DCT

2:23-cv-00396

Oura Health Oy v. Ultrahuman Healthcare Pvt Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:23-cv-00396, E.D. Tex., 03/14/2024
  • Venue Allegations: Venue is alleged to be proper because Defendants are foreign entities, and they import, offer to sell, and sell the accused products through websites accessible in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s Ultrahuman Ring and associated mobile application infringe four U.S. patents related to the physical construction of wearable electronic rings and methods for analyzing physiological data to assess a user's readiness.
  • Technical Context: The lawsuit concerns the smart ring market, a segment of the wearable technology industry focused on providing health and fitness monitoring in a compact, finger-worn form factor.
  • Key Procedural History: This is a First Amended Complaint. Notably, after the filing of this complaint, the assignee filed statutory disclaimers for all asserted claims of U.S. Patent Nos. 10,893,833 and 10,842,429, which may significantly impact the viability of the infringement counts related to those patents.

Case Timeline

Date Event
2013-11-29 Priority Date for ’178 and ’179 Patents
2015-02-26 Priority Date for ’429 Patent
2015-08-14 Priority Date for ’833 Patent
2020-11-24 ’429 Patent Issued
2021-01-19 ’833 Patent Issued
2022-07-01 Accused Ultrahuman Ring Launched (approx.)
2024-01-09 ’178 and ’179 Patents Issued
2024-03-14 First Amended Complaint Filed

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

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

  • Patent Identification: U.S. Patent No. 10,893,833, "Wearable Electronic Device and Method for Manufacturing Thereof," issued January 19, 2021 (’833 Patent).

The Invention Explained

  • Problem Addressed: The patent describes the difficulty in manufacturing conventional wearable devices to be both waterproof and comfortable against the skin, noting that structures using two-part covers, screws, and o-rings are complex, prone to manufacturing defects, and may create uncomfortable grooves on the inner surface (’833 Patent, col. 1:35-61).
  • The Patented Solution: The invention proposes a simplified manufacturing method where the device has a single, molded body part with a cavity formed on its inner surface. Electronic components are placed within this cavity, which is then filled and sealed with a moldable filler material, creating a smooth, waterproof device with a simple structure (’833 Patent, col. 2:4-16; FIG. 3).
  • Technical Importance: This approach aims to improve the durability, water resistance, and user comfort of small wearable devices by eliminating mechanical seams and fasteners on the skin-contacting surface.

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶29).
  • Essential elements of claim 1 include:
    • A wearable electronic device comprising:
    • a body part made of a non-ceramic material, having an inner surface and an outer surface, wherein at least one cavity is formed on the inner surface;
    • an electronic part arranged in the cavity, where the electronic part's thickness is less than the cavity's depth; and
    • a coating made of a moldable filler material on the inner surface, covering the electronic part and the cavity.

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

  • Patent Identification: U.S. Patent No. 10,842,429, "Method and System for Assessing a Readiness Score of a User," issued November 24, 2020 (’429 Patent).

The Invention Explained

  • Problem Addressed: The patent notes that while conventional devices can monitor physical activities and biological signals, they fail to provide meaningful information about an individual's recovery from physical and mental stress or a holistic "readiness score" to help guide their activities (’429 Patent, col. 1:29-43).
  • The Patented Solution: The invention describes a method that obtains a user's movements to distinguish between "activity periods" and "rest periods." During rest, it measures biosignals (e.g., heart rate, temperature). It then determines "rest" and "activity" summaries based on current and previous data periods to calculate a "readiness score," which is presented to the user with actionable instructions through a mobile device interface (’429 Patent, Abstract; col. 2:1-6).
  • Technical Importance: This technology moves beyond raw data collection to provide synthesized, actionable insights, helping users understand their body's capacity for strain and need for recovery.

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶43).
  • Essential elements of claim 1 include:
    • A method for assessing readiness of a user, comprising:
    • obtaining the user's movements;
    • using the movements to determine a nature of the period (activity vs. rest);
    • measuring at least one biosignal during the rest period;
    • determining a rest summary based on the current and a previous rest period's biosignal;
    • determining an activity summary based on the current and a previous activity period's movements;
    • determining a body response summary based on the rest and activity summaries;
    • calculating a readiness score based on the current and a previous body response summary; and
    • using a user interface to show elements contributing to the score and instructions for improving it.

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

  • Patent Identification: U.S. Patent No. 11,868,178, "Wearable Computing Device," issued January 9, 2024 (’178 Patent).
  • Technology Synopsis: This patent details a specific structural arrangement for a finger-worn ring device. It claims a configuration comprising an external housing and an internal housing that form a cavity, with a battery positioned in a first portion of the cavity and a printed circuit board (PCB) extending through a second, different portion of the cavity, allowing for a compact packaging of electronics.
  • Asserted Claims: Independent claim 1 (Compl. ¶59).
  • Accused Features: The complaint alleges that the physical construction of the Ultrahuman Ring, including its distinct internal and external housing components and the specific placement of its battery and PCB within the cavity they form, infringes the ’178 patent (Compl. ¶¶61-68).

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

  • Patent Identification: U.S. Patent No. 11,868,179, "Wearable Computing Device," issued January 9, 2024 (’179 Patent).
  • Technology Synopsis: This patent describes a wearable computing device focused on optical sensing. The claims cover a device with a housing containing a PCB and a plurality of sensors, specifically including light-emitting components for at least two different wavelengths (one infrared, one visible) and light-receiving components, along with a processor to analyze the reflected or absorbed light.
  • Asserted Claims: Independent claim 1 (Compl. ¶76).
  • Accused Features: The complaint alleges that the Ultrahuman Ring’s sensor suite, which includes infrared, red, and green LEDs for photoplethysmography (PPG) and other measurements, infringes the ’179 Patent’s claims directed to a multi-wavelength optical sensing system (Compl. ¶¶81-84).

III. The Accused Instrumentality

  • Product Identification: The "Ultrahuman Ring" and the associated "Ultrahuman App" are collectively identified as the "Accused Instrumentalities" (Compl. ¶8).
  • Functionality and Market Context: The Ultrahuman Ring is a wearable electronic ring designed to be worn on a finger to track physiological data related to sleep, movement, and recovery (Compl. ¶8). The complaint alleges the ring contains sensors such as an infrared photoplethysmography (PPG) sensor, a skin temperature sensor, and a 3D accelerometer (Compl. ¶10). The collected data is processed and displayed to the user through the Ultrahuman App, which provides metrics such as a "Recovery Score" (Compl. ¶44). The product is offered for sale to customers in the United States through Ultrahuman's website and third-party retailers like Amazon.com (Compl. ¶¶14-15). The complaint shows a screenshot from Ultrahuman's website advertising that it ships to the United States (Compl. p. 10).

IV. Analysis of Infringement Allegations

’833 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a body part made of a non-ceramic material, having an inner surface and an outer surface The Ultrahuman Ring has an outer shell made of "fighter jet grade Titanium reinforced with Tungsten Carbide Carbon coating," which is a non-ceramic material. ¶32 col. 4:16-20
wherein at least one cavity is formed on the inner surface of the body part...extending from the inner surface...towards the outer surface The body part of the ring has at least one cavity formed on its inner surface that extends towards the outer surface. The complaint provides an annotated exploded view of the accused product to illustrate this structure. (Compl. p. 17). ¶33 col. 4:21-26
an electronic part arranged in said at least one cavity, which electronic part has a thickness that is less than the depth of the at least one cavity The Ultrahuman Ring's electronics are arranged within the cavity and allegedly have a thickness less than the cavity's depth. The complaint provides an annotated image to support this allegation. (Compl. p. 17). ¶34 col. 4:45-48
a coating made of a moldable filler material on the inner surface of the body part, covering the electronic part and the at least one cavity The "inners of the ring" are advertised as being "coated with medical-grade hypoallergenic epoxy resin," which is alleged to be a moldable filler material that covers the electronics and the cavity. ¶35 col. 4:42-45
  • Identified Points of Contention:
    • Scope Questions: A potential issue may be whether the advertised "Titanium" shell, which is part of a larger assembly, constitutes the claimed "body part," and whether the advertised "epoxy resin" meets the claim limitations of a "coating made of a moldable filler material" that covers both the electronic part and the cavity.
    • Technical Questions: The analysis may turn on the manufacturing process of the accused ring. The court will need to determine if the epoxy resin functions as a filler material that is applied to seal a pre-existing cavity containing electronics, as the patent describes.

’429 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
obtaining the user's movements; The Ultrahuman Ring calculates its "Recovery Score" based on five factors, including "movement." ¶45 col. 5:50-58
using the obtained user's movements to determine a nature of the period, wherein the nature of the period is selected from an activity period and a rest period The Ultrahuman Ring's "Movement Index" is described as representing "how much rest and recovery your body needs," thereby distinguishing between periods of activity and rest. ¶46 col. 5:29-34
measuring at least one biosignal of the user during the rest period The accused product measures biosignals such as resting heart rate, HRV, and body temperature during the resting period (e.g., sleep). ¶47 col. 5:6-15
determining a rest summary for the rest period, based on the measured at least one biosignal and at least one biosignal of a previous rest period The Ultrahuman App calculates a "Sleep Quotient," which is alleged to be a rest summary based on measured biosignals from multiple rest periods. ¶48 col. 8:25-31
calculating a readiness score based on the body response summary and a previous body response summary Ultrahuman calculates a "Recovery Score" which is alleged to be based on a response summary over multiple days, thus incorporating a previous body response summary. ¶51 col. 9:1-2
using a user interface...to show elements contributing to the readiness score and instructions related to...improving the readiness score The Ultrahuman App's user interface displays the "Recovery Score Contributors" and provides instructions such as "Need more rest?". The complaint provides a screenshot of this interface. (Compl. p. 24). ¶52 col. 9:53-61
  • Identified Points of Contention:
    • Scope Questions: The key dispute may center on the mapping of terms. Do Ultrahuman’s "Recovery Score," "Sleep Quotient," and "Movement Index" correspond to the patent's "readiness score," "rest summary," and "activity summary," respectively? The definition of "body response summary" will be particularly important.
    • Technical Questions: A factual question will be whether the accused system's calculation of the "Recovery Score" actually uses a "previous body response summary" as required by the claim, or if it uses a different calculation methodology, such as a rolling average of raw inputs.

V. Key Claim Terms for Construction

U.S. Patent No. 10,893,833

  • The Term: "a body part made of a non-ceramic material" (from claim 1)
  • Context and Importance: This term is central because the accused product is advertised as having a titanium shell with a tungsten carbide carbon coating (Compl. ¶32). The definition will determine whether a metal body with specific coatings falls within the scope of the claim. Practitioners may focus on this term because the identity of the "body part" versus its various layers or coatings could be a point of non-infringement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification explicitly states that the "non-ceramic material" can be "plastic, metal (such as titanium, steel, platinum, gold, palladium, silver or bronze or a gold based alloys), rubber or any combination thereof" (’833 Patent, col. 4:16-20). This language appears to directly support reading the claim on a titanium-based product.
    • Evidence for a Narrower Interpretation: A party could argue that the "body part" must be considered as a whole, including its coatings, and that the combination of materials might be construed in a way that falls outside the claim. However, the specification's explicit inclusion of titanium presents a challenge to a narrower construction.

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

  • The Term: "readiness score" (from claim 1)
  • Context and Importance: The accused product calculates a "Recovery Score" (Compl. ¶44). The infringement analysis will depend on whether this accused score is equivalent to the claimed "readiness score." The term appears throughout the claims and is fundamental to the patent's purpose.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent defines "readiness" broadly as an "estimated readiness of the user to perform well at a given day" which "summarizes both physical and mental prerequisites for a good day" and "covers the effects of earlier physical activity, previous night's sleep, and body responses measured lately" (’429 Patent, col. 4:43-49). This broad, functional definition may support encompassing the accused "Recovery Score," which is described as an "aggregate measure of five parameters determining your body's preparedness for the next day" (Compl. ¶44).
    • Evidence for a Narrower Interpretation: A party could argue that the specific calculation method—requiring inputs of a "body response summary" and a "previous body response summary"—narrows the term to a score calculated in a very specific manner, potentially distinguishing it from the accused product's algorithm.

VI. Other Allegations

  • Indirect Infringement: For all four patents, the complaint alleges induced infringement, stating that Ultrahuman encourages infringement by its customers who wear and use the Accused Instrumentalities (e.g., Compl. ¶¶28, 42, 58, 75). For the ’429 method patent, the complaint alleges that Ultrahuman induces users to practice the patented process (Compl. ¶42).
  • Willful Infringement: Willfulness is alleged for all four asserted patents. The complaint bases this on alleged knowledge of the patents since at least their issuance dates, and further supports the allegation with claims of a "bold and deliberate effort to replicate the Oura Ring," including hiring former Oura employees and copying user interface designs and marketing materials (Compl. ¶¶1, 9, 11-13).

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

  • A threshold legal issue will be one of justiciability: what is the effect of the plaintiff's post-suit statutory disclaimers of the asserted claims of the ’833 and ’429 patents? The court will have to determine whether the infringement counts for these two patents can proceed or must be dismissed as moot, potentially narrowing the case to the two more recently issued patents.
  • A central technical question will be one of algorithmic equivalence: for the ’429 patent, does the accused "Recovery Score" operate in the same way as the claimed "readiness score"? This will likely require a detailed analysis of whether the accused system's use of inputs like a "Sleep Quotient" and "Movement Index" constitutes the claimed steps of generating and using a "rest summary," "activity summary," and "body response summary" based on both current and previous periods.
  • For the patents directed to physical structure (’833, ’178, and ’179), a core issue will be one of structural mapping: does the physical construction of the Ultrahuman Ring, as manufactured and sold, contain each of the specific structural elements required by the asserted claims, particularly regarding the materials used, the arrangement of internal components within cavities, and the configuration of the multi-wavelength optical sensors?