Mobile Health Innovative Solutions LLC v. Samsung Electronics Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Mobile Health Innovative Solutions, LLC (Wyoming)
  • Defendant: Samsung Electronics Co., LTD (Republic of Korea); Samsung Electronics America, Inc. (New York)
  • Plaintiff’s Counsel: Garteiser Honea, PLLC
• Case Identification: 2:24-cv-00106, E.D. Tex., 02/16/2024
• Venue Allegations: Venue is alleged to be proper as to the foreign parent company, Samsung Electronics Co., LTD, because it is not a U.S. resident and can be sued in any judicial district. Venue is alleged to be proper as to the U.S. subsidiary, Samsung Electronics America, Inc., based on its registration to do business in Texas and its maintenance of regular and established places of business within the district.
• Core Dispute: Plaintiff alleges that Defendant’s Galaxy Watch5 Pro and associated health monitoring applications infringe a patent related to determining a user's physiological load or stress level by analyzing biometric data from multiple sources, including device sensors and application usage.
• Technical Context: The technology operates in the wearable health-tech and mobile device sector, where data from on-device sensors is processed to provide users with insights into their physiological state.
• Key Procedural History: The complaint notes that during the patent's examination, the U.S. Patent and Trademark Office examiner conducted a search of prior art and, after consideration, allowed all claims to issue.

Case Timeline

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

U.S. Patent No. 11,468,984 - Device, Method and Application for Establishing a Current Load Level

Issued October 11, 2022

The Invention Explained

• Problem Addressed: The patent asserts that prior methods for determining a user's stress level were disadvantaged by being unreliable, as they relied on very few categories of biometric data, or were inconvenient, as they required the use of special dedicated sensors worn on the body or demanded high user effort, such as repeatedly filling out questionnaires (’984 Patent, col. 2:4-34).
• The Patented Solution: The invention describes a system where a software application on a general-purpose mobile terminal (e.g., a smartphone) establishes a user's "load level" by collecting and analyzing a multiplicity of biometric data types (’984 Patent, col. 2:56-59). Crucially, this data is gathered from two distinct sources: (1) signal data from sensors integrated into the mobile device itself (e.g., gyroscope, microphone), and (2) user data extracted from the use of other "available applications" on the device (e.g., SMS or telephony apps) (’984 Patent, col. 3:25-45; Fig. 1). An evaluation unit then processes this diverse data, often using a neural network, to determine a stress level.
• Technical Importance: This approach seeks to provide a more reliable and nuanced assessment of a user's physiological state by combining multiple, disparate data streams, while minimizing user burden by leveraging the hardware and software already present on a standard mobile device (’984 Patent, col. 2:45-54).

Key Claims at a Glance

• The complaint asserts infringement of independent claims 1 and 12, and dependent claims 5 and 11, noting these are asserted "at least" (Compl. ¶27).
• Independent Claim 1 (a device) includes the following essential elements:
  • A mobile end unit with at least one integrated sensor and a plurality of available applications.
  • An evaluation unit (on the device or a central server).
  • A "further application" on the unit that calculates biometric data from both sensor signals and "user data" from the available applications.
  • The biometric data is divided into a plurality of categories, and "category-specific load levels" are ascertained.
  • The evaluation unit determines the user's current load level by applying a method carried out in a "network of artificial neural networks that includes a plurality of artificial neural networks that interact with each other."
• Independent Claim 12 (a method) includes the following essential elements:
  • Starting a "further application" on a mobile end unit.
  • Calculating biometric data using the application, where the data is recorded from user data from a plurality of applications and calculated from signal data from at least one sensor.
  • Dividing the biometric data into categories and ascertaining "category-specific load levels."
  • Evaluating the biometric data with an evaluation unit to determine the current load level "with the aid of a network of artificial neural networks."

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are the "Galaxy Watch5 Pro, which is compatible with multiple apps such as the Samsung Health app and Samsung Health Monitor app that are used for calculating stress level" (Compl. ¶27).

Functionality and Market Context

The complaint alleges that these products, collectively, are used for the purpose of "calculating stress level" (Compl. ¶27). The complaint does not provide further technical detail regarding the specific operation of the accused products, instead incorporating by reference a claim chart attached as Exhibit B, which was not included with the publicly filed complaint (Compl. ¶¶27, 33). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not contain a claim chart within its body, instead referring to an external Exhibit B that was not filed with the complaint (Compl. ¶¶32, 33). The narrative infringement theory alleges that Samsung's accused products practice the technology claimed by the ’984 Patent and that they "satisfy all elements of the exemplary Claims 1, 5, 11 and 12" (Compl. ¶32). The core of the allegation is that the "Products," used for calculating stress levels, infringe the patent's claims for a device and method that do the same (Compl. ¶27).

Identified Points of Contention

Based on the claim language and the general nature of the accused products, the litigation may focus on several key questions.

• Scope Questions: A central question may be whether the combination of a smartwatch (Galaxy Watch5 Pro) and associated software (Samsung Health apps) constitutes the "mobile end unit" having a "further application" and a "plurality of available applications" as described in the patent, which primarily uses a smartphone as its exemplary embodiment (’984 Patent, col. 2:25-29).
• Technical Questions: The complaint makes a conclusory allegation of infringement but provides no specific factual support for how the accused products meet highly technical claim limitations. An evidentiary question for the court will be whether the plaintiff can prove that Samsung's system:
  1. Calculates a stress level by combining data from both raw sensor signals and "user data" derived from other "available applications," as required by the claims.
  2. Employs the specific architecture of a "network of artificial neural networks that includes a plurality of artificial neural networks that interact with each other," rather than a single neural network or an alternative machine learning model.

V. Key Claim Terms for Construction

The Term: "network of artificial neural networks that includes a plurality of artificial neural networks that interact with each other" (Claim 1)

• Context and Importance: This term defines a specific and complex technical architecture. The infringement analysis will hinge on whether Samsung’s stress-calculation algorithm can be shown to use this particular multi-network structure. Practitioners may focus on this term because it appears to be a significant point of novelty and a potentially high bar for the plaintiff to prove is met by the accused system.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent describes various neural network types, including a "multilayer perceptron network" (’984 Patent, col. 6:20-24). A party could argue the term should be read more broadly to encompass different configurations of interacting machine learning components, not just one specific implementation.
  • Evidence for a Narrower Interpretation: The specification provides a detailed description and figure for a "network of artificial neural networks" in the form of a "deep belief network" or "convolutional deep belief network 50" (’984 Patent, col. 21:35-42; Fig. 6). A party could argue this detailed disclosure limits the claim term to such complex, hierarchical structures composed of multiple, distinct neural networks.

The Term: "user data of said plurality of available applications used by the user" (Claim 1)

• Context and Importance: This term is critical because it requires the patented system to draw data not just from sensors, but from the user's interaction with separate software applications. Proving that the accused system accesses and uses this type of data for stress calculation will be essential for the plaintiff.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent provides examples such as evaluating data from "SMS applications, e-mail applications or social network applications" (’984 Patent, col. 17:10-14). This could support an interpretation that covers high-level metadata about application usage (e.g., frequency of messaging).
  • Evidence for a Narrower Interpretation: The patent also provides a very specific example of an "observer" that records "all keypad inputs by the user" when using an SMS application (’984 Patent, col. 8:50-65). A party could argue that "user data" is limited to this type of specific, content-level information actively extracted from an application's operation, not just general usage statistics.

VI. Other Allegations

Indirect Infringement

The complaint alleges inducement of infringement, stating that Samsung distributes "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes" (Compl. ¶30). It is further alleged that Samsung knowingly and intentionally induces infringement post-filing (Compl. ¶31).

Willful Infringement

The willfulness allegation is based on knowledge of infringement "at least as of the service of the present complaint" (Compl. ¶25). The complaint alleges that despite this knowledge, Samsung continues its infringing activities, which forms the basis for potential enhanced damages (Compl. ¶30).

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

• A core issue will be one of architectural equivalence: can the plaintiff produce evidence that Samsung's stress calculation algorithm uses the specific "network of artificial neural networks that interact with each other" as recited in the claims, or does it utilize a different and non-infringing machine learning architecture?
• A key evidentiary question will be one of data integration: can the plaintiff demonstrate that the accused Samsung Health system determines stress not only from biometric sensor data, but also by actively collecting and incorporating "user data" from a "plurality of available applications" on the device, as strictly required by the patent's claims?