DCT

2:25-cv-01011

Eight Sleep Inc v. Somnus Lab

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-01011, E.D. Tex., 10/06/2025
  • Venue Allegations: Venue is asserted on the basis that both Defendants are foreign entities and may be sued in any judicial district pursuant to 28 U.S.C. § 1391(c)(3).
  • Core Dispute: Plaintiff alleges that Defendants’ Sleep Pad, a temperature-regulating mattress cover, infringes three U.S. patents related to systems and methods for monitoring users' biological signals to dynamically control a bed's temperature.
  • Technical Context: The technology operates in the "sleep fitness" market, where smart devices integrate biometric sensors and thermal regulation to actively manage the sleep environment and improve sleep quality.
  • Key Procedural History: The complaint alleges that Plaintiff sent Defendants a notice letter regarding the asserted patents on September 29, 2025, approximately one week before filing the lawsuit, which may form a basis for allegations of willful infringement.

Case Timeline

Date Event
2014-06-05 Earliest Priority Date for ’461, ’240, and ’339 Patents
2020-10-06 ’461 Patent Issued
2024-08-01 Somnus Lab Founded (approximate)
2025-07-29 ’339 Patent Issued
2025-08-05 ’240 Patent Issued
2025-09-29 Plaintiff's Notice Letter Sent to Defendants
2025-10-01 Accused Product Expected Delivery Begins (approximate)
2025-10-06 Complaint Filing Date

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

U.S. Patent No. 10,792,461 - "Methods and Systems for Gathering and Analyzing Human Biological Signals" (Issued Oct. 6, 2020)

The Invention Explained

  • Problem Addressed: The patent background describes the limitations of existing sleep technologies like electric blankets, which require manual operation and lack the ability to dynamically adjust to a user's changing physiological state during different sleep stages (e.g., light sleep, deep sleep, REM sleep) (’461 Patent, col. 1:59-65).
  • The Patented Solution: The invention is a system for a bed device that uses embedded sensors to detect a user's biological signals (e.g., heart rate, temperature, motion) (’461 Patent, col. 4:55-60). A processor analyzes these signals to identify the user and regulate the bed's temperature via a coupled temperature control device, creating a responsive and personalized sleep environment (’461 Patent, Abstract; Fig. 1).
  • Technical Importance: The technology enabled a shift from static or pre-programmed heating/cooling to a dynamic system that responds in real-time to a user's actual biometric data throughout the night (’461 Patent, col. 2:7-14).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶34).
  • The essential elements of Claim 1 include:
    • At least one sensor integrated into a bed device, configured to detect a user's biological signal.
    • A temperature control device coupled to the bed device to regulate its temperature.
    • A processor communicatively coupled to the sensor and temperature control device.
    • The processor is configured to identify the user from a plurality of users based on the detected biological signal and regulate the bed's temperature based on that user's identity.
    • Biological signal data for identifying each user is stored for access by the processor.

U.S. Patent No. 12,377,240 - "Methods and Systems for Gathering and Analyzing Human Biological Signals" (Issued Aug. 5, 2025)

The Invention Explained

  • Problem Addressed: The patent addresses the same general problem as its family member, the ’461 Patent: the inadequacy of non-responsive sleep technologies (’240 Patent, col. 1:40-col. 2:10).
  • The Patented Solution: This invention focuses specifically on a dual-user system. It describes a method where biological signals are obtained from a first user in a first zone of the bed and a second user in an adjacent second zone (’240 Patent, col. 10:1-8). The system then generates separate temperature control instructions for each zone based on each user's distinct, specified preferences, allowing the two sides of the bed to be heated or cooled differently (’240 Patent, Abstract; col. 10:9-37).
  • Technical Importance: This approach provides a technical solution for dual-occupant beds, where individuals often have different thermal comfort levels and sleep patterns that cannot be addressed by a single-zone system (’240 Patent, col. 6:50-54).

Key Claims at a Glance

  • The complaint asserts at least claim 29, a system claim that implements the method of independent claim 1 (Compl. ¶46-48).
  • The essential elements of the method of Claim 1 include:
    • Obtaining a first biological signal from a first user on a first zone of a bed device.
    • Obtaining a second biological signal from a second user on an adjacent second zone.
    • Generating control signals with separate instructions to set the temperature of the first and second zones to different temperatures.
    • The instruction for each zone is based at least in part on that specific user's user-specified preference.
    • Sending the control signals to temperature control devices to heat or cool the two zones differently.

U.S. Patent No. 12,370,339 - "Methods and Systems for Gathering and Analyzing Human Biological Signals" (Issued July 29, 2025)

  • Technology Synopsis: This patent describes a method for timed and dynamic temperature control. The system determines a first control signal and a time to send it (e.g., to pre-heat or pre-cool a bed based on a user's bedtime), and later determines a second control signal to adjust the temperature in response to a new biological signal obtained while the user is in bed (’339 Patent, Abstract). This covers both a pre-conditioning phase based on schedule and a dynamic adjustment phase based on real-time biometrics.
  • Asserted Claims: The complaint asserts at least claim 29, a system claim that implements the method of independent claim 1 (Compl. ¶61-63).
  • Accused Features: The complaint alleges that the Accused Product's "Bedtime & Wake-Up Scheduling" feature, which pre-cools or pre-heats the bed, infringes the first control signal element, while its "Temperature Blocks Scheduling" feature, which adjusts temperature based on sleep stages, infringes the second control signal element (Compl. ¶66).

III. The Accused Instrumentality

Product Identification

  • The Somnus Lab "Sleep Pad" (the "Accused Product") (Compl. ¶25).

Functionality and Market Context

  • The Accused Product is described as an "intelligent temperature system" comprising a thin pad and a base unit that provides heating and cooling with "12–42 °C precision, per side" (Compl. ¶25). Its features allegedly include "Somnus Insight," a built-in monitoring system with sensors to track heart rate, respiration, HRV, and motion without wearables; "Dual-zone precision" for independent profiles on each side of the bed; and "Stage-aware comfort" that adjusts temperature based on sleep stage (Compl. ¶27; Ex. 23). The system also features a "Gentle Thermal Alarm" that uses a gradual temperature rise to wake a user (Compl. Ex. 5 at 4).
  • The complaint alleges the Accused Product is a direct competitor to Plaintiff's "Eight Sleep Pod," highlighting similarities in functionality, marketing, and the user interface of its companion smartphone application (Compl. ¶29). Defendants are allegedly taking pre-orders for the product for delivery to U.S. customers (Compl. ¶26).

IV. Analysis of Infringement Allegations

'461 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
at least one sensor that is a part of said bed device... configured to detect a biological signal of a user... The Accused Product's "Somnus Insight" system includes "Hidden sensors" built into the pad that read heart rate and breathing without wearables. ¶36 col. 5:7-13
a temperature control device operatively coupled to said portion of said bed device... configured to regulate said temperature... The Accused Product is a "temperature-regulating sleep system" that includes a pad and base unit for "precise cooling and heating." ¶37 col. 6:1-3
a processor... configured to identify said user from a plurality of users... based on said biological signal, and regulate said temperature... based on said user's identity... The "Somnus Lab App" functions as a processor that supports "dual-zone control so each sleeper can set their own target temperature," which allegedly requires identifying each user to apply their settings. ¶38 col. 7:6-14
wherein biological signal data to identify each user of said plurality of users is stored for access by said processor... The Accused Product's processor stores biological signal data to create "Personalized temp curves" where "each sleeper gets their perfect temperature," requiring stored data associated with user identity. ¶39 col. 19:6-10

'240 Patent Infringement Allegations

The complaint asserts system claim 29, which comprises a processor and memory storing instructions to implement the method of claim 1. The allegations map the Accused Product's functions to the steps of this method.

Claim Element (from Method of Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
obtaining at least one first biological signal from a first user... on a first zone... [and] at least one second biological signal from a second user... on a second zone... The Accused Product's use requires users to "lie down" on the pad, which has "Somnus Insight" sensors that obtain biological signals and "quietly keeps each side of the bed at your perfect climate." ¶50, ¶51 col. 10:1-8
generating a plurality of control signals... comprising (1) a first instruction to set the temperature of the first zone... and (2) a second instruction to set the temperature of the second zone to a second temperature that is different... The Somnus Lab App adjusts temperatures for two users independently, as shown in a screenshot depicting different settings for "Jack - Side A" and "Sally - Side B." This is also supported by marketing claims of "AI-driven personalization." ¶52 col. 10:9-25
wherein the first instruction is based at least in part on a first user-specified preference... and the second instruction is based at least in part on a second user-specified preference... The system adjusts temperatures based on each user's "specified preferences," including "scheduled temperature curves" and manual overrides. ¶52 col. 10:26-32
sending the plurality of control signals to at least one respective temperature control device... such that the first and second zones are heated or cooled differently... The Accused Product's core functionality is providing "dual-zone temperature adjustment," which necessarily involves sending signals to heat or cool the two zones differently according to the generated instructions. ¶53 col. 10:33-37
  • Identified Points of Contention:
    • Scope Questions: A central question for the ’461 Patent may be the interpretation of "identify said user... based on said biological signal." The dispute may focus on whether associating a user profile (e.g., "Jack") with a physical location ("Side A") in an app meets this limitation, or if the claim requires the system to actively distinguish between users via their biometric signature, particularly if they were to switch sides of the bed.
    • Technical Questions: For the ’240 Patent, the complaint cites evidence of both local processing ("Process at the edge") and cloud processing ("Orchestrate the backend") (Compl. ¶54; Ex. 31 at 1-2). This raises the question of whether the claimed "processor" and "memory" of system claim 29 reside in a single location or are distributed, which could impact infringement analysis, particularly if different components are controlled by different entities.

V. Key Claim Terms for Construction

  • The Term: "identify said user from a plurality of users" (’461 Patent, Claim 1)
    • Context and Importance: This term is critical to the infringement theory of the ’461 Patent. The case may turn on whether the accused system’s "dual-zone" functionality, which applies settings to a specific side of the bed, constitutes "identifying" a user from a group, or merely associating a setting with a location.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent does not explicitly define the term. A party could argue that any association of a biological signal with a stored user profile, even one fixed to a location like "Side A," satisfies the claim.
      • Evidence for a Narrower Interpretation: The specification suggests a more robust identification, stating that "even if the users switch sides of the bed, the system will correctly identify the user" (’461 Patent, col. 7:6-9). This language may support an interpretation requiring active biometric identification rather than simple positional association.
  • The Term: "user-specified preference" (’240 Patent, Claim 1)
    • Context and Importance: Practitioners may focus on this term because infringement requires the system's temperature instructions to be based on such preferences. The scope of "preference" will be important—whether it covers a single temperature setting or requires a more complex input like a multi-stage schedule.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification states that the "desired temperature may be specified by the user," which could support an interpretation that a simple numerical temperature setting is a sufficient "preference" (’240 Patent, col. 8:14-15).
      • Evidence for a Narrower Interpretation: Embodiments described in the patent focus on more complex user inputs, such as preferences for each subzone of the bed (’240 Patent, col. 7:16-24). A party could argue the term should be construed in light of these more detailed examples. The complaint points to "AI-driven personalization" as evidence, suggesting a complex preference model (Compl. ¶52).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendants' advertising, user manuals, and other support materials instruct and encourage customers to use the Accused Product in an infringing manner (e.g., by using the dual-zone temperature controls) (Compl. ¶40, ¶55, ¶72).
  • Willful Infringement: Willfulness is alleged based on both pre-suit and post-suit knowledge. The complaint cites a "Notice Letter" dated September 29, 2025, as evidence of pre-suit notice (Compl. ¶30). It further alleges willful blindness, arguing that the "striking resemblance" between the parties' respective smartphone applications, including identical timestamps in marketing screenshots, should have prompted a reasonable company to investigate Plaintiff's patent rights (Compl. ¶29). This side-by-side comparison of the application interfaces is a key piece of visual evidence (Compl. p. 15).

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

  1. A core issue will be one of definitional scope: does assigning a user's settings to a specific side of the bed, as depicted in the accused app's interface (Compl. p. 22), satisfy the ’461 Patent’s requirement to “identify said user… based on said biological signal,” or does the claim require a more sophisticated biometric recognition that can distinguish between users regardless of their position?

  2. A central evidentiary question will be one of technical implementation: beyond marketing claims like "AI-driven personalization" and "Stage-aware comfort," what is the actual operational logic of the Accused Product? Discovery will be needed to determine if its software and hardware in fact perform the specific, multi-step methods of obtaining biological signals and generating user-preference-based control signals as required by the asserted claims.

  3. A significant question regarding damages will be the Defendants' state of mind. The complaint's visual evidence showing "uncanny" similarities between the parties' mobile apps (Compl. p. 14-15) raises a question of whether Defendants engaged in deliberate copying or willful blindness, which, if proven, could support a finding of willful infringement and potential for enhanced damages.