DCT

1:24-cv-01020

Ouraring Inc v. Ringconn LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:24-cv-01020, D. Del., 09/10/2024
  • Venue Allegations: Venue is asserted as proper in the District of Delaware on the basis that Defendant is a Delaware corporation.
  • Core Dispute: Plaintiff alleges that Defendant’s smart rings infringe two patents related to the construction and components of wearable computing devices.
  • Technical Context: The technology at issue falls within the consumer electronics domain of wearable smart rings, which are used for monitoring physiological data and physical activity.
  • Key Procedural History: The complaint alleges that Defendant has been on notice of the ’178 Patent since at least March 13, 2024, due to a co-pending U.S. International Trade Commission (ITC) complaint. It further alleges knowledge of the ’124 Patent from the same date, based on the ’178 Patent being in the same family and Defendant’s identification of other family patents in an ITC Markman brief.

Case Timeline

Date Event
2013-11-29 Earliest Priority Date for ’178 and ’124 Patents
2021-11-30 U.S. Patent No. 11,188,124 Issued
2024-01-09 U.S. Patent No. 11,868,178 Issued
2024-03-13 Co-pending ITC Complaint Filed Against Defendant
2024-09-10 Complaint Filed

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

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

  • Patent Identification: U.S. Patent No. 11,868,178, titled “WEARABLE COMPUTING DEVICE,” issued on January 9, 2024.
  • The Invention Explained:
    • Problem Addressed: The patent’s background section identifies a problem with then-current wearable electronics being “bulky and can be intrusive or interfere with a person’s daily life,” making them uncomfortable for extended periods of use (’178 Patent, col. 1:43-46).
    • The Patented Solution: The invention is a smart ring that houses its electronic components within a curved, U-shaped interior, which includes a curved battery and a semi-flexible printed circuit board (PCB) with various sensors. These components are encapsulated by a potting material that is substantially transparent to light, which forms an interior wall of the ring (’178 Patent, Abstract). This ring form factor is intended to be worn comfortably for long durations, allowing for consistent data collection (’178 Patent, col. 9:18-24).
    • Technical Importance: The ring-based design enables prolonged and consistent skin contact, which may facilitate more reliable and extended recording of a user's biological and activity data compared to other wearable form factors (’178 Patent, col. 9:18-24).
  • Key Claims at a Glance:
    • The complaint asserts at least independent claim 1 and alleges infringement of "one or more claims" (’178 Patent, Compl. ¶¶9, 11).
    • The essential elements of independent claim 1 include:
      • an external housing component defining an outer circumferential surface of the finger-worn wearable ring device;
      • an internal housing component defining an inner circumferential surface of the finger-worn wearable ring device;
      • a battery positioned within a cavity formed between the internal and external housing components;
      • a printed circuit board disposed between the internal and external housing components; and
      • one or more sensors electrically coupled with the printed circuit board and the battery and configured to acquire data from the user through the internal housing component.

U.S. Patent No. 11,188,124

  • Patent Identification: U.S. Patent No. 11,188,124, titled “WEARABLE COMPUTING DEVICE,” issued on November 30, 2021.
  • The Invention Explained:
    • Problem Addressed: The ’124 Patent addresses the same problem as the related ’178 Patent: existing wearable electronics are often bulky, intrusive, and uncomfortable for long-term wear (’124 Patent, col. 1:26-31).
    • The Patented Solution: The invention is a wearable computing device in a ring form factor with a housing characterized by a "C-shaped cross section" that defines an interior space. This space contains a curved battery, a conforming printed circuit board, sensors (including a temperature sensor), a processor, and other electronics. The components are encapsulated by a potting material that "forms an interior wall" of the device and is substantially transparent to light (’124 Patent, Abstract; col. 33:40–col. 34:21).
    • Technical Importance: By integrating complex electronics into a compact, ergonomic ring, the invention aims to provide a device suitable for prolonged usage, which can create more reliable and extended recordings of a user’s fitness activity and health information (’124 Patent, col. 7:10-20).
  • Key Claims at a Glance:
    • The complaint asserts at least independent claim 1 and alleges infringement of "one or more claims" of the ’124 Patent (Compl. ¶¶17, 19).
    • The essential elements of independent claim 1 include:
      • an external housing with a C-shaped cross section defining an interior space;
      • a curved rechargeable battery disposed within the interior space and curved to conform to the interior surface;
      • a printed circuit board within the interior space, configured to approximately conform to the interior surface;
      • one or more sensors, a memory, a short-range communication module, and a first temperature sensor disposed on the printed circuit board;
      • a processor coupled to the components; and
      • a potting material in the interior space that encapsulates the components, forms an interior wall of the device, and is substantially transparent to light.

III. The Accused Instrumentality

  • Product Identification: The complaint identifies the accused products as the "RingConn Smart Rings (Gen. 1 and Gen. 2)" (Compl. ¶1).
  • Functionality and Market Context: The complaint does not provide sufficient detail for analysis of the accused products' specific functionality or market context beyond their identification as smart rings.

IV. Analysis of Infringement Allegations

The complaint alleges that the Accused Products infringe at least claim 1 of the ’178 Patent and claim 1 of the ’124 Patent, referencing external claim charts (Exhibits B and D, respectively) that were not provided with the complaint (Compl. ¶¶11, 19). The complaint does not contain a narrative description of the infringement theory for either patent.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

  • For the ’178 Patent:
    • The Term: "internal housing component" / "external housing component"
    • Context and Importance: Claim 1 requires two distinct housing "components" that form a cavity between them. The physical construction of the accused rings will be critical to determining if they meet this two-part limitation, or if they are instead constructed from a single, unitary housing. Practitioners may focus on this term because the dispute may turn on whether the accused device's structure can be conceptually or physically separated into the two claimed "components."
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification, which is shared across the patent family, describes various embodiments, including constructions with potting that forms a wall, suggesting the term "component" might not be limited to a single, solid piece of metal or plastic but could encompass different structural arrangements that collectively define inner and outer surfaces (’124 Patent, col. 14:40-45).
      • Evidence for a Narrower Interpretation: Figures in the specification of the related ’124 Patent depict a distinct "OUTER RING 812a" and "INNER RING 812b", which may support an argument that the terms refer to separate, discrete physical parts that are assembled (’124 Patent, Fig. 8).
  • For the ’124 Patent:
    • The Term: "potting material ... forms an interior wall"
    • Context and Importance: This limitation requires the potting material to serve a specific structural function as the "interior wall," which is the surface that would contact the wearer's finger. A central dispute may arise over whether the accused product's encapsulant merely protects internal electronics or if it actually constitutes the device's innermost wall as claimed. Practitioners may focus on this term because it links the material composition (potting) to a specific structural role.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent’s abstract explicitly states that the "potting material ... forms an interior wall of the smart ring," directly linking the material to the structural element (’124 Patent, Abstract). The summary also describes an "internal window defined by the interior wall," which can be made of potting material, further supporting this interpretation (’124 Patent, col. 1:53-54).
      • Evidence for a Narrower Interpretation: The claim preamble recites an "external housing having ... an interior surface." A party could argue that this pre-existing "interior surface" of the housing is the true "interior wall," and the potting material is simply a filler within the space defined by that wall, not the wall itself.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement and contributory infringement for both patents, asserting that Defendant induces infringement by others "by wearing and using the Accused Product" and contributes by selling a "material part of the invention" (Compl. ¶¶10, 18).
  • Willful Infringement: The complaint alleges deliberate and willful infringement. For the ’178 Patent, this is based on alleged knowledge since at least March 13, 2024, the filing date of an ITC complaint asserting that patent (Compl. ¶12). For the ’124 Patent, willfulness is based on the same ITC action, with the complaint further alleging that the ’124 Patent is from the same family and that Defendant’s own ITC filings identified other patents from that family, suggesting Defendant knew or should have known of the ’124 Patent (Compl. ¶20).

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

  • A central issue will be one of structural definition: can the physical construction of the accused RingConn rings be mapped onto the specific multi-part housing limitations of the asserted claims? The case may depend on whether terms like "internal housing component" and "external housing component" require physically separate pieces or can be met by a unitary body with distinct functional surfaces.
  • A key evidentiary question will concern the functional role of materials: does the encapsulating material used in the accused rings serve merely as a protective filler, or does it structurally "form an interior wall" of the device as required by claim 1 of the ’124 patent?
  • A significant question for potential damages will be the scope and timing of knowledge: what is the legal effect of the prior ITC proceeding on Defendant's alleged knowledge of the asserted patents, particularly whether knowledge of one patent and its family can establish pre-suit knowledge of the specific claims of the related ’124 patent for willfulness purposes?