DCT
2:24-cv-00215
Slyde Analytics LLC v. Garmin Ltd
I. Executive Summary and Procedural Information
- Case Name: Slyde Analytics LLC v. Garmin Ltd.
- Parties & Counsel:
- Plaintiff: Slyde Analytics LLC (Texas)
- Defendant: Garmin Ltd. (Switzerland) and Garmin Corporation (Taiwan)
- Plaintiff’s Counsel: Fabricant LLP; Rubino IP
- Case Identification: 2:24-cv-00215, E.D. Tex., 03/27/2024
- Venue Allegations: Plaintiff alleges venue is proper because Defendants are not residents of the United States and may therefore be sued in any judicial district, pursuant to 28 U.S.C. § 1391(c)(3). The complaint further alleges that Defendants conduct substantial business in the district, including through authorized dealers.
- Core Dispute: Plaintiff alleges that Defendant’s smartwatches and related fitness tracking devices infringe nine patents related to wearable device technology, including user interfaces, power management systems, simulated mechanical watch faces, and methods for analyzing biomechanical parameters of an athlete's stride.
- Technical Context: The case concerns the technology inside modern smartwatches and fitness trackers, a highly competitive consumer electronics market focused on health, athletic performance, and general-purpose wearable computing.
- Key Procedural History: The complaint does not reference any prior litigation, Inter Partes Review (IPR) proceedings, or other significant procedural events related to 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 & 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 & 10,198,085 |
| 2013-11-19 | Issue Date for U.S. Patent No. 8,588,033 |
| 2016-04-26 | Issue Date for U.S. Patent No. 9,320,457 |
| 2017-01-03 | Issue Date for U.S. Patent No. 9,536,134 |
| 2017-05-16 | Issue Date for U.S. Patent No. 9,651,922 |
| 2017-10-31 | Issue Date for U.S. Patent No. 9,804,678 |
| 2018-01-23 | Issue Date for U.S. Patent No. 9,873,018 |
| 2019-02-05 | Issue Date for U.S. Patent No. 10,198,085 |
| 2023-06-27 | Issue Date for U.S. Patent No. 11,687,809 |
| 2024-01-16 | Issue Date for U.S. Patent No. 11,875,696 |
| 2024-03-27 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,588,033 - “Wristwatch with Electronic Display” (Issued Nov. 19, 2013)
The Invention Explained
- Problem Addressed: The patent describes a need for an electronic watch that captures the aesthetic "fascination of fine mechanical watches" while retaining the accuracy and versatility of an electronic device (’033 Patent, col. 2:5-16).
- The Patented Solution: The invention is a wristwatch with an electronic display and a microcontroller programmed to reproduce a "simulation of a mechanical watch movement" (’033 Patent, Abstract). This is not merely a static image or video loop; the microcontroller calculates the position of the simulated components in real time and synchronizes the time indicated by the simulated movement with an accurate quartz oscillator (’033 Patent, col. 4:1-5; Compl. ¶57). The simulation can also be made to react to external forces, such as gravity or shocks, as measured by an on-board accelerometer (’033 Patent, col. 3:25-36).
- Technical Importance: The technology aimed to merge the traditional aesthetic appeal of mechanical horology with the advanced functional capabilities of emerging smartwatch displays (Compl. ¶19).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶56).
- Independent Claim 1 requires:
- A wristwatch comprising a watchcase, an electronic display, and a quartz oscillator.
- A microcontroller arranged for reproducing on the display a simulation of a mechanical watch movement comprising a gear train, with the simulation being visible to indicate the time.
- The microcontroller is further arranged for synchronizing the displayed time (via the mechanical movement) with the time from the quartz oscillator.
- The complaint does not explicitly reserve the right to assert dependent claims.
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)
The Invention Explained
- Problem Addressed: The patent identifies the ergonomic challenges of navigating complex functions on a small watch screen, noting the limitations of interfaces that rely on tapping predefined zones ("zero-dimension") or simple linear swipes ("one-dimensional") (’922 Patent, col. 1:31-col. 2:16).
- The Patented Solution: The invention discloses a two-dimensional user interface paradigm where full-screen displays, termed "cards," are arranged in a virtual structure, such as a row and a column (’922 Patent, col. 7:13-24). A user navigates by swiping horizontally to scroll through cards in the virtual row and vertically to scroll through cards in the virtual column. This method allows a user to access different functions by replacing the entire displayed card with another, with the replacement card being determined by the direction of the swipe gesture (’922 Patent, Abstract).
- Technical Importance: This approach provides an intuitive method for organizing and accessing a large number of applications or information screens on a compact, touch-sensitive display, a foundational design problem for smartwatches (Compl. ¶20).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶67).
- Independent Claim 1 requires:
- A wristwatch with a digital matrix display and a two-dimensional touch-sensitive glass.
- A processing circuit laid out to interpret signals from the glass for selecting and displaying a "card" on the entire display.
- The circuit is laid out to cause available "cards" to scroll past to "lastingly replace" the initial card with a new one.
- The replacement card is dependent on the initial card and the direction of movement, but is "independent from the starting point and end point of the movement."
- The new card "occupies the whole" of the display and "immediately and without further user intervention" replaces the prior card.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 9,804,678 (and related 10,198,085) - “Method and Circuit for Switching a Wristwatch from a First Power Mode to a Second Power Mode”
- Patent Identification: U.S. Patent No. 9,804,678, "Method and Circuit for Switching a Wristwatch from a First Power Mode to a Second Power Mode," issued Oct. 31, 2017. U.S. Patent No. 10,198,085 is a related patent covering a method.
- Technology Synopsis: The patents describe a power-saving technology for a wristwatch. The invention uses a combination of an inertial sensor (e.g., accelerometer) and a touch panel to reliably detect a user gesture (like a tap or wrist-turn) to switch the device from a low-power 'sleep' mode to a higher-power active mode, while discriminating against accidental activations (’678 Patent, Abstract; ’085 Patent, Abstract).
- Asserted Claims: At least claim 14 of the ’678 Patent and claim 1 of the ’085 Patent (Compl. ¶¶30, 43).
- Accused Features: The accused functionality is the feature in Garmin smartwatches, such as the Forerunner 965, that turns on the screen in response to a user raising and turning their arm, a feature referred to as 'Gesture' in the device settings (Compl. ¶¶31, 34, 44).
U.S. Patent No. 9,320,457 (and related 9,873,018) - “Integrated Portable Device and Method Implementing an Accelerometer for Analyzing Biomechanical Parameters of a Stride”
- 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 Apr. 26, 2016. U.S. Patent No. 9,873,018 is a related patent that adds a GPS receiver.
- Technology Synopsis: The patents disclose a device and method for analyzing a runner's stride. A device worn on the torso uses a triaxial accelerometer (and GPS in the ’018 patent) to measure acceleration data, from which a processor calculates biomechanical parameters like vertical oscillation, ground contact time, and stride length (’457 Patent, Abstract; ’018 Patent, Abstract).
- Asserted Claims: At least claim 1 of the ’457 Patent and claim 1 of the ’018 Patent (Compl. ¶¶78, 92).
- Accused Features: The complaint accuses Garmin's 'Running Dynamics' features, which use the Forerunner 965's built-in accelerometer and GPS to track and display running metrics such as cadence, stride length, and vertical oscillation (Compl. ¶¶79, 83, 93-98).
U.S. Patent No. 9,536,134 - “Athlete Performance Monitoring Device”
- Patent Identification: U.S. Patent No. 9,536,134, "Athlete Performance Monitoring Device," issued Jan. 3, 2017.
- Technology Synopsis: The patent describes a system comprising an accelerometer that communicates wirelessly with a separate user-worn processing device (e.g., a smartphone). The system is configured to conserve power by having the processing system request acceleration data from the accelerometer only when a "predefined event has occurred," such as reaching a certain point in a race (’134 Patent, Abstract).
- Asserted Claims: At least claim 1 (Compl. ¶108).
- Accused Features: The complaint targets Garmin's 'PacePro' feature, which allows a user to set a pace plan for a race and tracks performance against that plan at specific intervals (e.g., every mile or kilometer) (Compl. ¶¶109-110).
U.S. Patent No. 11,687,809 - “Method and Apparatus for Predicting a Race Time”
- Patent Identification: U.S. Patent No. 11,687,809, "Method and Apparatus for Predicting a Race Time," issued Jun. 27, 2023.
- Technology Synopsis: The patent covers a method for providing real-time race information to an athlete, such as a race time prediction. A wearable device measures intermediate times during a race and uses this data to retrieve a pre-defined "race profile"—a non-linear function of time over distance—which is then used to predict the final outcome (’809 Patent, Abstract).
- Asserted Claims: At least claim 20 (Compl. ¶119).
- Accused Features: The allegations again target Garmin's 'PacePro' feature, which provides real-time feedback on whether the user is ahead of or behind a pre-set pace, effectively predicting their ability to achieve a target time (Compl. ¶120).
U.S. Patent No. 11,875,696 - “Method and Device for Retrieving Biomechanical Parameters of a Stride”
- Patent Identification: U.S. Patent No. 11,875,696, "Method and Device for Retrieving Biomechanical Parameters of a Stride," issued Jan. 16, 2024.
- Technology Synopsis: The patent discloses a method to improve the accuracy of biomechanical analysis from an accelerometer worn on a limb (e.g., wrist, arm) or the head. The method involves identifying frequency components in the acceleration data caused by the "extra-motions" of the limb relative to the runner's center of mass (e.g., arm swing) and attenuating those components to determine the true biomechanical parameters of the stride (’696 Patent, Abstract).
- Asserted Claims: At least claim 17 (Compl. ¶133).
- Accused Features: The complaint accuses the Garmin Forerunner 965 of infringement by determining biomechanical parameters from its wrist-mounted accelerometer, which necessarily involves processing data that includes both stride motion and "extra-motions" from the arm (Compl. ¶134).
III. The Accused Instrumentality
Product Identification
The complaint primarily names the Garmin Forerunner 965 smartwatch as the exemplary accused product (Compl. ¶29). It also broadly accuses numerous other Garmin smartwatches and fitness information tracking devices, including the Venue, Instinct, Epix, Fenix, and Vivoactive lines, among others (Compl. ¶¶19-25).
Functionality and Market Context
- The Garmin Forerunner 965 is described as a high-end smartwatch with an AMOLED display, a touch screen, and a processor (Compl. ¶¶31-32, 68). Its accused features include power-saving gesture controls, a swipe-based user interface for navigating "glances," downloadable watch faces that simulate mechanical movements, and advanced software for tracking and analyzing athletic performance in real-time, such as 'Running Dynamics' and 'PacePro' (Compl. ¶¶31, 58, 69, 79, 110, 120).
- The complaint alleges Garmin is "one of the leading smartwatch sellers in the United States and the world" (Compl. ¶2). A screenshot from Garmin's website shows its dealer locator for the area around the court, illustrating its business presence (Compl. p. 2). The accused products are part of Garmin's core "fitness and outdoor product lines" (Compl. ¶3).
IV. Analysis of Infringement Allegations
U.S. Patent No. 8,588,033 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A wristwatch comprising a watchcase, an electronic display in said watchcase, and a quartz oscillator | The Garmin Forerunner 965 is a wristwatch with a watchcase, electronic display (AMOLED), and a quartz oscillator. | ¶57 | col. 4:9-15 |
| a microcontroller being arranged for reproducing on the electronic display the simulation of a mechanical watch movement comprising a gear train | The Forerunner 965 has a microcontroller (processor) and allows users to download watch faces from the Connect IQ Store that simulate mechanical watch movements, including some with visible gear trains. An example "Art Deco" watch face is provided as visual evidence (Compl. p. 21). | ¶¶57-58 | col. 2:38-45 |
| the simulation being visible so as to indicate the time | The simulated mechanical movement is displayed on the screen to show the current time. | ¶57 | col. 2:38-40 |
| the microcontroller being further arranged for synchronizing the displayed time by the displayed mechanical movement with that of the quartz oscillator | The microcontroller synchronizes the time shown by the simulated mechanical movement with the time kept by the device's quartz oscillator. | ¶57 | col. 4:1-5 |
- Identified Points of Contention:
- Scope Questions: A central question may be whether a general-purpose smartwatch that runs third-party software (a watch face app) meets the claim limitation of a "wristwatch comprising a microcontroller being arranged for reproducing" the simulation. The dispute could focus on whether the specific arrangement must be inherent to the device as sold, or if it can be created by software downloaded later.
- Technical Questions: The case may turn on the definition of "simulation." The patent specification discusses calculating the movement based on physical laws and external forces (’033 Patent, col. 3:25-36). The question is whether the accused graphical watch faces perform such a "simulation" or are merely pre-rendered animations, and whether the latter falls within the scope of the claim.
U.S. Patent No. 9,651,922 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a wristwatch comprising a digital matrix display...a sheet of touch-sensitive glass...a processing circuit | The Garmin Forerunner 965 is a wristwatch with a 1.4" AMOLED digital matrix display, touch-sensitive glass, and a processing circuit. | ¶68 | col. 4:1-5 |
| said touch-sensitive glass is a two-dimensional glass for detecting a movement of at least one finger at any place on the touch-sensitive glass along at least two different directions | The Forerunner 965 touchscreen detects user swipes "left, right, up, or down." Visual evidence from the user manual illustrates these multi-directional swipe gestures (Compl. p. 25). | ¶¶68-69 | col. 3:37-41 |
| said processing circuit is specifically laid out so as to cause several available cards to scroll past in order to lastingly replace the initially displayed card with a replacement card | The processing circuit causes different faces and/or applications ("cards") to scroll and replace one another in response to swipes. | ¶68 | col. 4:50-55 |
| the replacement card is dependent from the initially displayed card and from the direction of the movement | The complaint alleges that the new application/face displayed depends on the direction of the user's swipe. | ¶68 | col. 4:12-17 |
| and is independent from the starting point and end point of the movement on the digital matrix display | The complaint alleges this element is met but provides no specific facts explaining how the operation is independent of the swipe's start and end points. | ¶68 | col. 8:56-62 |
- Identified Points of Contention:
- Scope Questions: The definition of "card" will be critical. The question is whether Garmin's "glances" or widgets, which a user swipes through, meet the patent's description of full-screen "cards" arranged in a specific virtual structure.
- Technical Questions: A key point of contention may be the limitation that the replacement card is "independent from the starting point and end point of the movement." This language suggests a "flick" or inertial scrolling gesture, where the scrolling continues after the finger is lifted. The complaint does not provide evidence that the accused Garmin interface operates in this specific manner, creating a potential mismatch in technical operation.
V. Key Claim Terms for Construction
For the ’033 Patent:
- The Term: "simulation of a mechanical watch movement"
- Context and Importance: This term is the central inventive concept. Its construction will determine whether a simple graphical animation of watch parts infringes, or if a more complex, physics-based calculation is required. Practitioners may focus on this term because the patent's specification describes a "calculated simulation of the position of the displayed elements taking into account for example the simulated shape and mass of these elements" (’033 Patent, col. 3:28-32).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent's abstract simply refers to displaying a "simulated mechanical watch movement," which could be argued to cover any visual representation that mimics a mechanical movement.
- Evidence for a Narrower Interpretation: The detailed description repeatedly refers to a "calculated simulation" based on "correct physical laws" and inputs from an accelerometer, suggesting something more than a pre-recorded animation is contemplated (’033 Patent, col. 3:25-36).
For the ’922 Patent:
- The Term: "card"
- Context and Importance: The entire navigation paradigm of the ’922 patent is based on scrolling through "cards." The infringement analysis depends on whether Garmin's UI elements (e.g., "glances," widgets) are properly categorized as "cards" under the patent's definition.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent defines a card as a "control, or widget, displayed on the watch's graphical interface to represent on the entire screen a unit such as the current time, a phase of the moon, a chronograph display etc." (’922 Patent, col. 4:18-22). This broad definition could be argued to encompass Garmin's full-screen glances.
- Evidence for a Narrower Interpretation: The patent consistently describes the cards as being arranged in a specific virtual structure (e.g., a cross shape of a row and column) that a user navigates (’922 Patent, col. 7:13-16). If Garmin's UI is merely a linear loop, it might not meet the structural context implied for "cards."
VI. Other Allegations
- Indirect Infringement: For all asserted patents, the complaint alleges induced infringement. The basis for this allegation is that Garmin provides user manuals, product literature, and its website with instructions that allegedly direct end-users to operate the accused products in an infringing manner (e.g., instructing them how to use the 'Gesture' feature or download watch faces) (Compl. ¶¶35, 37, 59, 61).
- Willful Infringement: The complaint alleges that Defendants had knowledge of the patents-in-suit at least as of the date the complaint was filed (Compl. ¶¶36, 49). It further alleges willful blindness, stating on information and belief that Defendants have "adopted a policy of not reviewing the patents of others," thereby remaining willfully blind to their infringement (Compl. ¶36).
VII. Analyst’s Conclusion: Key Questions for the Case
This multifaceted litigation will likely turn on several key technical and legal questions for the court to resolve.
- A primary issue will be one of definitional scope: Across multiple patents, the analysis will depend on whether Garmin's specific implementations (e.g., "glances," "gestures," graphical watch faces) fall within the patent-specific claim terms like 'card' ('922), 'simulation' ('033), and the precise multi-step definition of a 'wristturn' ('085).
- A second core issue is one of software-enabled infringement: For apparatus claims like those in the '033 patent, a key question will be whether a general-purpose hardware device infringes when the allegedly infringing functionality is provided by software (a watch face) that is downloaded by the user post-sale.
- A third area of focus will be technical and algorithmic equivalence: For the biomechanical patents ('457, '018, '696), a central evidentiary question will be whether the algorithms Garmin uses to process sensor data from a wrist-worn device perform the specific steps of calculating stride parameters, and particularly of filtering "extra-motions" as claimed in the '696 patent.