims, which recite multi-part structures like "internal" and "external" housings or "cavities" on an "inner surface," be construed to cover the physical design of the Samsung Galaxy Ring?