Healthness LLC v. Empatica Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Healthness LLC (Delaware)
  • Defendant: Empatica, Inc. (Delaware)
  • Plaintiff’s Counsel: Garibian Law Offices, P.C.; Rabicoff Law LLC
• Case Identification: 1:25-cv-00269, D. Del., 03/07/2025
• Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant is incorporated in Delaware and maintains an established place of business in the District.
• Core Dispute: Plaintiff alleges that certain of Defendant's products and services for remote monitoring infringe two patents related to systems and methods for remotely monitoring the movement of individuals.
• Technical Context: The technology relates to health and safety monitoring systems that non-intrusively track an individual's movement within a location to detect potential emergency situations, such as a lack of activity.
• Key Procedural History: The U.S. Patent No. 6,696,957 is a continuation of the application that led to U.S. Patent No. 6,445,298. The '957 Patent is subject to a terminal disclaimer, which may limit its enforceable term to that of the '298 Patent.

Case Timeline

Date	Event
2000-12-21	Priority Date for ’298 Patent
2000-12-21	Priority Date for ’957 Patent
2002-09-03	’298 Patent Issued
2004-02-24	’957 Patent Issued
2025-03-07	Complaint Filing Date

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

U.S. Patent No. 6,445,298 - System and method for remotely monitoring movement of individuals, Issued September 3, 2002

The Invention Explained

• Problem Addressed: The patent describes a need for a system to check on the well-being of individuals (e.g., elderly or disabled persons) without constant intrusion. It notes that traditional emergency response systems require the individual to actively trigger an alarm, which may not be possible in an emergency. Furthermore, automated systems that simply detect a lack of motion over a long period (e.g., 24 hours) can lead to false alarms and unnecessary property damage if the person is merely away on vacation (ʼ298 Patent, col. 1:13-58).
• The Patented Solution: The invention proposes a multi-part system to address this. A local "base system" uses monitoring devices like motion detectors to generate movement data at a person's home ("first location"). This data is transferred to a remote "central monitoring system" ("second location"), which stores and processes it. Finally, an authorized "client system" (e.g., a family member's computer) can access this information from a "third location" to non-intrusively ascertain the individual's activity level and well-being ('298 Patent, Abstract; col. 2:18-38; Fig. 7). The system also contemplates a "vacation mode" to prevent false alarms when the premises are known to be empty ('298 Patent, col. 8:32-40).
• Technical Importance: The invention provided a framework for passive, remote wellness monitoring that could offer peace of mind to caregivers while preserving the privacy of the person being monitored ('298 Patent, col. 2:48-58).

Key Claims at a Glance

• The complaint asserts one or more "exemplary method claims" without specifying claim numbers (Compl. ¶12). Independent claim 1 is a representative method claim.
• Essential elements of independent claim 1 include:
  • detecting movement of the individual at a first location with at least one monitoring device;
  • tabulating a total number of detected movements within a predetermined time period;
  • transferring the total number of detected movements from the first location to a second location remote from the first location; and
  • displaying the total number of detected movements at a third location remote from the first and second locations.
• The complaint does not explicitly reserve the right to assert dependent claims for the ’298 Patent.

U.S. Patent No. 6,696,957 - System and method for remotely monitoring movement of individuals, Issued February 24, 2004

The Invention Explained

• Problem Addressed: The ’957 Patent is a continuation of the application for the '298 Patent and shares a nearly identical specification ('957 Patent, col. 1:7-9). It therefore addresses the same problem of enabling non-intrusive, remote monitoring while avoiding false alarms common in prior art systems ('957 Patent, col. 1:21-54).
• The Patented Solution: The solution is substantively the same as that described in the '298 Patent, involving a local base system, a remote central monitoring system, and a remote client system for accessing activity data ('957 Patent, Abstract; Fig. 7). The claims are directed to both methods and systems for implementing this architecture.
• Technical Importance: As a continuation, this patent broadens the protection for the core monitoring invention, claiming it from both a method and system perspective ('957 Patent, col. 9:21-10:52).

Key Claims at a Glance

• The complaint asserts one or more "exemplary method claims" (Compl. ¶18). Independent claim 1 is the primary method claim, and independent claim 11 is the primary system claim.
• Essential elements of independent method claim 1 include:
  • detecting movement... at a first location;
  • tabulating a total number of detected movements within a predetermined time period;
  • transferring an activity signal based on the total number of detected movements from the first location to a second location; and
  • displaying activity information based on the transferred activity signal at a third location.
• The complaint does not explicitly reserve the right to assert dependent claims for the ’957 Patent.

III. The Accused Instrumentality

Product Identification

• The complaint refers to the accused instrumentalities as the "Exemplary Defendant Products" (Compl. ¶¶12, 18).

Functionality and Market Context

• The complaint does not identify or describe any specific products in its text. It states that the accused products are identified in claim charts provided as Exhibit 3 and Exhibit 4 (Compl. ¶¶14, 20). These exhibits were not filed with the complaint. Therefore, the complaint does not provide sufficient detail for analysis of the accused instrumentality's specific features, functions, or market context. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant’s products infringe by practicing the technology claimed in the patents-in-suit (Compl. ¶¶ 14, 20). It incorporates by reference claim charts in Exhibits 3 and 4, which were not provided with the publicly filed complaint (Compl. ¶¶ 15, 21). As such, a detailed claim chart analysis is not possible. The narrative infringement theory suggests that Defendant's products perform the claimed methods of detecting movement, processing that movement data, and transferring it for remote display and analysis.

Identified Points of Contention

• Scope Questions: A central issue may be how the patent's geographically distinct "first location" (home), "second location" (central monitoring system), and "third location" (client system) map onto modern distributed architectures, such as cloud-based servers and smartphone applications. The definition of these locations could be a point of dispute.
• Technical Questions: The patents describe a specific process of "tabulating a total number of detected movements" ('298 Patent, cl. 1; '957 Patent, cl. 1). A key question for the court will be whether the accused products perform this specific tabulation, or if they employ a different data-processing logic (e.g., streaming raw sensor data, using machine learning to classify activity levels) that Plaintiff will argue is equivalent.

V. Key Claim Terms for Construction

For the ’298 Patent

• The Term: "tabulating a total number of detected movements within a predetermined time period" (Claim 1)
• Context and Importance: This term defines a core data processing step. The infringement analysis may depend on whether the accused system performs this specific counting and aggregation function or a technically different one. Practitioners may focus on this term to determine if there is a literal match in functionality or if the doctrine of equivalents will be required.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification discusses monitoring an "activity level" generally, which could support interpreting "tabulating" as any form of data aggregation or summarization that reflects activity ('298 Patent, col. 6:40-44).
  • Evidence for a Narrower Interpretation: The detailed description and Figure 8 provide a specific flowchart where a counter (M_t) is explicitly incremented (M_t=M_t+1) and later compared to a "Preset Amount" ('298 Patent, Fig. 8, blocks 116, 118). This could support a narrower construction requiring a literal counter that tracks a total number.

For the ’957 Patent

• The Term: "activity signal based on the total number of detected movements" (Claim 1)
• Context and Importance: This term is central to how information is communicated between the system components. The dispute may center on what data must be contained within the "activity signal."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the communications medium broadly (e.g., PSTN, Internet) and focuses on the transfer of information, which could suggest that any signal carrying data sufficient to ascertain the activity level meets the limitation ('957 Patent, col. 5:19-27).
  • Evidence for a Narrower Interpretation: The claim language explicitly ties the "activity signal" to being "based on the total number." This suggests the signal is not merely raw sensor data but is a processed signal that is directly derived from or contains the tabulated numerical count of movements.

VI. Other Allegations

The complaint does not contain explicit counts or factual allegations supporting claims for indirect or willful infringement. The prayer for relief requests that the case be declared "exceptional" under 35 U.S.C. § 285 (Compl. ¶G.i).

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

1. A core issue will be one of definitional scope: How will claim terms from the early 2000s, such as "tabulating a total number," "central monitoring system," and distinct first, second, and third "locations," be construed in the context of modern, cloud-based, and algorithm-driven health monitoring technologies?
2. A key evidentiary question will be one of operational functionality: Once technical details of the accused products are revealed in discovery, the case will likely turn on whether they perform the specific data processing and reporting functions recited in the claims (e.g., incrementing a movement counter as shown in Figure 8) or if their underlying technical operation is fundamentally different, raising a significant dispute over literal infringement and the doctrine of equivalents.
3. A third question relates to pleading sufficiency: Given that the complaint's infringement allegations rely entirely on un-filed exhibits without providing any factual detail in the body of the complaint itself, there may be an initial challenge to whether the complaint meets the plausibility standards for pleading direct infringement under Twombly and Iqbal.