Suunto Oy v. Garmin Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Suunto Oy (Finland)
  • Defendant: Garmin Ltd. (Switzerland) and Garmin International, Inc. (Kansas)
  • Plaintiff’s Counsel: Cherry Johnson Siegmund James PLLC
• Case Identification: 2:25-cv-00967, E.D. Tex., 01/20/2026
• Venue Allegations: Plaintiff alleges venue is proper for Garmin Ltd., a foreign corporation, in any judicial district. It further alleges that Defendants conduct substantial business in the Eastern District of Texas through product sales at physical retail locations and via an interactive commercial website.
• Core Dispute: Plaintiff alleges that Defendant’s smartwatches and wearable devices infringe four patents related to automated golf shot detection and recording, energy-efficient physiological monitoring, and specialized antenna structures for wearable devices.
• Technical Context: The technologies at issue concern core functionalities in the competitive sports and fitness smartwatch market, including automated activity tracking, biometric data analysis, and the underlying hardware design for reliable wireless communication.
• Key Procedural History: The complaint is a First Amended Complaint for Patent Infringement. The patents-in-suit form two distinct families: two patents relate to software/algorithmic features for activity and health tracking, while the other two relate to hardware-level antenna design. The '306 Patent is a continuation of an application that issued as U.S. Patent No. 7,803,117. The '731 Patent is part of a chain of continuation and continuation-in-part applications originating from an application filed in 2013.

Case Timeline

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

U.S. Patent No. 7,489,241 - Method in Connection with a Wristop Computer and a Wristop-Computer System (Issued Feb. 10, 2009)

The Invention Explained

• Problem Addressed: The patent's background section describes that prior art methods for recording golf shot data required a player to manually press a key to log the location of their stroke, an action that is easily forgotten during a game, leading to incomplete or inaccurate data collection (Compl. ¶3; ’241 Patent, col. 2:37-41).
• The Patented Solution: The invention is a system where a wrist-worn computer automatically detects a "strike event" (e.g., the impact of a golf club hitting a ball) through a measurement from a sensor, such as an accelerometer. This detected event then triggers the recording of game data, most notably the GPS position of the stroke, without requiring manual input from the user (’241 Patent, Abstract; col. 2:46-56). Figure 4 of the patent illustrates a block diagram of the system, including a wristop computer (20) with a trigger circuit (21) and a reading device (23) (’241 Patent, col. 4:63-67).
• Technical Importance: This automation removes a point of friction for the user, potentially improving the consistency and accuracy of data collection for sports performance analysis (Compl. ¶3).

Key Claims at a Glance

• The complaint asserts direct infringement of at least claims 9, 10, and 12 (Compl. ¶24). Independent claim 9 is directed to a wristop computer system and requires:
  • A wristop computer able to detect a strike event with the aid of a measurement.
  • A "strike event detecting means" for detecting the event.
  • A "data determining means" for determining the user's GPS position when the event is detected.
  • A "recording means" for recording at least the GPS position in the wristop computer after the position is determined.

U.S. Patent No. 8,021,306 - Method, device and computer program product for monitoring the physiological state of a person (Issued Sep. 20, 2011)

The Invention Explained

• Problem Addressed: The patent's background section notes that prior art methods for estimating energy consumption required information about a person's maximum oxygen consumption (VO2max), which is difficult to estimate accurately without specific testing and can lead to large errors in calculation (’306 Patent, col. 1:19-24). The complaint adds that traditional methods were often computationally intensive and consumed significant battery power, making them less suitable for wearables (Compl. ¶4).
• The Patented Solution: The invention provides a method to determine a person's respiratory frequency by analyzing the "periodicity of the temporal variation of the pulse intervals (pulse interval noise)" directly in the time domain. By analyzing the subtle timing variations between heartbeats, the system can derive the user's breathing rate without resorting to power-hungry frequency-domain calculations like Fourier transforms (’306 Patent, Abstract; col. 2:56-68).
• Technical Importance: This approach offers a computationally efficient, low-power method for calculating a key physiological metric, making continuous respiration monitoring feasible on battery-constrained devices like smartwatches (Compl. ¶4).

Key Claims at a Glance

• The complaint references at least exemplary claim 11 (Compl. ¶197). Independent claim 11 is directed to a portable device for monitoring a physiological state and requires:
  • A sensor for detecting a heartbeat to create a pulse signal, or means for receiving such a signal.
  • A processing unit for determining the respiratory frequency of the person based on the periodicity of the temporal variation of the pulse interval.
  • The processing unit is adapted to determine this periodicity "in the time domain" by time-stamping pulses, creating a series of time points, and determining the period of that series.
  • The processing unit is further adapted to determine the respiratory frequency based on the determined period of the series.

U.S. Patent No. 7,271,774 - "Electronic wearable device" (Issued September 18, 2007)

• Patent Identification: U.S. Patent No. 7,271,774, "Electronic wearable device," issued September 18, 2007 (Compl. ¶19).
• Technology Synopsis: The patent addresses the challenge of maintaining strong wireless signal reception in wearable devices that incorporate metal components, which can interfere with antenna performance. The patented solution is an "integral slot antenna" formed directly in a conductive portion of the device's outer housing, allowing for the use of metal components while preserving antenna function (Compl. ¶5; '774 Patent, Abstract).
• Asserted Claims: The complaint references at least exemplary claim 1 (Compl. ¶590).
• Accused Features: The complaint accuses Garmin's fēnix 5, 6, 7, and 8 Series smartwatches of infringing by incorporating "slot-mode antenna structures and conductive housing assemblies" (Compl. ¶589).

U.S. Patent No. 10,734,731 - "Antenna assembly for customizable devices" (Issued August 4, 2020)

• Patent Identification: U.S. Patent No. 10,734,731, "Antenna assembly for customizable devices," issued August 4, 2020 (Compl. ¶20).
• Technology Synopsis: The patent addresses the need to cost-effectively customize wearable devices, where changing components like a metal bezel can alter antenna performance and require redesigns. The invention is a tunable antenna assembly with an element that has "multiple attachment points" for connecting members. This allows a single printed circuit board design to be used across different device variants by selecting the appropriate attachment point to optimize the antenna for that specific configuration ('731 Patent, Abstract; col. 1:46-54).
• Asserted Claims: The complaint references at least exemplary claim 1 (Compl. ¶595).
• Accused Features: The complaint accuses Garmin's fēnix 6, 7, and 8 Series smartwatches of infringing by incorporating "configurable antenna assemblies and conductive structural components" (Compl. ¶594).

III. The Accused Instrumentality

• Product Identification: The complaint names a wide range of Garmin smartwatches and wearable devices. The products accused of infringing the '241 Patent are primarily those with golf-tracking features, including the Approach, fēnix, EPIX, Venu, and MARQ Golfer series (Compl. ¶22). The products accused of infringing the '306 Patent encompass a broader set of Garmin's product lines that feature optical heart rate sensing, including the Approach, Forerunner, fēnix, Venu, Instinct, and Lily series, among others (Compl. ¶¶196, 20-21).
• Functionality and Market Context: The relevant functionality for the '241 Patent allegations is the "Garmin AutoShot™" feature, which automatically detects and records golf shots (Compl. ¶34). For the '306 Patent, the key functionality is the determination of a user's respiration rate based on data from an optical heart rate sensor, including through the analysis of Heart Rate Variability (HRV) (Compl. ¶¶201-202). The complaint asserts that Garmin offers smartwatches with advanced sensor technology in the competitive smartwatch and wearable device market (Compl. ¶6). The screenshot from a Garmin dealer locator map shows multiple retail locations for Garmin products within the judicial district (Compl. p. 5).

IV. Analysis of Infringement Allegations

7,489,241 Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: Claim 9 uses means-plus-function language (e.g., "strike event detecting means"). The scope of these claim terms is limited to the structures disclosed in the patent's specification for performing the claimed function, and their equivalents. A central question may be whether the specific hardware (e.g., accelerometer) and software algorithms used in Garmin's "AutoShot" feature are structurally equivalent to the disclosed embodiments in the '241 Patent, which include detection via sound, vibration, pressure, or acceleration sensors ('241 Patent, col. 2:50-65).

8,021,306 Infringement Allegations

• Identified Points of Contention:
  • Technical Questions: The patent distinguishes its "time domain" approach from more computationally intensive frequency-domain analyses. A key technical question will be what specific algorithm Garmin's processor uses to derive respiration rate from HRV. The infringement analysis may turn on whether Garmin's method operates "in the time domain" by creating and analyzing the period of a series of time-stamped pulses, as claimed, or if it uses a different technique that falls outside the claim's scope.

V. Key Claim Terms for Construction

• Term: "strike event" (’241 Patent, Claim 9)
  • Context and Importance: The detection of a "strike event" is the trigger for the entire claimed system. Its definition is critical to determining the scope of infringing activities. Practitioners may focus on this term because the complaint centers on golf, but the patent's language could potentially cover impacts in other sports.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification suggests the event can be detected by various means, including "vibration, pressure, or sound," and through "acceleration sensors," which are not inherently limited to golf (’241 Patent, col. 2:50-65).
    • Evidence for a Narrower Interpretation: The patent's background and described embodiments focus exclusively on the game of golf, which may support an interpretation limiting the term to the context of striking a ball with an implement like a golf club (’241 Patent, col. 2:5-41).
• Term: "determine in the time domain" (’306 Patent, Claim 11)
  • Context and Importance: This term is central to the patent's asserted novelty over prior art that allegedly relied on frequency-domain analysis. The infringement determination for the '306 Patent may depend heavily on whether Garmin's accused HRV analysis method is properly characterized as a "time domain" process.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification contrasts the invention with methods requiring Fourier transforms, suggesting "time domain" could be broadly construed to mean any analysis performed on the sequence of pulse intervals that does not require transformation to the frequency domain (’306 Patent, col. 2:28-32).
    • Evidence for a Narrower Interpretation: The specification describes a specific implementation for this step, involving forming a time series, "calculating the second derivatives of the series and examining the zeros of this new series" to find the period. This specific disclosure could be used to argue for a narrower construction limited to that disclosed method or its equivalents (’306 Patent, col. 3:35-40).

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement of the '241 Patent, stating that Defendant provides user manuals and instructions that teach and encourage end users to use the accused "automatic shot detection" features (Compl. ¶25). The complaint includes a screenshot from the Garmin Approach S70 Owner's Manual which instructs the user on the "automatic shot detection and recording" feature (Compl. p. 9).
• Willful Infringement: While the complaint does not contain a specific count for willful infringement, it alleges that at least from the filing of the lawsuit, Defendants are aware of the '241 Patent and that their actions encourage infringement, but continue these actions despite such awareness (Compl. ¶25). The prayer for relief requests attorneys' fees pursuant to 35 U.S.C. § 285 based on the "exceptional nature of this case" (Compl. p. 55).

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

• A core issue for the '241 Patent will be one of means-plus-function scope: is the specific hardware and software algorithm in Garmin’s "AutoShot" feature structurally equivalent to the "strike event detecting means" disclosed in the patent's specification, or does it represent a distinct, non-equivalent technology?
• A key technical question for the '306 Patent will be one of algorithmic scope: does Garmin's method for deriving respiration rate from Heart Rate Variability operate "in the time domain" as required by the claims, or does it employ a fundamentally different computational approach (such as a frequency-domain analysis) that the patent itself distinguishes as prior art?
• For the '774 and '731 hardware patents, a central question will be one of structural correspondence: do the physical antenna assemblies in the accused Garmin fēnix watches—specifically the interaction between the bezel, housing, and circuit board—replicate the specific "slot-mode" and "configurable attachment point" structures required by the asserted claims?