DCT

2:25-cv-01064

Ouraring Inc v. Samsung Electronics America Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-01064, E.D. Tex., 10/24/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains a regular and established place of business in the district, including a major facility in Plano, Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s Galaxy Ring smart ring and associated applications infringe eight U.S. patents related to the technology and manufacturing of wearable smart ring computing devices.
  • Technical Context: The technology concerns the design and function of health and activity-tracking sensors and components housed within a finger-worn ring, a segment of the growing wearable technology market.
  • Key Procedural History: The complaint describes significant pre-suit legal maneuvering. Plaintiff notes that months before the commercial launch of the accused product, Defendant initiated a declaratory judgment action for non-infringement of five Oura patents, including U.S. Patent No. 11,868,178, in May 2024. The complaint also states that Defendant has filed multiple Post Grant Review and Inter Partes Review petitions challenging the validity of Oura's patents before the Patent Trial and Appeal Board.

Case Timeline

Date Event
2013-11-29 Earliest Priority Date for all Patents-in-Suit
2024-01-09 U.S. Patent No. 11,868,178 Issued
2024-05-30 Samsung files Declaratory Judgment Action regarding '178 Patent
2024-05-31 Samsung files Post Grant Review against '178 Patent
2024-05-31 Samsung files IPR/PGR proceedings against other Oura patents
2024-06-28 Samsung files additional IPR/PGR proceedings
2025-01-23 Samsung files additional IPR proceeding
2025-02-11 U.S. Patent No. 12,222,759 Issued
2025-07-01 U.S. Patent No. 12,346,159 Issued
2025-07-01 U.S. Patent No. 12,346,160 Issued
2025-07-08 U.S. Patent No. 12,353,244 Issued
2025-08-19 U.S. Patent No. 12,393,227 Issued
2025-09-23 U.S. Patent No. 12,422,889 Issued
2025-09-30 U.S. Patent No. 12,429,909 Issued
2025-10-24 Complaint Filing Date

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

U.S. Patent No. 11,868,178 - "Wearable Computing Device"

The Invention Explained

  • Problem Addressed: The patent’s background section notes that many wearable electronics are “bulky and can be intrusive or interfere with a person’s daily life,” which makes them uncomfortable for extended periods of wear (’178 Patent, col. 1:42-46).
  • The Patented Solution: The invention is a wearable computing device in the form of a ring, which aims to be more comfortable for long-term use due to its form factor and position on a user's finger (’178 Patent, col. 1:52-55). The technology involves placing key electronic components—specifically a battery, a printed circuit board (PCB), and sensors—within a cavity formed between an inner and an outer housing component of the ring, as illustrated in Figure 4 (’178 Patent, Fig. 4).
  • Technical Importance: This design enables the miniaturization of health-tracking technology into a discreet and comfortable ring, facilitating continuous monitoring that may not be practical with larger, wrist-worn devices (Compl. ¶1).

Key Claims at a Glance

  • The complaint asserts one or more claims, including at least independent claim 1 (Compl. ¶32).
  • Claim 1 of the ’178 Patent includes the following essential elements:
    • An external housing component defining an outer circumferential surface.
    • An internal housing component defining an inner circumferential surface configured to contact the user's tissue.
    • A battery positioned within a cavity formed between the housing components and extending through a first portion of the cavity.
    • A printed circuit board disposed between the housing components and extending through a second portion of the cavity.
    • One or more sensors electrically coupled to the printed circuit board and battery, configured to acquire data from the user through the internal housing component.

U.S. Patent No. 12,353,244 - "Wearable Computing Device"

The Invention Explained

  • Problem Addressed: The complaint states that the patent is directed to a wearable ring device that allows a user to track physical movement, skin temperature, heart rate, and blood oxygenation levels (Compl. ¶48).
  • The Patented Solution: The ’244 Patent, as described in the complaint, discloses a wearable ring device with a specific combination of components and strict dimensional constraints. The claimed device includes an external housing, "internal potting," a curved battery, a printed circuit board, an accelerometer, a temperature sensor, a first LED, a second LED, and light sensors, all housed within a ring body with a specified range for its interior diameter, exterior diameter, width, and thickness (Compl. ¶49).
  • Technical Importance: This patented approach focuses on a specific manufacturable embodiment of a smart ring, defining both the required components and the physical dimensions necessary for its function (Compl. ¶49).

Key Claims at a Glance

  • The complaint asserts one or more claims, including at least independent claim 1 (Compl. ¶50).
  • Claim 1 of the ’244 Patent, as summarized in the complaint, includes the following essential elements:
    • An external housing with a specified interior diameter (12-24 mm), exterior diameter (18-30 mm), width (3-8 mm), and thickness (1.5-3 mm).
    • An internal potting.
    • A curved battery.
    • A printed circuit board.
    • An accelerometer.
    • A temperature sensor.
    • A first light emitting diode (LED).
    • A second LED.
    • One or more light sensors.

U.S. Patent No. 12,346,159 - "Wearable Computing Device"

  • Patent Identification: U.S. Patent No. 12,346,159 (“’159 Patent”), titled “Wearable Computing Device,” issued July 1, 2025 (Compl. ¶64).
  • Technology Synopsis: The patent discloses a wearable smart ring device for tracking physical movement, skin temperature, and blood oxygenation. The claims specify a particular combination of components, including an external and internal housing, a curved battery, a PCB, and various sensors, within defined dimensional ranges (Compl. ¶66-67).
  • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶68).
  • Accused Features: The complaint alleges the Samsung Galaxy Ring possesses the claimed external and internal housing, curved battery, PCB, accelerometer, temperature sensor, LEDs, and light sensors, and that its dimensions fall within the claimed ranges (Compl. ¶70).

U.S. Patent No. 12,393,227 - "Wearable Computing Device"

  • Patent Identification: U.S. Patent No. 12,393,227 (“’227 Patent”), titled “Wearable Computing Device,” issued August 19, 2025 (Compl. ¶82).
  • Technology Synopsis: The patent is directed to a method of manufacturing a wearable ring device. The claimed method includes constructing an external housing, inserting a curved battery and other components into the internal space, applying an "internal potting" to fill the space and cover the components, and then polymerizing the potting material (Compl. ¶85).
  • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶86).
  • Accused Features: The infringement allegation targets Samsung’s process for manufacturing the Galaxy Ring, including the assembly of its components within the housing and the use of an alleged internal potting material (Compl. ¶88, 93). The complaint also points to the importation of rings allegedly made by this method as an act of infringement (Compl. ¶91).

U.S. Patent No. 12,346,160 - "Wearable Computing Device"

  • Patent Identification: U.S. Patent No. 12,346,160 (“’160 Patent”), titled “Wearable Computing Device,” issued July 1, 2025 (Compl. ¶99).
  • Technology Synopsis: The patent discloses a wearable ring device for tracking health metrics, specifying that the external housing is made of a "metallic material." It otherwise claims a combination of components similar to the other asserted apparatus patents, including internal potting, a curved battery, a PCB, and various sensors (Compl. ¶102).
  • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶103).
  • Accused Features: The complaint alleges that the Samsung Galaxy Ring's "Durable titanium frame" meets the "metallic material" limitation for the external housing, in addition to possessing the other claimed internal components (Compl. ¶105-106, p. 47).

U.S. Patent No. 12,422,889 - "Wearable Computing Device"

  • Patent Identification: U.S. Patent No. 12,422,889 (“’889 Patent”), titled “Wearable Computing Device,” issued September 23, 2025 (Compl. ¶117).
  • Technology Synopsis: The patent claims a wearable ring apparatus with an external housing made of a metallic material. A key feature is the definition of the external housing as having an internal surface, a "first flange, and a second flange" that create an internal space for the components, which include internal potting, a curved battery, and sensors (Compl. ¶120).
  • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶121).
  • Accused Features: The complaint alleges the Samsung Galaxy Ring is constructed with a metallic external housing, internal potting, and the other claimed components, and that its housing structure includes the claimed "flange" elements (Compl. ¶123).

U.S. Patent No. 12,429,909 - "Wearable Computing Device"

  • Patent Identification: U.S. Patent No. 12,429,909 (“’909 Patent”), titled “Wearable Computing Device,” issued September 30, 2025 (Compl. ¶135).
  • Technology Synopsis: This patent claims a method of manufacturing a wearable ring device. The method involves constructing an external housing with a "first flange and a second flange," inserting components like a curved battery and PCB, and applying an internal potting material that forms an interior surface to contact the user's finger (Compl. ¶138).
  • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶139).
  • Accused Features: The infringement allegations concern Samsung's manufacturing processes for the Galaxy Ring, specifically the steps of constructing a flanged housing, inserting components, and applying potting material. The complaint includes a photograph of the product packaging indicating the device was "MADE IN VIETNAM BY SAMSUNG" to support its allegation of infringement by importation (Compl. ¶141, 144, p. 69).

U.S. Patent No. 12,222,759 - "Wearable Computing Device"

  • Patent Identification: U.S. Patent No. 12,222,759 (“’759 Patent”), titled “Wearable Computing Device,” issued February 11, 2025 (Compl. ¶152).
  • Technology Synopsis: The patent claims a wearable ring device comprising a housing made at least in part of a metallic material, a curved battery, a PCB, and a "plurality of sensors." This plurality includes "one or more light-emitting diode components," "one or more light-receiving components," and a "communication module" (Compl. ¶155).
  • Asserted Claims: At least independent claim 17 is asserted (Compl. ¶156).
  • Accused Features: The complaint alleges the Samsung Galaxy Ring possesses the claimed housing, battery, PCB, and the specified plurality of sensor and communication components (Compl. ¶158).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentality is the Samsung Galaxy Ring and its corresponding software applications, the Galaxy Wearable Application and the Samsung Health Application (Compl. ¶33).

Functionality and Market Context

  • The complaint describes the Galaxy Ring as a finger-worn smart ring designed for health and fitness tracking (Compl. ¶34, 38). Its functions include monitoring heart rate, physical movement, and skin temperature to provide users with health insights, including cycle tracking (Compl. ¶38, 56). The device incorporates an accelerometer, an optical bio-signal sensor (PPG), and a skin temperature sensor to perform these functions (Compl. ¶53, p. 20). The complaint presents a product specifications sheet listing a titanium housing, a 19.5mAh battery, an accelerometer, a PPG sensor, and a temperature sensor (Compl. ¶35, p. 12). Plaintiff alleges Defendant markets the product as packing "the latest health tracking innovations into a compact design that fits comfortably around your finger" (Compl. ¶38).

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits for its infringement allegations but does not include them with the filing. The narrative infringement theories are summarized below.

11,868,178 Patent Infringement Allegations

  • The complaint alleges that the Samsung Galaxy Ring directly infringes claim 1 of the ’178 Patent because it is a finger-worn wearable ring device that possesses the claimed structural elements (Compl. ¶32, 34). Specifically, it is alleged to have "an external housing component," "an internal housing component," "a battery," "a printed circuit board," and "one or more sensors" arranged as claimed (Compl. ¶34). The complaint provides an image from Samsung's website showing the interior of the ring with the caption "Precise monitoring with three sensors" as evidence of the claimed sensor and housing structure (Compl. ¶35, p. 11).

12,353,244 Patent Infringement Allegations

  • The complaint alleges the Samsung Galaxy Ring directly infringes claim 1 of the ’244 Patent by embodying all claimed elements, including specific dimensional requirements (Compl. ¶50, 52). The complaint asserts the accused product has "an external housing," "an internal plotting," "a curved battery," a "printed circuit board," and the specified accelerometer, temperature, and optical sensors (Compl. ¶52). To support the dimensional limitations, the complaint points to a specifications sheet from Samsung's website stating the Galaxy Ring has a width of 7.0mm and a thickness of 2.6mm, which falls within the claimed ranges of 3-8mm for width and 1.5-3mm for thickness (Compl. ¶49, 53, p. 21). The complaint includes a marketing image highlighting the accelerometer, optical bio-signal sensor, and skin temperature sensor as further evidence (Compl. ¶53, p. 20).

Identified Points of Contention

  • Scope Questions: For the ’178 Patent, a central question may be the interpretation of "first portion" and "second portion" of the cavity. The complaint does not provide evidence of the specific internal layout of the accused product's battery and PCB, which will likely be a focus of discovery and expert analysis to determine if they occupy distinct portions as claimed.
  • Technical Questions: For the ’244 Patent, a key dispute may arise over the term "internal potting." The complaint alleges the presence of this feature but provides no direct evidence, such as a cross-section of the accused product. The determination of whether Samsung's device uses a cured potting material versus a pre-formed internal housing component will be a critical factual question for infringement. For all apparatus claims, while the complaint provides marketing materials and high-level specifications, the actual internal construction and operation of the accused product will be central to the dispute.

V. Key Claim Terms for Construction

  • The Term: an internal housing component (’178 Patent) vs. an internal potting (’244 Patent)
  • Context and Importance: Practitioners may focus on the distinction between these terms, as they appear in the independent claims of two separate patents asserted against the same device. The patentee has chosen to claim these features separately, suggesting they are not coextensive. The infringement analysis may hinge on whether the accused product's internal structure is properly characterized as a pre-formed "component" or as a cured-in-place "potting."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification of the ’178 Patent describes an embodiment where an "internal housing portion" is configured to seal components within an internal space, and separately mentions that the device can be "potted with two different compounds" (’178 Patent, col. 2:38-44, col. 16:33-36). This could suggest the terms describe alternative, rather than mutually exclusive, constructions.
    • Evidence for a Narrower Interpretation: The ’178 Patent consistently uses the term "internal housing component" or "portion" when describing its primary structural embodiments, often with reference to figures showing a discrete part (e.g., "internal housing 1212" in Fig. 12E) (’178 Patent, col. 17:30-36). This may support an argument that a "component" is a distinct, pre-formed structural element, whereas "potting" implies an amorphous, cured-in-place material, as described in the manufacturing method claims of the ’227 and ’909 patents (Compl. ¶85, 138). The complaint does not provide intrinsic evidence from the ’244 Patent for analysis.

VI. Other Allegations

Indirect Infringement

  • The complaint alleges induced infringement across all asserted patents based on Defendant’s user manuals, websites, and other instructions that allegedly direct customers to use the Galaxy Ring in an infringing manner (Compl. ¶37-38, 55-56). Contributory infringement is alleged on the basis that Defendant supplies the Galaxy Ring, which contains components (housings, sensors, PCBs) that are a material part of the patented inventions and are not staple articles of commerce suitable for substantial non-infringing use (Compl. ¶40-41, 58-59). For the method patents ('227 and '909), infringement is also alleged under 35 U.S.C. § 271(g) based on the importation into the U.S. of a product made by a patented process (Compl. ¶92, 145).

Willful Infringement

  • Willfulness is alleged for all patents. For the '178 Patent, the allegation is based on pre-suit knowledge, evidenced by Defendant’s filing of a declaratory judgment action and a PGR petition specifically concerning that patent before this lawsuit was filed (Compl. ¶42-43). For the other patents, willfulness is based on knowledge acquired "since, at least, the filing of this Complaint" (Compl. ¶61, 79, 96, 114, 132, 149, 167).

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

  • A core issue will be one of evidentiary proof: can Plaintiff produce evidence, likely through discovery and reverse engineering, demonstrating that the internal construction of the Samsung Galaxy Ring meets the specific structural and material limitations of the asserted claims? This includes the spatial arrangement of the battery and PCB required by the ’178 patent and the existence of "internal potting" as required by the ’244, ’159, ’160, and ’889 patents.
  • A second key issue will be one of claim differentiation and validity: given the assertion of eight patents from the same family with overlapping technical disclosures, the case will likely involve significant disputes over claim construction to preserve the validity of each patent's claims as distinct from one another and from the prior art. Defendant's pre-suit validity challenges through IPR and PGR proceedings suggest that claim scope and patentability will be central battlegrounds.