DCT

2:25-cv-00967

Suunto Oy v. Garmin Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
    • Plaintiff: Suunto Oy (Finland)
    • Defendant: Garmin Ltd. (Switzerland)
    • Plaintiff’s Counsel: Capshaw & Siegmund
  • Case Identification: 2:25-cv-00967, E.D. Tex., 09/22/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant sells accused products through an interactive website and at physical retail locations within the Eastern District of Texas. The complaint further alleges that because Garmin is not a U.S. resident, venue is proper in any judicial district.
  • Core Dispute: Plaintiff alleges that Defendant’s smartwatches infringe five patents related to wearable device technologies, including automatic golf shot tracking, energy-efficient physiological monitoring, and antenna assemblies.
  • Technical Context: The dispute involves core technologies in the competitive sports and fitness smartwatch market, focusing on the automated collection of athletic performance data and the physical design of wearable antennas.
  • Key Procedural History: The complaint notes that U.S. Patent Nos. 8,021,306 and 10,734,731 are continuations of earlier applications, establishing earlier priority dates for the claimed subject matter.

Case Timeline

Date Event
2004-06-16 Priority Date for U.S. Patent No. 7,489,241
2005-10-21 Priority Date for U.S. Patent No. 7,271,774
2006-05-12 Priority Date for U.S. Patent No. 8,021,306
2009-02-10 U.S. Patent No. 7,489,241 Issues
2011-09-20 U.S. Patent No. 8,021,306 Issues
2013-03-11 Priority Date for U.S. Patent No. 10,734,731
2018-02-08 Priority Date for U.S. Patent No. 11,018,432
2020-08-04 U.S. Patent No. 10,734,731 Issues
2021-05-25 U.S. Patent No. 11,018,432 Issues
2025-09-22 Complaint Filed

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"

The Invention Explained

  • Problem Addressed: The patent's background section describes the problem of golfers having to manually record information about their game, such as club choice and stroke location, which is easily forgotten and distracts from concentrating on play (Compl. ¶ 3; ’241 Patent, col. 1:20-44).
  • The Patented Solution: The invention is a wrist-worn computer that automatically detects a "strike event" (e.g., hitting a golf ball) and, in response, determines and records the GPS position of that event. This allows for seamless tracking of shots without manual user input during the game (’241 Patent, Abstract; col. 2:9-14).
  • Technical Importance: This approach automated a key part of golf performance tracking, shifting the burden from manual data entry to sensor-based event detection on a wearable device.

Key Claims at a Glance

  • The complaint asserts independent claim 1 and system claim 9, as well as dependent claims 2, 4, 10, and 12 (Compl. ¶ 22).
  • Independent Claim 1 requires:
    • A method in connection with a wristop computer
    • detecting a strike event with the aid of a measurement
    • determining a GPS position of the user when the strike event is detected
    • recording at least the GPS position of the user within a wearable wristop computer

U.S. Patent No. 8,021,306 - "Method, device and computer program product for monitoring the physiological state of a person"

The Invention Explained

  • Problem Addressed: The patent addresses the challenge of accurately estimating a person's energy consumption during exercise, noting that prior methods were often computationally intensive, required large memory capacities, or relied on difficult-to-obtain physiological data like maximum oxygen consumption, making them ill-suited for power-constrained wearable devices (’306 Patent, col. 1:15-41).
  • The Patented Solution: The invention provides an energy-efficient method for determining a person's respiratory rate by analyzing the "periodicity of the temporal variation of the pulse intervals (pulse interval noise)" directly in the "time domain." This avoids computationally expensive frequency-domain transformations (like a Fourier transform), conserving battery life in portable devices (’306 Patent, Abstract; col. 2:16-32).
  • Technical Importance: This solution enabled physiological monitoring features on wearable devices where battery conservation is a critical design constraint.

Key Claims at a Glance

  • The complaint asserts independent device claim 11 (Compl. ¶ 195).
  • Independent Claim 11 requires:
    • A portable device for monitoring a physiological state
    • a sensor for detecting heartbeat or means for receiving a pulse signal
    • a processing unit for determining the respiratory frequency based on the periodicity of the temporal variation of the pulse interval
    • wherein the processing unit is adapted to determine this periodicity in the time domain by time stamping pulses and determining the period of the resulting series of time points

U.S. Patent No. 11,018,432 - "Slot mode antennas"

  • Technology Synopsis: The patent describes an antenna assembly for a wearable device, such as a smartwatch, that uses a conductive body (e.g., a metal bezel) and a conductive rim on a circuit board to form a "slot mode antenna." This design aims to provide strong signal reception even when metal components are incorporated into the watch design, which could otherwise interfere with performance (’432 Patent, Abstract; col. 1:21-34).
  • Asserted Claims: The complaint asserts at least exemplary claim 1 (Compl. ¶ 588).
  • Accused Features: The antenna structures within the Garmin fēnix 5, 6, 7, and 8 series smartwatches are accused of infringement (Compl. ¶ 588).

U.S. Patent No. 7,271,774 - "Electronic wearable device"

  • Technology Synopsis: This patent discloses a wrist-wearable electronic device with an "integral slot antenna" formed directly in the conductive material portion of the device's outer housing. By integrating the antenna into the housing itself, the invention seeks to save internal space and improve performance by enabling a larger antenna dimension than would be possible if it were an internal component (’774 Patent, Abstract; col. 2:6-14).
  • Asserted Claims: The complaint asserts at least exemplary claim 1 (Compl. ¶ 593).
  • Accused Features: The antenna structures within the Garmin fēnix 5, 6, 7, and 8 series smartwatches are accused of infringement (Compl. ¶ 593).

U.S. Patent No. 10,734,731 - "Antenna assembly for customizable devices"

  • Technology Synopsis: This patent describes a tunable antenna assembly that allows for cost-efficient customization of wearable devices. The design includes an antenna element with multiple attachment points for a connecting member, allowing the same printed circuit board to be used with different device variants (e.g., different bezels) by simply changing where the connecting member is coupled, thereby tuning the antenna's performance (’731 Patent, Abstract; col. 1:49-55).
  • Asserted Claims: The complaint asserts at least exemplary claim 1 (Compl. ¶ 598).
  • Accused Features: The antenna structures within the Garmin fēnix 5, 6, 7, and 8 series smartwatches are accused of infringement (Compl. ¶ 598).

III. The Accused Instrumentality

Product Identification

  • The complaint names numerous Garmin smartwatches, primarily grouped into two categories of accused functionalities:
    1. Golf Shot Tracking: Products including the Garmin Approach series (S70, S62, etc.), MARQ Golfer, fēnix series, and EPIX series watches that incorporate Garmin’s "AutoShot" feature (Compl. ¶ 21).
    2. Respiration Rate Monitoring: A broad range of Garmin smartwatches across nearly all product families (Approach, fēnix, Forerunner, Venu, etc.) that include an optical heart rate sensor and calculate respiration rate (Compl. ¶ 195).
    3. Antenna Structures: The Garmin fēnix 5, 6, 7, and 8 series smartwatches are accused of infringing the three antenna patents (’432, ’774, and ’731 Patents) (Compl. ¶¶ 588, 593, 598).

Functionality and Market Context

  • The complaint alleges the accused golf watches use features like "automatic shot detection and recording" to automatically track and measure the distance of a user's golf shots (Compl. ¶ 24). The complaint provides a screenshot from the Approach S70 manual stating, "Your device features automatic shot detection and recording" (Compl. p. 9).
  • The complaint alleges the accused physiological monitoring watches use an optical heart rate sensor to obtain heart rate data and determine a user's respiration rate based on an analysis of "Heart Rate Variability" derived from that signal (Compl. ¶ 201).
  • The complaint alleges Garmin is a major commercial entity in the smartwatch and wearable device market, offering products with advanced sensor technology (Compl. ¶ 6).

IV. Analysis of Infringement Allegations

’241 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A method in connection with a wristop computer... The accused products, such as the Garmin Approach S70, are smartwatches designed to be worn on the wrist. ¶26 col. 4:8-10
detecting a strike event with the aid of a measurement... The accused products automatically detect when a user hits a golf ball, a function based in part on an accelerometer. ¶29, ¶30, ¶34 col. 4:51-54
determining a GPS position of the user when the strike event is detected... The accused products include GPS functionality and determine a GPS position when a user strikes a golf ball. ¶36, ¶37 col. 4:55-58
recording at least the GPS position of the user within a wearable wristop computer... The accused products feature automatic recording of shot information, allowing a user to view shot distance later. ¶32, ¶35 col. 4:59-62
  • Identified Points of Contention:
    • Scope Questions: A central question may be whether the sensor data and algorithms used by Garmin's "AutoShot" feature constitute "detecting a strike event with the aid of a measurement" as understood in the context of the patent. The defense may argue that its method of detection differs from what the patent discloses or claims.
    • Technical Questions: The complaint alleges detection is based "in whole or in part on an accelerometer" (Compl. ¶34). The case may require evidence on precisely how the accused devices process accelerometer data to distinguish a golf swing from other user movements and whether that process aligns with the method claimed.

’306 Patent Infringement Allegations

Claim Element (from Independent Claim 11) Alleged Infringing Functionality Complaint Citation Patent Citation
A portable device for monitoring the physiological state of a person... The accused products are smartwatches that monitor physiological states. ¶195 col. 2:1-2
a sensor for detecting heartbeat in order to create a pulse signal or means for receiving a pulse signal... The accused products include an optical heart rate sensor that obtains heart rate data. ¶199 col. 2:2-5
a processing unit for determining the respiratory frequency of the person on the basis of the periodicity of the temporal variation of the pulse interval... The accused products include a processor that determines a user's respiration rate based on an analysis of Heart Rate Variability (HRV) derived from the optical heart rate signal. ¶201, ¶202 col. 2:5-9
wherein the processing unit is adapted to determine... periodicity of the temporal variation of the pulse interval... in the time domain by time stamping pulses... and determining the period of the series... The complaint alleges the respiration rate is determined from HRV derived from the optical heart rate signal. The complaint does not provide sufficient detail for analysis of whether this determination is performed specifically "in the time domain" by "time stamping pulses" as required by the claim. ¶201 col. 2:9-15
  • Identified Points of Contention:
    • Scope Questions: The case may turn on whether Garmin's use of "Heart Rate Variability" (HRV) is equivalent to the patent's claimed "periodicity of the temporal variation of the pulse interval" (also described as "pulse interval noise").
    • Technical Questions: A key evidentiary question will be whether Garmin's method for calculating respiration rate from HRV operates "in the time domain" as the claim requires, or if it uses a different computational approach, such as a frequency-domain analysis, that would fall outside the claim scope.

V. Key Claim Terms for Construction

Term from the ’241 Patent: "strike event"

  • Context and Importance: The definition of this term is central to the infringement analysis. The scope of "strike event" will determine what type of sensor activity (e.g., acceleration, vibration, sound) and what level of certainty is required to trigger the claimed method steps of determining and recording a GPS position.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification mentions detection can be implemented with "vibration, pressure, or sound" or "acceleration detection, or a mechanical switch," suggesting the term is not limited to a single physical phenomenon (’241 Patent, col. 2:38-46).
    • Evidence for a Narrower Interpretation: The detailed description focuses heavily on the context of a golf club striking a ball, which could be used to argue that the "strike event" must be an impact characteristic of that specific activity, excluding other motions or impacts (’241 Patent, col. 3:23-26).

Term from the ’306 Patent: "pulse interval noise"

  • Context and Importance: This term is the core technical concept upon which the claimed invention operates. Infringement will depend on whether Garmin's analysis of "Heart Rate Variability" falls within the patent's definition of "pulse interval noise."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent states that within the time between pulse periods, "there are variations (noise), which are mainly influenced by respiration," suggesting "pulse interval noise" is a general descriptor for these variations from which a respiration signal can be extracted (’306 Patent, col. 2:53-56).
    • Evidence for a Narrower Interpretation: The detailed description repeatedly links the term to a specific method of time-domain analysis involving "time stamps" and calculating derivatives of the resulting time series, which might suggest the term is limited to data processed in this specific manner (’306 Patent, col. 3:30-41; col. 6:23-46).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement of the ’241 Patent, stating that Garmin provides user manuals and instructions that "encourage infringement" by teaching end users how to use the accused "automatic shot detection and recording" features (Compl. ¶ 24). The complaint includes a screenshot from an owner's manual for the Approach S70 as evidence (Compl. p. 9).
  • Willful Infringement: The complaint does not allege pre-suit knowledge of the patents. It bases its request for enhanced damages on Defendant's alleged awareness of the patents "at least as a result of the filing of this action," which may support a claim for post-suit willful infringement (Compl. ¶ 24).

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

  • A central issue will be one of technical implementation: Does Garmin's "AutoShot" feature, which relies on accelerometer data, perform the specific steps of "detecting a strike event" and responsively recording a GPS position in a manner that falls within the scope of the ’241 patent's claims?
  • A key question of definitional scope will be whether Garmin's use of "Heart Rate Variability" (HRV) to calculate respiration is technically and legally equivalent to the ’306 patent's claimed method of analyzing "pulse interval noise" directly "in the time domain."
  • The dispute over the three antenna patents (’432, ’774, and ’731) will likely focus on structural equivalence: Do the physical antenna assemblies in Garmin's fēnix smartwatches, specifically the relationship between the bezel, casing, and circuit board, incorporate the specific "slot mode" antenna structures claimed in the patents-in-suit?