DCT

2:23-cv-00172

Slyde Analytics LLC v. Zepp Health Corp

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: [Slyde Analytics LLC](https://ai-lab.exparte.com/party/slyde-analytics-llc) v. Zepp Health Corp, 2:23-cv-00172, E.D. Tex., 01/30/2024
  • Venue Allegations: Venue is alleged to be proper because Defendant is not a resident of the United States and may therefore be sued in any judicial district.
  • Core Dispute: Plaintiff alleges that Defendant’s smartwatches infringe seven U.S. patents related to user interfaces, power management, and athletic performance analysis for wearable devices.
  • Technical Context: The patents address core functionalities in the competitive smartwatch market, including power-saving gesture recognition, touch-screen navigation, and the use of on-board sensors to provide biomechanical feedback to athletes.
  • Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history concerning the patents-in-suit.

Case Timeline

Date Event
2009-07-03 Priority Date for U.S. Patent No. 9,651,922
2010-03-30 Priority Date for U.S. Patent No. 8,588,033
2010-06-16 Priority Date for U.S. Patent Nos. 9,320,457 and 9,873,018
2011-06-17 Priority Date for U.S. Patent No. 9,536,134
2011-10-18 Priority Date for U.S. Patent Nos. 9,804,678 and 10,198,085
2013-11-19 U.S. Patent No. 8,588,033 Issues
2016-04-26 U.S. Patent No. 9,320,457 Issues
2017-01-03 U.S. Patent No. 9,536,134 Issues
2017-05-16 U.S. Patent No. 9,651,922 Issues
2017-10-31 U.S. Patent No. 9,804,678 Issues
2018-01-23 U.S. Patent No. 9,873,018 Issues
2019-02-05 U.S. Patent No. 10,198,085 Issues
2024-01-30 Amended Complaint Filed

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

U.S. Patent No. 9,804,678 - "Method and Circuit for Switching a Wristwatch from a First Power Mode to a Second Power Mode"

The Invention Explained

  • Problem Addressed: The patent describes the technical challenge of reliably waking an electronic device, such as a wristwatch, from a low-power "sleep mode" using a gesture like a tap, while avoiding unintended activations from other movements or high accelerations that occur during normal use, such as sports (’678) Patent, col. 1:47-52, col. 2:7-15).
  • The Patented Solution: The invention proposes a method that combines two different sensors—an inertial sensor (e.g., an accelerometer) and a touch panel—to confirm a user's intent to wake the device. The system first uses the always-on inertial sensor to detect a potential gesture and, only then, powers on the touch controller to confirm it, thereby saving power (’678 Patent, col. 2:28-45). The method further discriminates a valid tap from other movements by analyzing the "frequency," "slope," and/or "direction" of the acceleration signal, rather than just its amplitude (’678 Patent, col. 2:50-64, Fig. 4).
  • Technical Importance: This dual-sensor, signal-signature approach aimed to improve both the reliability and power efficiency of gesture-based controls on small, battery-constrained wearable devices.

Key Claims at a Glance

  • The complaint asserts independent claim 14 (’678 Patent, Compl. ¶25).
  • Key elements of claim 14 include:
    • A wristwatch with a display, microcontroller, touch panel, touch controller, and an inertial sensor (accelerometer and processor).
    • The microcontroller and touch controller are in a "sleep power mode."
    • The inertial sensor's processor is arranged for "discriminating between gesture and no gesture based on a direction of said acceleration signal... and on a slope or frequency of said acceleration signal."
    • The touch controller is commanded to switch to the second power mode upon gesture detection by the inertial sensor to detect a "tap gesture."
    • The microcontroller is commanded to switch to the second power mode upon tap gesture detection by the touch controller.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 10,198,085 - "Method and Circuit for Switching a Wristwatch from a First Power Mode to a Second Power Mode"

The Invention Explained

  • Problem Addressed: The patent addresses the need for a reliable, low-power method to switch a wristwatch display on when a user rotates their wrist to look at the time, a common feature known as "raise-to-wake" (’085) Patent, col. 9:36-42).
  • The Patented Solution: The invention claims a specific multi-step method for detecting a valid "wristturn" using an accelerometer. The method requires detecting that the watch first enters and holds a "starting position" within a defined time and angle range, then moves to a "final position" in a different angle range, and finally "remains substantially immobile" for a predetermined duration (’085 Patent, col. 10:1-41; Figs. 7a-7c). This sequence is designed to distinguish an intentional viewing gesture from other arm movements.
  • Technical Importance: By defining a specific kinematic sequence for a valid wrist turn, the invention sought to provide a more robust and power-efficient alternative to simpler motion-based triggers that could lead to false activations.

Key Claims at a Glance

  • The complaint asserts independent claim 1 (’085 Patent, Compl. ¶36).
  • Key elements of claim 1 include:
    • A method for switching a wristwatch from a first to a second power mode.
    • Using an accelerometer to detect a "wristturn."
    • The "wristturn" detection comprises multiple steps:
      • Detecting the watch is in a "starting position" held within a first range for a defined time.
      • Detecting the watch is then in a "final position" within a second, different range.
      • In response, detecting the watch "remains substantially immobile" for a predetermined duration.
      • Detecting that the duration between the starting and final positions is in a predefined range.
  • The complaint does not explicitly reserve the right to assert dependent claims.

  • Multi-Patent Capsule: U.S. Patent No. 8,588,033

    • Patent Identification: U.S. Patent No. 8,588,033, "Wristwatch with Electronic Display," issued November 19, 2013.
    • Technology Synopsis: The patent addresses the desire to combine the aesthetic appeal of traditional mechanical watches with the functionality of modern electronic displays (’033) Patent, col. 1:8-16). The solution is a wristwatch with an electronic display that reproduces a "simulation of a mechanical watch movement," which is synchronized with a time base from a quartz oscillator (’033 Patent, Abstract).
    • Asserted Claims: At least claim 1 (Compl. ¶47).
    • Accused Features: The complaint alleges that the Amazfit Falcon and other smartwatches infringe by promoting and displaying digital watch faces that simulate mechanical movements (Compl. ¶¶48-49).

  • Multi-Patent Capsule: U.S. Patent No. 9,651,922

    • Patent Identification: U.S. Patent No. 9,651,922, "Wristwatch with a Touch Screen and Method for Displaying on a Touch-Screen Watch," issued May 16, 2017.
    • Technology Synopsis: The patent addresses the challenge of navigating between different functions or screens on a small watch display (’922) Patent, col. 2:38-48). The solution is a system where different functions are represented as full-screen "cards" that a user can scroll through horizontally or vertically by swiping on the touch screen, with the displayed card being "lastingly" replaced by the new one (’922 Patent, Abstract; col. 4:16-21).
    • Asserted Claims: At least claim 1 (Compl. ¶58).
    • Accused Features: The complaint alleges that the Amazfit Falcon infringes when a user changes the watch face by touching, holding, and then swiping left or right to select a new watch face display (Compl. ¶¶59-60).

  • Multi-Patent Capsule: U.S. Patent No. 9,320,457

    • Patent Identification: U.S. Patent No. 9,320,457, "Integrated Portable Device and Method Implementing an Accelerometer for Analyzing Biomechanical Parameters of a Stride," issued April 26, 2016.
    • Technology Synopsis: The patent addresses the difficulty for runners to objectively measure the biomechanical efficiency of their stride without complex lab equipment (’457) Patent, col. 1:31-43). The invention is a portable device worn on the torso with a triaxial accelerometer that measures acceleration data and a processor that calculates biomechanical parameters like the "vertical oscillation of the center of gravity" during a stride (’457 Patent, Abstract).
    • Asserted Claims: At least claim 1 (Compl. ¶69).
    • Accused Features: The complaint alleges that the Amazfit Cheetah Pro's run-tracking software infringes by using an accelerometer to track and calculate information regarding a user's stride, cadence, and other running parameters (Compl. ¶¶73-74).

  • Multi-Patent Capsule: U.S. Patent No. 9,873,018

    • Patent Identification: U.S. Patent No. 9,873,018, "Integrated Portable Device and Method Implementing an Accelerometer for Analyzing Biomechanical Parameters of a Stride," issued January 23, 2018.
    • Technology Synopsis: This patent is related to the ’457 Patent and similarly addresses the analysis of a runner's stride using a portable device. It adds the use of a GPS receiver in combination with the accelerometer to calculate biomechanical parameters based on acceleration data, distance measured by the GPS, and time from a chronograph (’018) Patent, col. 15:58-col. 16:32).
    • Asserted Claims: At least claim 1 (Compl. ¶83).
    • Accused Features: The complaint alleges the Amazfit Cheetah Pro infringes by using both its GPS and acceleration sensors to track and calculate running information such as stride and cadence (Compl. ¶¶88-89).

  • Multi-Patent Capsule: U.S. Patent No. 9,536,134

    • Patent Identification: U.S. Patent No. 9,536,134, "Athletic Performance Monitoring Device," issued January 3, 2017.
    • Technology Synopsis: The patent describes an athletic monitoring system with two components: an accelerometer worn close to the athlete's center of gravity and a separate user-worn device with a processing system (e.g., a phone or watch) (’134) Patent, Abstract). The system is configured so the processing system requests acceleration data from the accelerometer "only when a predefined event has occurred" (e.g., reaching a certain distance or time interval) to provide performance information, which creates a power-efficient, event-driven architecture (’134 Patent, col. 2:8-14).
    • Asserted Claims: At least claim 1 (Compl. ¶99).
    • Accused Features: The complaint alleges the Amazfit Cheetah Pro infringes by tracking a user's running pace at certain intervals, which allegedly constitutes requesting and processing acceleration data upon a predefined event (Compl. ¶101).

III. The Accused Instrumentality

  • Product Identification: The complaint identifies a broad range of Amazfit and Zepp smartwatches (Compl. ¶16), but the specific infringement counts focus on the Amazfit Falcon (for the ’678, ’085, ’033, and ’922 Patents) and the Amazfit Cheetah Pro (for the ’457, ’018, and ’134 Patents) (Compl. ¶¶24, 35, 46, 57, 68, 82, 98).
  • Functionality and Market Context:
    • The complaint alleges the accused products are smartwatches that include features such as gesture detection for switching power modes, often referred to as a "raise-to-wake" functionality (Compl. ¶¶9, 27, 38). These devices are alleged to have multiple power-saving modes (Compl. ¶27).
    • The accused products are also alleged to feature touch screens and processing capabilities that allow users to select and display different digital watch faces, including some that simulate mechanical movements (Compl. ¶¶49, 60). A screenshot from the complaint shows a menu for stride and cadence tracking on the Amazfit Cheetah Pro (Compl. p. 22).
    • For athletic performance, the complaint accuses the Amazfit Cheetah Pro of using an integrated accelerometer and GPS to track and calculate biomechanical parameters of a runner's stride, such as cadence and stride information (Compl. ¶¶73-74, 84). The complaint includes a screenshot from Defendant's marketing materials showing a "Virtual Pacer" and "Race Achievement Predictions" feature, which allegedly tracks a user's pace at intervals (Compl. p. 31).

IV. Analysis of Infringement Allegations

  • U.S. Patent No. 9,804,678 Infringement Allegations
Claim Element (from Independent Claim 14) Alleged Infringing Functionality Complaint Citation Patent Citation
a wristwatch which can be operated in a plurality of power modes including a first power mode and a second power mode The Amazfit Falcon has power saving modes, such as turning the screen from "off" to "on". ¶26, ¶27 col. 3:14-19
a display; a microcontroller; a touch panel underneath a cover glass...; a touch controller...; wherein the microcontroller and the touch controller are in a sleep power mode The Amazfit Falcon comprises these components, including a microcontroller (processor) and touch controller that are in a sleep power mode. ¶26 col. 6:15-20
an inertial sensor comprising an accelerometer and a processor... The Amazfit Falcon comprises an inertial sensor with an accelerometer and processor. ¶26 col. 6:20-22
said processor being arranged for discriminating between gesture and no gesture based on a direction of the acceleration signal... and on a slope or frequency of the acceleration signal... The processor is alleged to discriminate between gesture and no gesture based on direction, slope, or frequency of the signal from its three-dimensional accelerometer. ¶26 col. 2:50-54
wherein touch controller is commanded so as to be switched to the second power mode upon gesture detection by the inertial sensor and for detecting a tap gesture... The touch controller is allegedly commanded to switch to the second power mode upon gesture detection by the inertial sensor to detect a tap. ¶26 col. 8:1-10
wherein the microcontroller is arranged for controlling a display... and commanded to be switched to the second power mode upon a tap gesture detection by the touch controller... The microcontroller is allegedly commanded to switch to the second power mode upon tap detection by the touch controller to control the display. ¶26 col. 8:26-34
  • Identified Points of Contention:
    • Scope Questions: The analysis may focus on the definition of "sleep power mode." The claim requires both the microcontroller and the touch controller to be in this mode. The question will be whether the accused product's "off" state or low-power standby mode meets the specific functional state described in the patent.
    • Technical Questions: A central evidentiary question may be whether the accused product's processor performs the claimed "discriminating" step based on the direction, slope, or frequency of the acceleration signal, as opposed to relying solely on amplitude or a simpler motion threshold. The complaint asserts this functionality in a conclusory manner, raising the question of what evidence will support it.
  • U.S. Patent No. 10,198,085 Infringement Allegations
Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A method for switching a wristwatch from a first power mode to a second power mode, comprising: using an accelerometer for detecting a wristturn... The Amazfit Falcon performs a method of switching power modes and uses an accelerometer for detecting a wristturn, such as when a user turns the screen "off" to "on" by changing its orientation. ¶37, ¶38 col. 9:36-42
detecting that an orientation of the wristwatch is in a starting position, wherein said step of detecting that the orientation is in the starting position comprises detecting that the orientation of the wristwatch is held within a first range for a defined time; The Amazfit Falcon allegedly detects that the watch's orientation is in a starting position held within a first range for a defined time. ¶37 col. 10:1-4
detecting that an orientation of the wristwatch is then in a final position, wherein said step of detecting that the orientation is in the final position comprises detecting that the orientation is in a second range different from said first range, The Amazfit Falcon allegedly detects that the watch's orientation is then in a final position within a second range, different from the first. ¶37 col. 10:5-10
in response to a detection that the orientation of the wristwatch is in the second range, detecting that the wristwatch remains substantially immobile during a predetermined duration... In response to detecting the final position, the Amazfit Falcon allegedly detects that the watch remains substantially immobile for a predetermined duration. ¶37 col. 10:26-32
...and that a duration between the starting position and the final position is in a predefined range. The Amazfit Falcon allegedly detects that the duration between the starting and final positions is within a predefined range. ¶37 col. 10:18-21
  • Identified Points of Contention:
    • Scope Questions: The dispute will likely center on the term "wristturn." The claim defines it through a specific, multi-part sequence of events (starting position, final position, immobility, timing). The key question is whether the accused "raise-to-wake" feature performs all of these specific claimed steps, or if it operates on a simpler motion-detection basis that falls outside the claim's scope.
    • Technical Questions: What evidence does the complaint provide that the Amazfit Falcon specifically measures orientation within a "first range," then a "second range," and then confirms that it is "substantially immobile"? The complaint's allegations track the claim language but may face challenges regarding the actual technical implementation in the accused device.

V. Key Claim Terms for Construction

  • Term: "wristturn" (’085 Patent, Claim 1)

    • Context and Importance: This term is the central trigger for the claimed method. Its definition is critical because if the accused device's "raise-to-wake" functionality does not constitute a "wristturn" as defined by the claim, there can be no infringement. Practitioners may focus on this term because the patent appears to give it a specific definition through the subsequent method steps.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The parties may argue that the term should be given its plain and ordinary meaning, a potentially encompassing any gesture involving turning the wrist to view the watch.
      • Evidence for a Narrower Interpretation: The claim itself recites that "detecting a wristturn comprises" a series of specific steps (detecting a starting position, a final position, immobility, and duration). This structure strongly suggests that "wristturn" is not just any motion but is defined by the successful completion of this entire sequence, as illustrated in Figures 7a-7c and the accompanying description (’085 Patent, col. 9:56 - col. 10:41).

  • Term: "substantially immobile" (’085 Patent, Claim 1)

    • Context and Importance: This is the final confirmation step in the claimed "wristturn" detection method. The scope of this term will determine what level of user motion is permissible for the watch to activate, which is key to distinguishing the claimed method from a simple motion trigger.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: A defendant may argue this is a relative term of degree that should not be read too restrictively.
      • Evidence for a Narrower Interpretation: The specification provides a potential definition, stating that the system "verifies whether this final orientation... is maintained" by checking if "all 3 axis show no movement above a certain threshold for a defined time" (’085 Patent, col. 10:26-32). This language may support a construction requiring a specific, measurable state of inaction below a set threshold.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement for all asserted patents. The allegations are based on Defendant supplying customers with instructions on how to operate the infringing technology, such as through user manuals, websites, and product literature (Compl. ¶¶30, 41, 52, 63, 77, 91, 104). The complaint cites to the Amazfit Falcon User Manual instructions for "Always On Display" and gesture controls (Compl. ¶30 n.4, ¶63 n.11).
  • Willful Infringement: The complaint alleges that Defendant had knowledge of infringement at least as of the date of the complaint and has been willfully blind to the patents-in-suit. This allegation is based on a purported "policy of not reviewing the patents of others" (Compl. ¶¶29, 40, 51, 62, 76, 92, 103).

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

  • A core issue will be one of definitional scope: can the term "wristturn," as defined by the ’085 Patent’s multi-step process involving specific start/end positions and immobility, be construed to cover the general "raise-to-wake" functionality of the accused smartwatches?
  • A key evidentiary question will be one of technical operation: what proof will show that the accused products' processors discriminate gestures based on the claimed criteria of signal frequency, slope, and direction (’678 Patent), or calculate biomechanical parameters using the specific methods claimed (’457 and ’018 Patents), versus using alternative, unclaimed technical means?
  • A third central question relates to event-driven architecture: does the accused athletic monitoring software operate by requesting accelerometer data "only when a predefined event has occurred," as required by the ’134 Patent, or does it employ a different data-handling architecture, such as continuous streaming or periodic polling?