Encelion LLC v. Polar Electro Oy

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Encelion LLC (New Mexico)
  • Defendant: Polar Electro Oy (Finland)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-875, E.D. Tex., 08/26/2025
• Venue Allegations: Venue is asserted based on the defendant being a foreign corporation and having allegedly committed acts of patent infringement within the Eastern District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s products infringe a patent related to wearable pulse sensors that measure arterial motion to determine pulse rate and infer physiological states such as hydration.
• Technical Context: The technology at issue involves non-invasive physiological monitoring, a core feature in the competitive market for wearable fitness trackers, smartwatches, and health devices.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.

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"

• Patent Identification: U.S. Patent No. 11,471,072, titled "Pulse sensor, system, and method for using a pulse sensor," issued on October 18, 2022 (the "’072 Patent").

The Invention Explained

• Problem Addressed: The patent describes the need for a non-invasive way to monitor physiological conditions beyond simple heart rate, such as a wearer's state of hydration (Summary, col. 1:11-15). Changes in hydration can alter blood viscosity and volume, which in turn affects blood pressure and the characteristics of a person's pulse wave (Summary, col. 1:16-31).
• The Patented Solution: The invention proposes a sensor that uses a magnet and a magnetometer to detect the physical movement of a peripheral artery caused by a pulse ('072 Patent, Abstract). As the artery expands and contracts, it causes a nearby magnet to move or tilt, which creates a detectable change in the magnetic field measured by the magnetometer ('072 Patent, col. 8:1-6; FIG. 1). By analyzing the resulting signal waveform, the system can determine not only the pulse rate but also a "modulation" feature—related to the shape of the pulse wave—which is then correlated with the user's hydration level to generate alerts ('072 Patent, Abstract).
• Technical Importance: This magnetic-based approach presents an alternative to common optical photoplethysmography (PPG) sensors and claims the ability to derive additional physiological data, such as hydration status, from the pulse wave's physical characteristics ('072 Patent, col. 1:32-46).

Key Claims at a Glance

• The complaint does not specify which claims of the ’072 Patent are asserted, instead referring to an unprovided "Exhibit 2" for this information (Compl. ¶13). For analytical purposes, independent claim 1 is representative of the patented method.
• The essential elements of Claim 1, which is directed to a non-transitory computer readable medium, include:
  • Measuring a "physical periodic motion" of a peripheral artery using a pulse sensor.
  • The measurement includes a "modulation" (corresponding to a difference or ratio between systolic peak and diastolic hump) and a pulse rate.
  • Receiving and saving this data to a buffer memory as a history.
  • Determining at least one "limit" from the saved history.
  • Comparing new measured instances of modulation and pulse rate to the determined limit.
  • Outputting a prompt to a user if the measured instances fall outside the limit.

III. The Accused Instrumentality

Product Identification

The complaint does not identify any accused products by name (Compl. ¶11). It refers generally to "Exemplary Defendant Products" that are purportedly detailed in "charts incorporated into this Count" via an unprovided Exhibit 2 (Compl. ¶11, ¶13).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's specific functionality. It makes only the conclusory allegation that the "Exemplary Defendant Products practice the technology claimed by the '072 Patent" (Compl. ¶13). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint provides no specific factual allegations of infringement in its body. It states that claim charts comparing the asserted claims to the accused products are included in Exhibit 2 (Compl. ¶13-14). As this exhibit was not provided, a claim chart summary cannot be constructed. The narrative infringement theory is limited to the assertion that the "Exemplary Defendant Products satisfy all elements of the Exemplary '072 Patent Claims" (Compl. ¶13).

Identified Points of Contention

Based on the patent's focus and the lack of factual allegations in the complaint, several key questions may arise.

• Scope Questions: A central question may concern the scope of "measuring a physical periodic motion." The patent's specification heavily details a system using a magnet that physically moves in response to arterial expansion ('072 Patent, col. 6:55-57). It is an open question whether this claim language can be construed to read on other sensor technologies, such as optical PPG sensors common in wearable devices, which measure changes in light absorption rather than direct mechanical displacement.
• Technical Questions: The complaint provides no evidence regarding the technical operation of the accused products. A key factual dispute will likely be whether the accused products perform the specific data processing steps recited in the claims: specifically, whether they calculate a "modulation" value corresponding to a "systolic peak and diastolic hump," use that history to establish a "limit," and compare subsequent measurements against that limit to prompt a user about their physiological state (e.g., hydration).

V. Key Claim Terms for Construction

"modulation corresponds to a difference or ratio between systolic peak and diastolic hump" (from Claim 1)

• Context and Importance: This term defines the specific technical feature of the pulse waveform that the patent uses to assess physiological state. The outcome of the case may depend on whether the signal processing in the accused products can be shown to calculate a metric that meets this definition.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification refers to this concept more generally as an "arterial expansion ratio" ('072 Patent, col. 1:59-62), which could support an argument that any derived value tracking the relative heights of the pulse wave's primary and secondary peaks meets the limitation.
  • Evidence for a Narrower Interpretation: The patent illustrates these specific waveform features in FIG. 10, identifying the systolic maximum (1004) and the diastolic hump (1006) ('072 Patent, col. 16:41-44). A defendant may argue the term is limited to the analysis of these distinct features as disclosed, particularly as derived from the described magnetic sensor.

"measuring a physical periodic motion of a peripheral artery" (from Claim 1)

• Context and Importance: This term is foundational to the claimed method. Its construction will be critical in determining whether the patent's scope is limited to the magnetically-actuated mechanical sensors described in the specification or if it can extend to other sensor modalities.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A plaintiff could argue that any sensor data that originates from the artery's physical expansion and contraction—including changes in blood volume detected by optical sensors—constitutes a measurement of the underlying "physical periodic motion."
  • Evidence for a Narrower Interpretation: The specification consistently describes a mechanism where a magnet is "subject to movement responsive to the arterial pulse movement" and physically tilts ('072 Patent, col. 6:55-57, col. 8:40-43). This focus on direct mechanical displacement could support an argument that the term does not cover methods that measure secondary effects, such as changes in light absorption.

VI. Other Allegations

The complaint alleges only direct infringement (Compl. ¶11). It does not contain allegations of indirect or willful infringement.

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

The complaint as filed is conclusory and lacks specific factual allegations, deferring all substantive detail to an unprovided exhibit. Based on the patent and the nature of the dispute, the case appears to present two fundamental, open questions for the court.

• A core issue will be one of evidentiary sufficiency: What technical evidence can Plaintiff provide to demonstrate that the unidentified accused products perform the specific, multi-step method of the asserted claims, including the calculation of a "modulation" value from a "systolic peak and diastolic hump" and its use in a feedback loop to prompt the user?
• A second key question will be one of technological scope: Can the claims, which arise from a specification focused on detecting the direct mechanical movement of an artery via a magnetic sensor, be construed to cover the operation of different technologies, such as the optical sensors widely used in the wearable device market?