DCT

2:25-cv-00483

Omni MedSci Inc v. Samsung Electronics Co Ltd

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00483, E.D. Tex., 05/05/2025
  • Venue Allegations: Venue for U.S.-based defendants is alleged based on their regular and established places of business and sales activities within the Eastern District of Texas. For foreign-domiciled defendants, venue is alleged under the general venue statute applicable to foreign entities.
  • Core Dispute: Plaintiff alleges that Defendants’ smartwatches and smart rings infringe a patent related to wearable optical devices for non-invasively measuring physiological parameters.
  • Technical Context: The technology involves using light-emitting diodes and optical sensors in wearable devices to monitor biological metrics, a key feature set in the competitive consumer health and fitness technology market.
  • Key Procedural History: The complaint notes that the asserted patent is related through a chain of continuation applications to other patents asserted in a co-pending litigation against Samsung, which may have implications for claim construction and prior art discovery in the current case.

Case Timeline

Date Event
2012-12-31 '475 Patent Priority Date
2025-04-08 '475 Patent Issue Date
2025-05-05 Complaint Filing Date

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

U.S. Patent No. 12,268,475 - Wearable Device for Differential Measurement on Pulse Rate and Blood Flow

  • Issued: April 8, 2025

The Invention Explained

  • Problem Addressed: The patent describes the challenge of obtaining accurate non-invasive measurements of blood constituents (such as glucose) using optical spectroscopy, citing spectral artifacts from skin and weak signal levels as significant obstacles ('475 Patent, col. 3:32-42).
  • The Patented Solution: The invention is a wearable device that aims to improve measurement accuracy by enhancing the signal-to-noise ratio (SNR) of the optical signal ('475 Patent, Abstract). It proposes a specific signal processing method where the detection system is synchronized to the light source. The system generates a first signal based on ambient light received when the device's light sources are off and a second signal when at least one source is on; by comparing these two signals, the SNR is increased ('475 Patent, col. 9:15-28). The patent also suggests using a differential measurement across two different skin locations (e.g., one over a vein and one not) to further cancel out skin interference ('475 Patent, col. 23:1-7).
  • Technical Importance: The described technique is presented as a method to overcome noise and interference, which are fundamental challenges in using optical sensors to reliably monitor physiological parameters through the skin (Compl. ¶73).

Key Claims at a Glance

  • The complaint asserts independent claims 1 and 8.
  • Essential elements of Independent Claim 1 include:
    • An apparatus adapted to be worn by a user comprising one or more biosensors, a light source with a plurality of LEDs, one or more lenses, and a detection system.
    • The detection system is synchronized to the light source and includes a plurality of spatially separated detectors and at least one analog-to-digital converter.
    • The apparatus is configured to increase the SNR by increasing the light intensity.
    • The detection system is further configured to generate a first signal (light sources off), generate a second signal (at least one light source on), and increase the SNR by comparing the two signals.
    • The apparatus is configured to determine, based on the output signal, that it is being worn by the user.
  • Essential elements of Independent Claim 8 include:
    • A wearable device with a light source, a lens, a detector, and a processor.
    • The processor is configured to generate a first output signal (light source on), a second output signal (light source off), and a third output signal by using the first and second signals, where the third signal has a higher SNR.
    • The processor is also configured to determine that the device is being worn by the user based on the third output signal.

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are wearable smart devices, including:

  • Samsung: Galaxy Watch series, Galaxy Watch Active series, Galaxy Watch3-7, Galaxy Watch Ultra, and Samsung Ring (collectively, "Samsung Products") (Compl. ¶¶ 78, 81, 92).
  • OnePlus: OnePlus Watch, OnePlus Watch 2, OnePlus Watch 2R, and OnePlus Watch 3 series (collectively, "OnePlus Products") (Compl. ¶¶ 82, 101).
  • Fossil: Fossil Gen 1 through Gen 6 series watches ("Fossil Smartwatch") (Compl. ¶¶ 85, 110).
  • Ōura: Gen 1 through Gen 4 series smart rings ("Ōura Ring") (Compl. ¶¶ 88, 120).

Functionality and Market Context

The complaint alleges these devices include capabilities for measuring physiological parameters such as heartbeat and blood oxygen level (Compl. ¶¶ 78, 82, 85, 88). This functionality is allegedly enabled by hardware components, such as Samsung's "BioActive sensor" and "Bio-signal Sensor" (Compl. ¶¶ 80, 81). The devices are designed to be integrated into an ecosystem with a smartphone or tablet and a corresponding cloud computing platform (e.g., Samsung Cloud, Ōura Cloud), creating a system for measuring, processing, and storing user physiological data (Compl. ¶¶ 80, 84, 87, 90). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges infringement but does not provide a detailed mapping of accused product features to specific claim limitations. The following chart summarizes the allegations by linking the general functionality described in the complaint to the elements of the asserted independent claim.

'475 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
An apparatus adapted to be worn by a user comprising: one or more biosensors... Defendants' products are wearable devices (smartwatches and rings) that include capabilities for measuring physiological parameters. ¶¶ 78, 81, 82, 85, 88 col. 85:10-14
a light source comprising a plurality of light emitting diodes... The accused devices measure physiological parameters using hardware components, such as optical "BioActive" or "Bio-signal" sensors. ¶¶ 80, 81 col. 85:20-23
one or more lenses... The complaint does not provide sufficient detail for analysis of this element. col. 85:24-27
a detection system configured to receive at least a portion of the lens output light reflected from the tissue and to generate an output signal... The accused devices contain sensors that measure physiological parameters by receiving light reflected from the user's tissue. ¶¶ 80, 81, 90 col. 85:28-32
the detection system is configured to be synchronized to the light source... The complaint does not provide sufficient detail for analysis of this specific function. col. 85:33-34
the detection system comprises a plurality of detectors that are spatially separated from each other, and at least one analog to digital converter... The complaint does not provide sufficient detail for analysis of this specific hardware configuration. col. 85:35-39
the detection system further configured to: generate a first signal responsive to light received while the light emitting diodes are off, generate a second signal responsive to light received while at least one of the light emitting diodes is on, and increase the signal-to-noise ratio by comparing the first signal and the second signal... The complaint alleges that the asserted claims recite the capability of increasing the signal-to-noise ratio by using or comparing a signal generated while sources are off and another generated while sources are on. ¶73 col. 85:40-47
wherein the apparatus is at least in part configured to determine, based at least in part on the output signal, that the apparatus is being worn by the user. The complaint does not provide sufficient detail for analysis of this element. col. 86:1-4
  • Identified Points of Contention:
    • Evidentiary Questions: The complaint makes broad allegations that the accused products infringe but does not specify which components or software routines perform the functions recited in the claims. A central question for the court will be what evidence demonstrates that the accused products' sensors and processors perform the specific method of improving SNR recited in claim 1. Specifically, what evidence shows the generation and comparison of separate signals corresponding to the light source being "on" and "off"?
    • Technical Questions: A key technical question is whether the ambient light correction methods used in the accused products meet the specific claim limitation of "comparing" a first signal (source off) and a second signal (source on) to "increase the signal-to-noise ratio." The defense may argue that their methods are technically distinct from the claimed process.

V. Key Claim Terms for Construction

  • The Term: "increase the signal-to-noise ratio by comparing the first signal and the second signal" (from Claim 1).

    • Context and Importance: This term is central to the inventive concept of improving measurement accuracy. The infringement analysis will likely depend on whether the signal processing in the accused devices, which almost certainly includes some form of ambient light cancellation, falls within the scope of this "comparing" step.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent claims use the general functional term "comparing" without specifying a particular mathematical algorithm. Plaintiff may argue that any process that uses an ambient light measurement (signal with source "off") to correct the primary measurement (signal with source "on"), such as subtraction, constitutes "comparing" for the purpose of increasing SNR.
      • Evidence for a Narrower Interpretation: The patent repeatedly ties this comparison to a system where the "detection system is configured to be synchronized to the light source" ('475 Patent, cl. 1). A defendant may argue that "comparing" should be construed in the context of a specific lock-in or synchronous detection scheme, potentially narrowing the claim to exclude more general-purpose ambient light subtraction techniques.

  • The Term: "determine... that the apparatus is being worn by the user" (from Claim 1).

    • Context and Importance: This limitation requires an affirmative determination by the device. The dispute may focus on whether simply activating upon detecting a signal (i.e., skin contact) is sufficient, or if a more sophisticated logical step is required to distinguish "being worn" from other states.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The claim language is broad. A party could argue that any logic that prevents the device from attempting a measurement unless it receives a valid reflected optical signal is a form of "determining" it is being worn, as such a signal is only available when placed on tissue.
      • Evidence for a Narrower Interpretation: The specification discusses this feature in the context of a complete system ('475 Patent, col. 9:28-34). Practitioners may focus on this term because defendants could argue it implies a dedicated "wear detection" function that is separate from the primary physiological measurement logic, and which may not be present in their devices.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement against all Defendants. The allegations are based on Defendants providing the accused products along with software, instructions, product manuals, marketing, and technical support that allegedly encourage and instruct end-users to operate the devices in their normal, infringing manner (Compl. ¶¶ 96, 105, 115, 124).
  • Willful Infringement: Willfulness is alleged based on Defendants' purported knowledge of the '475 Patent at least upon service of the complaint. The complaint also alleges, on information and belief, that Defendants had prior knowledge due to their regular review of patents in the field and the existence of co-pending litigation involving the same patent family (Compl. ¶¶ 77, 100, 109, 119, 128).

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

  • A key evidentiary question will be one of technical operation: what proof can be adduced that the accused smartwatches and rings, which perform general ambient light correction, execute the specific signal processing recited in the claims—namely, generating a first signal while light sources are 'off,' a second while 'on,' and then 'comparing' the two to increase signal-to-noise ratio?
  • A core issue will be one of claim scope and construction: does the claimed method of "comparing" an "on" signal with an "off" signal to improve SNR encompass the general-purpose ambient light subtraction algorithms common in the wearable device industry, or is it limited to a more specific, synchronous detection technique suggested by the patent's specification?