DCT

1:25-cv-00945

BTL Industries Inc v. Your Sculpt Studio LLC

I. Executive Summary and Procedural Information

Parties & Counsel:
- Plaintiff: BTL Industries, Inc. (Delaware)
- Defendant: Your Sculpt Studio LLC (Washington, D.C.)
- Plaintiff’s Counsel: Patterson Intellectual Property Law, P.C.
Case Identification: 1:25-cv-00945, D.D.C., 03/31/2025
Venue Allegations: Venue is alleged to be proper as Defendant maintains its principal place of business in the District of Columbia.
Core Dispute: Plaintiff alleges that Defendant’s non-invasive body and facial contouring services, which use devices referred to as "knockoffs," infringe patents related to electromagnetic and radiofrequency aesthetic treatments.
Technical Context: The technology involves the application of controlled electromagnetic fields or a combination of radiofrequency and electrical currents to stimulate muscles and treat tissue for aesthetic body and facial sculpting.
Key Procedural History: The complaint alleges that Plaintiff sent Defendant a demand letter on September 27, 2024, followed by subsequent communications, which may serve as a basis for pre-suit knowledge in the context of willfulness allegations.

Case Timeline

Date	Event
2016-07-01	’634 Patent - Earliest Priority Date
2018-06-01	Plaintiff launches EMSCULPT® device
2019-11-19	’634 Patent - Issue Date
2020-05-04	’255 Patent - Earliest Priority Date
2023-06-20	’255 Patent - Issue Date
2024-09-27	Plaintiff sends demand letter to Defendant
2025-03-31	Complaint Filing Date

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

U.S. Patent No. 10,478,634 - “Aesthetic Method of Biological Structure Treatment by Magnetic Field”

Patent Identification: U.S. Patent No. 10,478,634, “Aesthetic Method of Biological Structure Treatment by Magnetic Field,” issued November 19, 2019.
The Invention Explained:
- Problem Addressed: The patent’s background section notes that common non-invasive aesthetic treatments based on mechanical or electromagnetic waves carry risks such as overheating, non-homogenous results, or are unable to effectively provide muscle shaping and toning (’634 Patent, col. 2:15-32). Existing magnetic methods are described as having limited parameters and low efficiency (’634 Patent, col. 2:33-37).
- The Patented Solution: The invention proposes a method of using a time-varying magnetic field with a high magnetic flux density to induce strong muscle contractions, thereby remodeling biological structures for aesthetic improvement (’634 Patent, col. 3:12-21, Abstract). The method is intended to achieve effects like muscle toning and shaping that are more efficient and significant than what is possible with conventional treatments or voluntary exercise (’634 Patent, col. 19:20-24).
- Technical Importance: The technology aims to provide a non-invasive method for achieving supramaximal muscle contractions, which can remodel muscle and surrounding tissue for aesthetic body contouring with improved results in shorter time periods (Compl. ¶22).
Key Claims at a Glance:
- The complaint asserts at least independent claim 1 (Compl. ¶47).
- Essential elements of independent claim 1 include:
  - A method for toning muscles in a patient using time-varying magnetic fields.
  - Placing a first applicator with a magnetic field generating coil in contact with the patient's skin or clothing at an abdomen or a buttock.
  - Coupling the applicator to the patient with an adjustable flexible belt.
  - Providing energy to the coil to generate a time-varying magnetic field.
  - Applying a magnetic fluence of 50 T·cm² to 1,500 T·cm² to the body region.
  - Wherein the magnetic field has a magnetic flux density sufficient to cause a muscle contraction.
- The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 11,679,255 - “Device and Method for Unattended Treatment of a Patient”

Patent Identification: U.S. Patent No. 11,679,255, “Device and Method for Unattended Treatment of a Patient,” issued June 20, 2023.
The Invention Explained:
- Problem Addressed: The patent identifies a challenge in providing unattended aesthetic treatments to uneven or rugged anatomical areas, such as the face. Manually controlled devices depend on operator skill and risk non-homogenous treatment, while existing unattended devices like LED masks are too low-power for significant thermal rejuvenation and do not conform well to individual facial structures (’255 Patent, col. 2:1-25).
- The Patented Solution: The invention describes a device comprising a flexible, adhesive pad designed to conform to a body part like the face (’255 Patent, col. 3:9-13). This pad contains an electrode configured to deliver both radiofrequency energy for tissue heating and pulsed electric current for muscle contraction, with a control unit managing the treatment, enabling an effective and safe unattended procedure on complex surfaces (’255 Patent, Abstract).
- Technical Importance: The patented solution combines thermal and muscle-stimulating energies into a single, unattended, conformable applicator, suggesting a method for achieving reproducible aesthetic results on anatomically complex areas without constant operator manipulation (Compl. ¶25).
Key Claims at a Glance:
- The complaint asserts at least independent claim 16 (Compl. ¶61).
- Essential elements of independent claim 16 include:
  - A device for treating a patient by radiofrequency energy and a pulsed electric current.
  - A flexible pad configured for attachment, comprising a flexible substrate, an electrode coupled to its underside, and an adhesive.
  - Wherein the electrode is configured to contact the body part via the adhesive.
  - Wherein the electrode is configured to apply radiofrequency energy to cause heating.
  - Wherein the electrode is configured to apply pulsed electric current to cause muscle contraction.
  - A control unit configured to control both the radiofrequency energy and the pulsed electric current.
  - Wherein the body part comprises one of a face, a neck, or a submentum.
- The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint identifies two categories of accused instrumentalities: "Body Knockoff Devices" and "Facial Knockoff Devices" (Compl. ¶33). These are used to provide services marketed under names such as "Total Tone," "EmSlim," "EmSlim NEO," and "No-Needle Face Lift" (Compl. ¶3).

Functionality and Market Context

The "Body Knockoff Devices" are alleged to operate by using an applicator containing a magnetic field generating coil, which is held against a patient’s skin with a flexible belt (Compl. ¶43, ¶50). These devices are advertised as generating time-varying magnetic fields to cause intense muscle contractions, with marketing materials claiming "20,000 contractions in each 30 minute session" to "Build Muscle and Burn Fat" (Compl. ¶48; p. 25 screenshot). The complaint includes a promotional image showing an applicator secured by a strap to a patient's abdomen (Compl. ¶33; p. 17 screenshot).
The "Facial Knockoff Devices" are alleged to use a combination of "High-Intensity Facial Electrical Stimulation—or HIFES" and radiofrequency energy to treat facial muscles (Compl. ¶64, ¶41). They are marketed for services like the "‘No-Needle Face Lift’" to "tighten delicate facial muscles while reducing wrinkles" (Compl. ¶64).

IV. Analysis of Infringement Allegations

’634 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A method for toning muscles in a patient using time-varying magnetic fields...	Defendant's services are advertised to "Sculpt & Tone Your Muscles" and "Build Muscle and Burn Fat," allegedly by using time-varying magnetic fields.	¶48	col. 3:45-54
placing a first applicator comprising a magnetic field generating coil in contact with a patient's skin or clothing at a body region of the patient, wherein the body region is an abdomen or a buttock;	The accused devices allegedly include an applicator with a magnetic field generating coil that is placed on a patient's abdomen or buttocks during treatment.	¶49	col. 18:8-14
coupling the first applicator to the patient with an adjustable flexible belt so that the belt holds the first applicator to the patient's skin or clothing;	Promotional materials allegedly depict the accused device's applicator being attached to patients using an adjustable flexible belt. A provided image shows a strap holding an applicator in place (p. 26 screenshot).	¶50	col. 10:50-54
providing energy to the magnetic field generating coil in order to generate a time-varying magnetic field;	The accused devices allegedly include a power supply that transmits energy to the applicators to generate time-varying magnetic fields.	¶52	col. 11:58-62
and applying a magnetic fluence of 50 T cm² to 1,500 T cm² to the body region,	The complaint alleges on information and belief that the accused devices are configured to generate a magnetic field resulting in a magnetic fluence within the claimed range.	¶53	col. 14:8-16
wherein the time-varying magnetic field is applied to the body region with a magnetic flux density sufficient to cause a muscle contraction in the body region.	Advertising for the accused services promotes the ability to cause "20,000 contractions in each 30 minute session," which allegedly demonstrates the generation of a sufficient magnetic flux density (p. 28 screenshot).	¶54	col. 24:63-65

Identified Points of Contention:
- Evidentiary Questions: The complaint's allegations regarding the specific "magnetic fluence" are based on "information and belief" (Compl. ¶53). A central question will be what evidence Plaintiff can produce through discovery or reverse engineering to demonstrate that the accused devices actually operate within the numerically defined range of 50 to 1,500 T·cm² required by the claim.
- Scope Questions: The patent describes a "positioning member" that may be an "adjustable flexible belt" ('634 Patent, col. 10:51-54). The analysis may examine whether the strap shown in Defendant’s advertising (Compl. ¶50) meets the functional requirements of "coupling" the applicator as described in the patent.

’255 Patent Infringement Allegations

Claim Element (from Independent Claim 16)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A device for treating a patient by radiofrequency energy and a pulsed electric current...	Defendant's "No-Needle Face Lift" service allegedly uses a device that treats patients with both radiofrequency energy and pulsed electric current (HIFES).	¶64	col. 30:57-59
a flexible pad configured to be attached to a body part of a patient, the flexible pad comprising: a flexible substrate...an electrode...and an adhesive...	On information and belief, the accused facial device includes a flexible pad with a substrate, electrode, and adhesive to attach to a patient's face.	¶¶65-67	col. 3:9-13
wherein the electrode is configured to be in contact with the body part via the adhesive;	On information and belief, the accused device's electrode is located on the underside of the flexible substrate and makes contact with the patient's body via an adhesive to operate.	¶68	col. 31:1-2
wherein the electrode is configured to apply radiofrequency energy to the body part to cause heating of the body part,	On information and belief, the accused device treats patients using radiofrequency energy, which requires an electrode to apply that energy and cause heating.	¶69	col. 31:3-5
and wherein the electrode is configured to apply pulsed electric current to the body part to cause a muscle contraction of a muscle within the body part;	The accused device's advertised use of "High-Intensity Facial Electrical Stimulation" allegedly requires an electrode to apply pulsed current and cause muscle contractions.	¶70	col. 31:6-8
a control unit configured to control the radiofrequency energy and the pulsed electric current...	On information and belief, the accused device includes a control unit to manage and provide both the heating and muscle contraction effects during treatment.	¶71	col. 31:9-13
wherein the body part comprises one of a face, a neck, or a submentum.	Promotional materials describe the accused device as targeting "the elevator muscles of the face" and the "frontalis muscle" for a lifting effect (p. 33 screenshot).	¶72	col. 31:14-15

Identified Points of Contention:
- Technical Questions: A key question will be whether the accused "Facial Knockoff Device" utilizes a single "electrode" that performs the dual functions of applying both radiofrequency energy for heating and pulsed electric current for muscle contraction, as recited in claim 16. If the accused device uses separate components for these functions, it may raise a significant non-infringement argument.
- Evidentiary Questions: The majority of the infringement allegations for the ’255 Patent are based on "information and belief" regarding the internal construction of the accused device. The case will depend on evidence establishing that the device actually contains a "flexible pad," "flexible substrate," "electrode," and "adhesive" as claimed.

V. Key Claim Terms for Construction

For the ’634 Patent

The Term: "magnetic fluence"
Context and Importance: This term is critical because it introduces a specific, quantitative limitation (50 T·cm² to 1,500 T·cm²) into the method claim. The infringement analysis will likely depend on whether the accused device can be shown to generate a magnetic field that falls within this precise numerical range. Practitioners may focus on this term because proving infringement requires technical evidence beyond simply showing that the accused device uses a magnetic field to cause muscle contractions.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification provides several overlapping and broad ranges for magnetic fluence, including "up to 60000 T-cm²," which could suggest that the inventors contemplated a wide spectrum of possible values, even if the claim is narrower (’634 Patent, col. 14:8-16).
- Evidence for a Narrower Interpretation: The claim itself provides an explicit numerical range. The patent also provides a specific formula for calculating magnetic fluence (MF=BPP*AMFGD), which provides a clear, technical definition that may limit how the term can be interpreted (’634 Patent, col. 14:1-6).

For the ’255 Patent

The Term: "an electrode"
Context and Importance: Claim 16 recites "an electrode" that is configured to perform two distinct functions: applying RF energy for heating and applying pulsed electric current for muscle contraction. The dispute will likely center on whether a single component in the accused device performs both functions. If the accused device uses separate structures—one for RF and another for electrical stimulation—it may not infringe this limitation.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue that "an electrode" could refer to a composite structure where different parts or layers work together as a single functional unit, even if made of different materials, to deliver both energies. The patent does not explicitly forbid such a construction.
- Evidence for a Narrower Interpretation: The consistent use of the singular term "an electrode" throughout the claim to describe the component responsible for both functions suggests a unitary structure. The claim separately recites the electrode is "configured to apply" RF energy and "configured to apply" pulsed current, tying both functions to the same antecedent element (’255 Patent, col. 31:3-8).

VI. Other Allegations

Indirect Infringement: For the ’255 Patent, the complaint alleges induced infringement based on Defendant's alleged promotion and instruction for customers to use the "Facial Knockoff Device" in an infringing manner (Compl. ¶63). For the ’634 Patent, the complaint alleges Defendant knew its "Body Knockoff Device" was designed for an infringing use and that the device lacks a substantial non-infringing use (Compl. ¶55).
Willful Infringement: The complaint alleges willful infringement for both patents based on pre-suit knowledge. It explicitly states that Defendant was aware of the patents since at least September 27, 2024, when Plaintiff sent a demand letter, and also references Plaintiff's public patent marking website (Compl. ¶38, ¶51, ¶56, ¶74).

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

A core issue will be one of evidentiary proof: can Plaintiff demonstrate through technical analysis that the accused "Body Knockoff Devices" generate a "magnetic fluence" that falls within the specific numerical range of 50 to 1,500 T·cm² as required by claim 1 of the ’634 patent, especially given that this allegation rests on "information and belief"?
A key question will be one of technical and definitional scope: does the accused "Facial Knockoff Device" employ a single, unitary "electrode" that is configured to deliver both radiofrequency energy for heating and pulsed electric current for muscle contraction, as required by claim 16 of the ’255 patent, or does it utilize a different architecture with separate components for each function?
A central question of factual discovery will be to substantiate the numerous "information and belief" allegations regarding the internal construction and operation of both the body and facial devices, which are currently premised on publicly available marketing materials rather than direct technical inspection.