DCT

2:25-cv-00674

CardiacSense Ltd v. Casio Computer Co Ltd

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:

  • Case Identification: 2:25-cv-00674, E.D. Tex., 07/02/2025

  • Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign corporation and has conducted substantial business in the Eastern District of Texas, including regularly selling the accused products to residents of the district.

  • Core Dispute: Plaintiff alleges that Defendant’s G-SHOCK series of multi-sensor sport watches infringes a patent related to a personal device for measuring and analyzing a user's training activity.

  • Technical Context: The technology at issue involves wearable electronic devices that use a combination of sensors, such as accelerometers and gyroscopes, to monitor the complex movements of a person during physical activities.

  • Key Procedural History: The complaint does not reference any prior litigation, inter partes review (IPR) proceedings, or licensing history concerning the patent-in-suit. The patent is owned by Plaintiff via assignment from the original inventors.

Case Timeline

Date Event
2006-09-11 Priority Date for U.S. Patent No. 7,980,998
2011-07-19 U.S. Patent No. 7,980,998 Issues
2025-07-02 Complaint Filed

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

U.S. Patent No. 7,980,998 - “Training and Instructing Support Device”

  • Patent Identification: U.S. Patent No. 7,980,998, “Training and Instructing Support Device,” issued July 19, 2011.

The Invention Explained

  • Problem Addressed: The patent describes a need for improved systems to monitor athletic activities like swimming, moving beyond simple timers to capture more detailed movement parameters and facilitate real-time communication between an instructor and multiple participants. (’998 Patent, col. 1:15-20, 1:49-54).
  • The Patented Solution: The invention is a wearable personal device that uses a "sensing unit"—comprising an accelerometer, a compass, and optionally a gyroscope—to repeatedly measure the movement of a body part during a training activity. ('998 Patent, Abstract). A processor within the device receives these measurements (e.g., linear and angular acceleration) and calculates data characterizing the activity, such as the body part's location and orientation for each measurement. ('998 Patent, col. 4:1-8).
  • Technical Importance: The technology aimed to provide a more holistic analysis of an athlete's performance by combining data from multiple types of motion sensors to characterize movement along six degrees of freedom. ('998 Patent, col. 10:28-39).

Key Claims at a Glance

  • The complaint asserts independent claim 1 and dependent claims 2-7, 10, and 12-16. (Compl. ¶27).
  • Independent Claim 1 recites the following essential elements:
    • A personal device for measuring a training activity of a trainee having a body part which moves and changes its location and orientation.
    • A sensing unit adapted to repeatedly measure parameters associated with the movement, comprising at least accelerometer means, a compass, and optionally gyroscope means.
    • The accelerometer means is adapted to measure linear acceleration along three axes.
    • The gyroscope means is adapted to measure angular acceleration around three axes.
    • Means for attaching the sensing unit to the body part.
    • A processor adapted to receive the parameters from the sensing unit and calculate data indicative of the training activity, including the location and orientation of the body part.

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are Casio’s sport and training watches, including products identified as “G-SHOCK Watches,” “G-SHOCK GBDH2000,” “G-SHOCK GBDH2000-2,” “G-SHCOK GBDH2000-1A,” “G-SHOCK GBDH2000-1A9,” and “6-Sensor+GPS Multi Sport Watches.” (Compl. ¶16).

Functionality and Market Context

  • The complaint describes the accused products as “training activity monitoring device[s]” that include software and can connect with Android and Apple mobile applications. (Compl. ¶28-29). The product name “6-Sensor+GPS Multi Sport Watches” suggests that the devices incorporate multiple sensors for monitoring physical activities. (Compl. ¶16). The complaint alleges these watches are sold through an established distribution channel to consumers throughout the United States, including in the judicial district where the suit was filed. (Compl. ¶11, ¶13).

IV. Analysis of Infringement Allegations

The complaint alleges that the accused products meet the limitations of the asserted claims but refers to non-prosecuted, external exhibits for a detailed element-by-element mapping. (Compl. ¶24, ¶26). The infringement theory, as constructed from the narrative allegations in the complaint, is summarized below. No probative visual evidence provided in complaint.

'998 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A personal device for measuring a training activity of a trainee having a body part which moves and changes its location and orientation... The accused products are identified as “sport / training watches” and “training activity monitoring device[s].” ¶16, ¶28 col. 4:63-66
a sensing unit adapted to repeatedly measure...parameters associated with the movement of said body part...wherein said sensing unit comprising at least accelerometer means, a compass and optionally gyroscope means, said accelerometer means being adapted to measure linear acceleration...along three axes, said gyroscope means being adapted to measure angular acceleration...around three axes... The accused products are marketed under names including “6-Sensor+GPS Multi Sport Watches,” which the complaint alleges contain the necessary components to monitor training activity. The complaint also alleges the devices include software that directly infringes the claims. ¶16, ¶28 col. 10:21-27
means for attaching the sensing unit to said body part The accused products are identified as “Watches,” which inherently possess a means for attachment to a user’s wrist. ¶16 col. 8:38-42
a processor adapted to receive from the sensing unit said parameters, and to calculate based thereon, data indicative of said training activity, said data including at least the location and orientation of said body part for each of the measurements. The accused devices are alleged to include “software” and can connect with mobile phone applications, functionalities that imply the presence of a processor for receiving sensor data and performing calculations. The complaint alleges these devices directly infringe by monitoring training activity. ¶28, ¶29 col. 7:62 - 8:2
  • Identified Points of Contention:
    • Technical Questions: A primary evidentiary question will concern the specific components of the accused "6-Sensor" watches. The case may require discovery to determine if these watches contain a "compass" (e.g., a magnetometer) and a three-axis "gyroscope means" that function in the manner required by the claim, or if they rely on different technologies (such as GPS) to derive similar data.
    • Scope Questions: Claim 1 uses "means-plus-function" phrasing (e.g., "means for attaching," "accelerometer means"). The scope of these terms is limited to the corresponding structures disclosed in the patent's specification and their equivalents. A dispute may arise over whether the specific structures in the Casio watches are structurally equivalent to those disclosed in the '998 patent, such as the watch-style band shown in Figure 2A. ('998 Patent, FIG. 2A; col. 8:38-42).

V. Key Claim Terms for Construction

  • The Term: "compass"

  • Context and Importance: This term is critical because Claim 1 requires a compass in the sensing unit. The accused products are advertised with GPS capability. (Compl. ¶16). The infringement analysis will depend on whether the term "compass" is construed to be limited to a device measuring the Earth's magnetic field (a magnetometer) or if it can be read more broadly to include orientation-finding functions derived from GPS signals. Practitioners may focus on this term because of the potential technical mismatch between a traditional compass and GPS-based heading data.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The patent does not provide an explicit definition of "compass," which may support an argument for its plain and ordinary meaning, potentially encompassing any technology that provides directional orientation.
    • Evidence for a Narrower Interpretation: The specification describes the compass's advantage as providing measurements "relative to the earth electromagnetic field as an external reference point," which suggests a device that senses magnetic fields. ('998 Patent, col. 10:51-53). This could support a narrower construction limited to magnetometers.

  • The Term: "personal device"

  • Context and Importance: The complaint alleges infringement by the accused watches both as standalone devices and "in combination with an application running on a mobile phone." (Compl. ¶29). The proper construction of "personal device" will determine whether the claim is limited to a single, self-contained apparatus (the watch) or can cover a distributed system (the watch plus a connected phone).

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The patent's description of a larger system, where personal devices (10) communicate with an instructor's computer (22), could be used to argue that the invention contemplates distributed functionality. ('998 Patent, FIG. 1).
    • Evidence for a Narrower Interpretation: Claim 1 recites the sensing unit, attachment means, and processor as components of a single "said device." Figures 2A and 3 depict the device as a singular, integrated wearable unit, which may support a construction limiting the term to a non-distributed apparatus. ('998 Patent, FIG. 2A, FIG. 3).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Defendant induces infringement by providing customers with the accused products along with instructions, thereby encouraging them to use the devices in an infringing manner. (Compl. ¶22, ¶32). It also pleads contributory infringement, alleging that Defendant supplies a material part of an infringing device that is not a staple article of commerce. (Compl. ¶22).
  • Willful Infringement: Willfulness is alleged based on Defendant’s purported knowledge of the '998 patent and its continued infringement after becoming aware. (Compl. ¶33). The complaint asserts that Defendant refused to "cease selling products or to engage in further attempts to reach a business resolution," suggesting the alleged knowledge may be pre-suit. (Compl. ¶33).

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

This case appears to present several central questions for the court's determination:

  • A core issue will be one of component correspondence: Does the "6-Sensor" array in the accused Casio watches contain components that function as the "compass" and "gyroscope means" required by Claim 1, and will the evidence show that these components perform the specific functions of measuring orientation relative to the Earth's magnetic field and angular acceleration around three axes, as described in the patent?
  • A key legal question will be the scope of the claim term "personal device": Can the claim be construed to cover a distributed system where infringing functionality is split between the accused watch and a separate mobile phone application, or is its scope limited to the single, integrated wearable unit described in the patent's embodiments?
  • Finally, the dispute may turn on the interpretation of means-plus-function limitations: The infringement analysis for elements like "means for attaching" will depend on whether the structures in the accused watches are legally equivalent to the specific bands, clamps, and patches disclosed in the '998 patent's specification.