Encelion LLC v. Samsung Electronics America Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Encelion LLC (NM)
  • Defendant: Samsung Electronics America, Inc. (New York)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:24-cv-00942, E.D. Tex., 11/16/2024
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains an established place of business within the Eastern District of Texas and has committed the alleged acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s unnamed products infringe two patents related to wearable sensors that analyze a user's pulse wave characteristics to monitor their hydration status.
• Technical Context: The technology involves wearable biometric sensors that use novel methods to continuously assess physiological states, a highly competitive and technically sophisticated feature in the consumer electronics market for smartwatches and fitness trackers.
• Key Procedural History: The two asserted patents, U.S. 11,980,459 and U.S. 11,471,072, are part of the same patent family. The ’459 Patent is a continuation of the application that matured into the ’072 Patent and is subject to a terminal disclaimer over the ’072 Patent, which ties their expiration dates together.

Case Timeline

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

U.S. Patent No. 11,471,072 - Pulse sensor, system, and method for using a pulse sensor, issued October 18, 2022 (’072 Patent)

The Invention Explained

• Problem Addressed: The patent describes the challenge of non-invasively and continuously monitoring a person's hydration level. It notes that as a person becomes dehydrated, their blood volume and viscosity change, which in turn alters the shape of their arterial pulse wave. (’072 Patent, col. 1:16-47).
• The Patented Solution: The invention proposes a wearable sensor, preferably worn on the wrist, that uses a magnet placed over an artery. As the artery pulses, it causes the magnet to physically move or tilt. A nearby magnetometer detects the resulting changes in the magnetic field. (’072 Patent, Abstract; col. 6:53-60). This system is designed to measure not only the pulse rate but also the "modulation" of the pulse wave—specifically, the relationship between the main systolic peak and a secondary "diastolic hump"—which the patent asserts is an indicator of hydration status. (’072 Patent, col. 1:31-47; Fig. 10).
• Technical Importance: The described technology aims to provide a method for continuous, real-time hydration monitoring for athletes or in medical contexts, moving beyond simple heart rate tracking to infer a more complex physiological state. (’072 Patent, col. 2:1-2).

Key Claims at a Glance

The complaint asserts exemplary method claims without specifying them, instead referring to an unfiled exhibit. (’072 Patent, ¶12). Independent claim 1 is representative:

• A non-transitory computer readable medium carrying instructions to cause a portable device to execute a method comprising the steps of:
• measuring a physical periodic motion of a peripheral artery with a pulse sensor, each measured motion including a modulation and a pulse rate, wherein the modulation corresponds to a difference or ratio between systolic peak and diastolic hump corresponding to respective expansion of the peripheral artery;
• receiving the modulation and the pulse rate with a micro-controller and saving them to a buffer memory;
• determining at least one limit from the stored history;
• writing the limit to a non-transitory computer readable medium;
• comparing measured instances of modulation, blood flow rate, and pulse rate to the limit; and
• outputting a prompt if the measured instances fall outside the limit.

The complaint reserves the right to assert other claims. (Compl. ¶12).

U.S. Patent No. 11,980,459 - Method and apparatus for human hydration sensing, issued May 14, 2024 (’459 Patent)

The Invention Explained

• Problem Addressed: As a continuation of the ’072 Patent, the ’459 Patent addresses the same technical problem: using characteristics of an arterial pulse wave to provide a non-invasive, continuous estimate of a user's hydration level. (’459 Patent, col. 1:1-15).
• The Patented Solution: The solution is materially identical to that described in the ’072 Patent, involving a sensor that measures pulse rate and pulse wave "modulation" (the systolic-to-diastolic peak relationship) to infer hydration. The specification and figures appear to be identical to the parent ’072 Patent. (’459 Patent, Abstract; col. 1:31-47).
• Technical Importance: The invention's importance is the same as described for the ’072 Patent: enabling a more sophisticated level of physiological monitoring from a wearable device. (’459 Patent, col. 2:1-2).

Key Claims at a Glance

The complaint asserts exemplary method claims without specifying them, instead referring to an unfiled exhibit. (Compl. ¶18). Independent claim 1 is representative:

• A method for monitoring the hydration of a person, comprising:
• measuring a pulse at a peripheral artery with a pulse sensor to determine pulse data;
• receiving the pulse data with a programmable hardware device and writing it to memory;
• determining at least one limit, including a "pulse wave modulation value" corresponding to a systolic/diastolic peak relationship, from the stored history;
• receiving new pulse data and calculating a new variable value;
• comparing the new value to the limit; and
• outputting a prompt if a predetermined number of instances fall outside the limit.

The complaint reserves the right to assert other claims. (Compl. ¶18).

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused Samsung products by name. It refers generally to "Exemplary Defendant Products" that are purportedly identified in claim charts in Exhibits 3 and 4. (Compl. ¶¶12, 14, 18, 20). These exhibits were not filed with the complaint.

Functionality and Market Context

The complaint does not provide any description of the accused products' technical functionality or market position. It makes only the conclusory allegation that the unnamed products "practice the technology claimed" and "satisfy all elements" of the asserted claims. (Compl. ¶¶14, 20). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint provides no specific factual allegations to support its infringement theories, instead incorporating by reference claim charts from unfiled exhibits. (Compl. ¶¶15, 21). The following tables summarize the infringement theories that would need to be proven for representative claims, based on the patent language.

’072 Patent Infringement Allegations

’459 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: A primary question may be whether the term "pulse sensor" can be construed to read on the technology used in the accused products, which likely employ optical photoplethysmography (PPG) sensors. The patents' specifications are heavily focused on a distinct mechanism involving a physically tilting magnet and a magnetometer. The extent to which general statements about other sensor types broaden the claims beyond the magnetic embodiment will be a central issue. (’072 Patent, col. 15:65-16:2).
• Technical Questions: The complaint provides no evidence that the accused products actually calculate a "modulation" value as specifically defined in the claims (a "difference or ratio between systolic peak and diastolic hump") for the purpose of assessing hydration. A key question for the court will be whether the general pulse wave analysis performed by the accused products for other health metrics (e.g., arrhythmia detection) performs the specific function required by the claims.

V. Key Claim Terms for Construction

• The Term: "modulation"

  • Context and Importance: This term is central to the claimed invention, as it represents the specific feature of the pulse wave used to infer hydration. Its construction will likely determine whether the analysis performed by the accused products infringes. Practitioners may focus on this term because the claims explicitly tie it to the "systolic peak and diastolic hump." (’072 Patent, Claim 1).
  • Intrinsic Evidence for a Broader Interpretation: The specification states that the "systolic peak to diastolic hump arterial expansion ratio... is expressed as modulation," which could be argued to encompass any quantitative relationship between these two parts of the pulse wave. (’072 Patent, col. 1:57-60).
  • Intrinsic Evidence for a Narrower Interpretation: The detailed description and figures provide a specific graphical representation of the systolic peak (1004) and diastolic hump (1006). (’072 Patent, Fig. 10). A defendant may argue that "modulation" is limited to the specific ratio as derived from the magnetically-sensed waveform depicted, not a more general analysis from a different type of sensor like PPG.

• The Term: "measuring a physical periodic motion... with a pulse sensor"

  • Context and Importance: This term is critical because the patents primarily describe a sensor that measures the physical tilting motion of a magnet, whereas the accused devices likely use optical sensors that measure changes in light reflection. The viability of the infringement case may depend on whether an optical measurement falls within the scope of "measuring a physical periodic motion."
  • Intrinsic Evidence for a Broader Interpretation: The patent mentions in passing that "sensors other than magnetic sensors" may be used, including "piezo-resistive sensors, capacitive sensors, or other kinds of sensors." (’072 Patent, col. 15:65-16:2). Plaintiff will likely argue this passage demonstrates the inventors' intent to claim the method broadly, irrespective of the specific sensor technology.
  • Intrinsic Evidence for a Narrower Interpretation: The overwhelming focus of the patent—in the abstract, summary, and detailed description—is on the magnetic sensor embodiment. (’072 Patent, Abstract; col. 3:50-4:4). A defendant may argue that the "physical periodic motion" claimed is the specific tilting of the magnet in response to the pulse, a mechanical action fundamentally different from the optical measurement of blood volume performed by a PPG sensor.

VI. Other Allegations

• Indirect Infringement: The complaint does not contain counts for indirect infringement. It alleges direct infringement by Defendant for making, using, and selling the accused products, including for internal testing. (Compl. ¶¶12-13, 18-19). The inclusion of infringement by "and/or its customers" may lay the groundwork for a future indirect infringement claim, but no specific facts supporting knowledge or inducement are pleaded. (Compl. ¶¶12, 18).
• Willful Infringement: The complaint does not allege willful infringement. While the prayer for relief seeks damages under 35 U.S.C. § 284 and a declaration of an exceptional case for attorneys' fees under § 285, it pleads no facts to suggest pre-suit knowledge or egregious conduct that would support a willfulness finding. (Compl. p. 5, ¶¶F-G).

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

1. Pleading Sufficiency: A threshold issue is whether the complaint, which omits any identification of the accused products and contains no factual allegations of infringement beyond incorporating unfiled exhibits, meets the plausibility pleading standard of Twombly/Iqbal. The lack of factual content may expose the complaint to an early motion to dismiss.
2. Technological Mismatch: Should the case proceed, a dispositive issue will be one of claim scope: can the claims, which are described and enabled primarily through the lens of a magnetic sensor detecting the physical motion of a magnet, be construed broadly enough to cover market-dominant optical PPG sensors that operate on entirely different physical principles?
3. Functional Specificity: A central evidentiary question will be whether the Plaintiff can prove that the accused products perform the specific, multi-step method claimed. This includes not just analyzing a pulse wave, but specifically calculating a "modulation" value based on the systolic-to-diastolic hump ratio and using that particular value to trigger a user prompt related to hydration, as the claims require.