DCT

2:24-cv-00331

Slyde Analytics LLC v. Apple Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:24-cv-00331, E.D. Tex., 05/06/2024
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Apple maintains regular and established places of business within the district, specifically through its operation of "Apple Shops" within Best Buy retail locations where accused products are sold and serviced.
  • Core Dispute: Plaintiff alleges that Defendant’s smartwatches and smartphones infringe eleven patents related to smartwatch user interfaces, power management, and the biomechanical analysis of user movement.
  • Technical Context: The technologies at issue pertain to wearable electronic devices, focusing on methods to improve user interaction, conserve battery life, and provide detailed athletic performance and health monitoring.
  • Key Procedural History: The complaint alleges that Defendant had pre-suit knowledge of numerous patents-in-suit because Defendant cited the patents or their family members during the prosecution of its own patent applications. This assertion forms the primary basis for the allegations of willful infringement.

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; 11,833,391
2011-06-08 Priority Date for U.S. Patent No. 10,881,905
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
2016-10-06 Priority Date for U.S. Patent No. 11,687,809
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
2017-08-29 Priority Date for U.S. Patent No. 11,875,696
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
2021-01-05 Issue Date for U.S. Patent No. 10,881,905
2023-06-27 Issue Date for U.S. Patent No. 11,687,809
2023-12-05 Issue Date for U.S. Patent No. 11,833,391
2024-01-16 Issue Date for U.S. Patent No. 11,875,696
2024-05-06 Complaint Filing Date

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"

  • Issued: October 31, 2017

The Invention Explained

  • Problem Addressed: The patent describes the technical challenge of designing a power-saving "sleep" mode for a wristwatch that can be exited by a user's gesture without frequent, unintended activations caused by normal arm movements or accelerations from activities like sports. (’678 Patent, col. 2:7-16).
  • The Patented Solution: The invention proposes a dual-sensor system that combines an inertial sensor (e.g., an accelerometer) with a touch panel to trigger a switch from a low-power mode to an active one. The system improves reliability by discriminating an intentional "tap" gesture not just by the amplitude of acceleration, but by analyzing its frequency, direction, and/or slope, which are more distinctive signatures of a deliberate user action. (’678 Patent, Abstract; col. 2:37-46).
  • Technical Importance: This approach aims to enhance the usability and battery life of smartwatches by creating a more robust "wake-up" mechanism that can better distinguish intentional user commands from incidental movements. (’678 Patent, col. 2:7-16).

Key Claims at a Glance

  • The complaint asserts at least independent claim 14 (Compl. ¶35).
  • The essential elements of claim 14 include:
    • A wristwatch operable in at least a first and second power mode.
    • A display, a microcontroller, a touch panel, and a touch controller.
    • An inertial sensor with an accelerometer and a processor arranged to discriminate between a gesture and no gesture based on the direction, slope, or frequency of an acceleration signal.
    • The system operates while the microcontroller and touch controller are in a "sleep power mode."
    • The touch controller is switched to the second power mode upon gesture detection by the inertial sensor.
    • The microcontroller is switched to the second power mode upon a subsequent tap gesture detection by the touch controller.

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

  • Issued: February 5, 2019

The Invention Explained

  • Problem Addressed: As with its parent patent, the '085 Patent addresses the need for a reliable method to switch a wristwatch out of a power-saving mode while avoiding false activations from everyday movements. (’085 Patent, col. 2:7-16).
  • The Patented Solution: The patent claims a method for switching power modes based on detecting a specific "wristturn" gesture using an accelerometer. The method requires detecting that the watch is held in a "starting position" within a first angular range for a defined time, then moves to a "final position" in a different range, and then remains "substantially immobile" for a predetermined duration. This defined sequence of events triggers the switch to the active power mode. (’085 Patent, claim 1; col. 9:28-40).
  • Technical Importance: The invention provides a specific, multi-stage gesture recognition algorithm for a common "wrist raise" action, aiming to improve wake-up accuracy over simpler motion detection systems and conserve battery. (’085 Patent, col. 9:28-67).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1. (Compl. ¶48).
  • The essential elements of method claim 1 include:
    • Switching a wristwatch from a first power mode to a second power mode upon detection of a "wristturn" by an accelerometer.
    • Detecting that the watch's orientation is held in a starting position within a first range for a defined time.
    • Detecting that the orientation then moves to a final position in a second, different range.
    • In response, detecting that the watch remains substantially immobile for a predetermined duration.
    • The duration between the starting and final positions is within a predefined range.

U.S. Patent No. 8,588,033 - "Wristwatch with Electronic Display"

  • Issued: November 19, 2013
  • Technology Synopsis: The patent relates to a wristwatch with an electronic display that reproduces a simulation of a mechanical watch movement, including a visible gear train. A microcontroller synchronizes the time displayed by the simulated mechanical movement with a quartz oscillator. (Compl. ¶22, ¶62).
  • Asserted Claims: At least claim 1 (Compl. ¶61).
  • Accused Features: The Apple Watch Ultra 2's ability to run third-party applications, such as Facer, that permit users to download and display watch faces simulating mechanical watch movements. A visual in the complaint shows an example "MOD-2010 Mechanical" watch face available for the device. (Compl. ¶63, p. 27).

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 describes a wristwatch with a touch-sensitive display where a user can scroll through different full-screen "cards" (e.g., watch faces or application views). The processing circuit is laid out to replace an initially displayed card with a new one based on the direction of a finger's movement on the screen. (Compl. ¶23, ¶73).
  • Asserted Claims: At least claim 1 (Compl. ¶72).
  • Accused Features: The Apple Watch Ultra 2's functionality that allows a user to change the watch face by touching and holding the screen to enter "Edit mode" and then swiping left or right to select a new face. (Compl. ¶74).

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 relates to a device with a power source, accelerometer, and digital processor for analyzing a runner's stride. The processor calculates biomechanical parameters, such as the vertical oscillation of the runner's center of gravity, based on acceleration data. (Compl. ¶25, ¶87).
  • Asserted Claims: At least claim 1 (Compl. ¶83).
  • Accused Features: The Apple Watch Ultra 2's run tracking software (e.g., the Workout App), which uses its accelerometer to track and display running metrics including "Vertical Oscillation." A screenshot from Apple's website lists "Vertical oscillation" as a metric available in "Outdoor Run workouts." (Compl. ¶84, ¶87, p. 35).

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 expands on the technology of the '457 patent by incorporating a GPS receiver alongside the accelerometer. The digital processor uses data from both sensors to calculate biomechanical parameters of a runner's stride. (Compl. ¶25, ¶102).
  • Asserted Claims: At least claim 1 (Compl. ¶97).
  • Accused Features: The Apple Watch Ultra 2, which includes both a "precision dual-frequency GPS antenna" and an accelerometer, and its associated software that uses both sensors to track running information such as stride and running cadence. (Compl. ¶¶100-102).

U.S. Patent No. 9,536,134 - "Athletic Performance Monitoring Device"

  • Issued: January 3, 2017
  • Technology Synopsis: The patent describes an athletic performance monitoring system comprising an accelerometer that is wirelessly connected to a user-worn device with a processing system. The system requests acceleration data from the accelerometer only when a predefined event occurs and processes the data to provide performance information. (Compl. ¶26, ¶115).
  • Asserted Claims: At least claim 1 (Compl. ¶113).
  • Accused Features: The Apple Watch Ultra 2 and its ability to track a user's running pace at certain intervals (a predefined event) to determine if they are on a pace set by the user. (Compl. ¶¶114-115).

U.S. Patent No. 11,687,809 - "Method and Apparatus for Predicting a Race Time"

  • Issued: June 27, 2023
  • Technology Synopsis: The patent relates to a method and device for predicting a race time or providing pace feedback to an athlete during a race. The system retrieves a "race profile" based on intermediate times measured during the race and compares it to predefined profiles to determine if the athlete's pace is adequate to achieve a target time. (Compl. ¶28, ¶125, ¶127).
  • Asserted Claims: At least claim 20 (Compl. ¶124).
  • Accused Features: The Apple Watch Ultra 2's "Pacer" workout feature, which allows a user to set a target pace for a distance and shows a graph of whether the user is ahead of or behind that pace. The complaint also points to the "Race Route" feature, which allows a user to race against their last or best time on a known route. (Compl. ¶125, ¶129, p. 49, p. 52).

U.S. Patent No. 11,875,696 - "Method and Device for Retrieving Biomechanical Parameters of a Stride"

  • Issued: January 16, 2024
  • Technology Synopsis: The patent describes a method for more accurately determining a runner's biomechanical parameters from a body-worn accelerometer (e.g., on the wrist). The system identifies and attenuates frequency components in the acceleration data caused by "extra-motions" (like arm swing) relative to the runner's center of mass to create a modified data sequence for analysis. (Compl. ¶27, ¶139).
  • Asserted Claims: At least claim 17 (Compl. ¶138).
  • Accused Features: The Apple Watch Ultra 2, which is worn on the wrist and contains an accelerometer and a processing system for determining biomechanical parameters of a runner's stride. (Compl. ¶139).

U.S. Patent No. 11,833,391 - "Integrated Portable Device and Method Implementing an Accelerometer for Analyzing Biomechanical Parameters of a Stride"

  • Issued: December 5, 2023
  • Technology Synopsis: This patent relates to a method for computing specific biomechanical parameters, including "stiffness" and "reactivity" (the ratio between flight time and contact time), from acceleration data gathered by a device with an accelerometer and GPS. (Compl. ¶29, ¶153).
  • Asserted Claims: At least claim 1 (Compl. ¶148).
  • Accused Features: The Apple Watch Ultra 2 and associated software, which use GPS and acceleration sensors to track running information, allegedly including the computation of parameters such as stiffness and reactivity. (Compl. ¶¶152-154).

U.S. Patent No. 10,881,905 - "Integrated Portable Device and Method Implementing an Accelerometer for Detecting Asymmetries in a Movement of a User"

  • Issued: January 5, 2021
  • Technology Synopsis: The patent describes a method for detecting asymmetries in a user's stride by using an accelerometer to gather data, from which a processor calculates parameters like a "stride regularity index" and a "fatigue level indicator." (Compl. ¶30, ¶165).
  • Asserted Claims: At least claim 1 (Compl. ¶163).
  • Accused Features: The iPhone 15 Pro Max and its "Walking Steadiness" feature within the Health App. A screenshot in the complaint shows the app displaying a user's "Walking Steadiness" and "Walking Asymmetry" data, which is allegedly used to estimate stability and fall risk. (Compl. ¶¶164-166, p. 63).

III. The Accused Instrumentality

Product Identification

  • The complaint primarily accuses the Apple Watch Ultra 2 of infringing the '678, '085, '033, '922, '457, '018, '134, '809, '696, and '391 patents. The iPhone 15 Pro Max is accused of infringing the '905 patent. (Compl. ¶¶ 35, 48, 61, 72, 83, 97, 113, 124, 138, 148, 163).

Functionality and Market Context

  • The complaint describes the Apple Watch Ultra 2 as a smartwatch with multiple power modes (e.g., "sleep," "low power mode," "awake"), an "always-on retina display," a touch panel, a microcontroller (the "S9 SiP"), and various sensors, including a "High-g accelerometer" and GPS. (Compl. ¶36, ¶37, ¶101). Its software allegedly uses these components to switch between power modes based on user gestures like a wrist raise or a screen tap. (Compl. ¶39). The complaint includes a screenshot from an Apple support document illustrating settings to "Wake the Apple Watch Ultra display" through these actions. (Compl. p. 16).
  • The device's software, such as the Workout App, is alleged to use the sensors to track detailed running metrics, including vertical oscillation, stride length, and cadence, and to provide pacing feedback relative to user-set goals. (Compl. ¶87, ¶125).
  • The iPhone 15 Pro Max is described as a smartphone with a digital processor, a rechargeable battery, and an accelerometer, which works with the Health App to monitor a user's "Walking Steadiness" and "Walking Asymmetry." (Compl. ¶¶164-165).

IV. Analysis of Infringement Allegations

'678 Patent 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 Apple Watch Ultra 2 operates in multiple power modes, such as "sleep" or "low power mode" and "awake" or "normal power mode." ¶36 col. 5:48-61
a display...a microcontroller...a touch panel underneath a cover glass...a touch controller The accused watch includes an "always-on retina display," an "S9 SiP" (microcontroller), a touch panel under its cover glass, and a touch controller. ¶37 col. 4:16-48; col. 5:12-14, 31-35
an inertial sensor comprising an accelerometer and a processor... arranged for discriminating between gesture and no gesture based on a direction... and on a slope or frequency of the acceleration signal The accused watch includes an accelerometer and processor that allegedly discriminate between gestures and non-gestures based on the direction and slope or frequency of the acceleration signal. ¶37 col. 6:22-67
while the microcontroller and the touch controller are in a sleep power mode The functionality is alleged to operate while the device's microcontroller and touch controller are in a low-power or "sleep" state. ¶37 col. 5:56-61
wherein the 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... Upon detection of a gesture by the inertial sensor, the touch controller is allegedly switched to an active mode to detect a tap on the screen. ¶38 col. 6:29-34
wherein the microcontroller is... commanded to be switched to the second power mode upon a tap gesture detection by the touch controller... Upon detection of a tap by the touch controller, the microcontroller is allegedly switched to the active power mode to control the display. ¶38 col. 8:1-12

Identified Points of Contention

  • Scope Questions: A question may arise as to whether the Apple Watch's "Always On" display, which remains active in a dimmed state, meets the claim limitation of the microcontroller and touch controller being in a "sleep power mode." The patent specification refers to this mode as one where components are "switched off." (’678 Patent, col. 5:58-59).
  • Technical Questions: The complaint alleges that the accused device discriminates gestures based on direction, slope, or frequency of the acceleration signal. A key question for the court will be what evidence demonstrates that Apple's algorithm uses these specific criteria, as required by the claim, rather than a different method for gesture recognition.

'085 Patent 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, using an accelerometer for detecting a wristturn... The Apple Watch Ultra 2 performs a method of switching from "sleep" to "awake" using its accelerometer to detect a wristturn gesture ("Wake on Wrist Raise"). ¶49, ¶50 col. 9:28-34
detecting that an orientation of the wristwatch is in a starting position... held within a first range for a defined time; The accused method allegedly includes detecting that the watch is in a starting orientation (e.g., wrist down) and held within a first angular range for a defined time. ¶51 col. 10:57-67
detecting that an orientation of the wristwatch is then in a final position... in a second range different from said first range, The method allegedly includes detecting that the watch then moves to a final orientation (e.g., wrist up) within a second, different angular range. ¶51 col. 9:5-16
in response... detecting that the wristwatch remains substantially immobile during a predetermined duration and that a duration between the starting position and the final position is in a predefined range. In response to reaching the final position, the method allegedly detects that the watch remains substantially immobile for a predetermined duration. ¶51 col. 10:25-47

Identified Points of Contention

  • Technical Questions: A central evidentiary question will be whether the "Wake on Wrist Raise" feature of the Apple Watch performs the specific, multi-step logical sequence recited in the claim. The claim requires affirmatively detecting a stable starting position, a move to a final position, and a subsequent period of immobility, all within defined parameters. The dispute may focus on whether the accused functionality operates via this specific algorithm or through a more generalized motion-detection heuristic that does not meet every claimed step.

V. Key Claim Terms for Construction

The Term: "sleep power mode" ('678 Patent, claim 14)

  • Context and Importance: The construction of this term is critical because the accused Apple Watch Ultra 2 features an "Always On" display, where the screen is dimmed rather than fully off in its low-power state. Whether this state qualifies as a "sleep power mode" in which the "microcontroller and the touch controller" operate will be central to the infringement analysis.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent specification, which is shared with the '085 patent, describes a stand-by mode where the display is "switched off or at least less luminous," which may support an interpretation that a dimmed, low-power state is included within the claim's scope. (’085 Patent, col. 5:59-62).
    • Evidence for a Narrower Interpretation: The same section of the specification also states that in one preferred embodiment of the "low power saving mode," "the display 4 and the touch sensor 3b are switched off." (’085 Patent, col. 5:56-59). This language could support a narrower construction requiring the components to be fully powered off, not merely in a reduced-power state.

The Term: "detecting that an orientation of the wristwatch is in a starting position" ('085 Patent, claim 1)

  • Context and Importance: This term defines the first required step of the claimed "wristturn" method. Infringement will depend on whether the accused "Wake on Wrist Raise" feature performs this specific, affirmative detection step, or if it simply reacts to a continuous motion from a generally "down" to a generally "up" orientation without explicitly identifying and timing a stable "starting position."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the starting position generally as being in an angle range "relatively to the horizontal," which could be construed broadly to cover any non-viewing orientation of the watch. (’085 Patent, col. 9:59-62).
    • Evidence for a Narrower Interpretation: The claim language requires "detecting that the orientation of the wristwatch is held within a first range for a defined time." This wording suggests an active process of identifying a stable, qualifying orientation before the wrist turn begins, not just any transient position. Dependent claim 2 specifies an exemplary angular range of "25° to 155° relatively to the horizontal," which could be used to argue for a more constrained, quantitatively defined starting position. (’085 Patent, col. 11:15-18).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement for all eleven patents-in-suit. The allegations are based on Defendant supplying the accused products to end-users along with instructions (e.g., user manuals, online support documents) on how to operate the allegedly infringing features, with the specific intent to cause infringement. (Compl. ¶40, ¶42, ¶53, ¶55).
  • Willful Infringement: The complaint alleges willful infringement for all asserted patents. The primary basis for willfulness is alleged pre-suit knowledge, supported by claims that Defendant cited the patents-in-suit or their family members during the prosecution of its own U.S. patent applications. (Compl. ¶41, fn. 24; ¶54, fn. 28; ¶65, fn. 31). As an alternative, the complaint alleges willful blindness based on a purported policy of not reviewing the patents of others. (Compl. ¶41).

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

  • A core issue will be one of definitional scope: for the power management patents ('678, '085), can the term "sleep power mode," which the patent specification links to components being "switched off," be construed to cover the accused Apple Watch's "Always On" low-power, dimmed state?
  • A key evidentiary question will be one of algorithmic correspondence: for the portfolio of biomechanical analysis patents, what evidence will show that the accused Apple software calculates the specific, often complex parameters required by the claims (e.g., "reactivity," "stiffness," filtering of "extra-motions") rather than more generalized, publicly marketed running metrics?
  • A central question for damages will be one of willfulness: given the repeated allegations that Defendant cited the asserted patent families during its own patent prosecution, the court will need to determine whether this constitutes pre-suit knowledge of the patented technology sufficient to find that any infringement was willful, potentially justifying enhanced damages.