DCT

2:25-cv-01064

Ouraring Inc v. Samsung Electronics America Inc

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Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-01064, E.D. Tex., 11/24/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant Samsung Electronics America, Inc. maintains a regular and established place of business in Plano, Texas, and Defendant Samsung Electronics Co., Ltd. is a foreign corporation that has committed acts of infringement in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s Galaxy Ring smart ring and associated applications infringe eight U.S. patents related to the design, construction, and manufacturing of wearable computing devices.
  • Technical Context: The technology at issue involves finger-worn smart rings that incorporate various sensors to monitor a user's physiological data, such as heart rate, temperature, and movement, for health and fitness tracking.
  • Key Procedural History: The complaint notes significant pre-suit activity, alleging that months before the launch of the accused product, Samsung filed a declaratory judgment action of non-infringement against five Oura patents, including the ’178 patent-in-suit. The complaint also states that Samsung has concurrently challenged the validity of the ’178 patent and eleven other Oura patents through Post Grant Review and Inter Partes Review proceedings at the Patent Trial and Appeal Board.

Case Timeline

Date Event
2013-11-29 Earliest Priority Date for all Patents-in-Suit
2015-01-01 Oura Ring Gen. 1 Released
2018-01-01 Oura Ring Gen. 2 Released
2021-01-01 Oura Ring Gen. 3 Released
2024-01-09 U.S. Patent No. 11,868,178 Issued
2024-01-01 Oura Ring Gen. 4 Released
2024-05-30 Samsung files Declaratory Judgment action in N.D. Cal.
2024-05-31 Samsung files Post Grant Review of '178 Patent
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 Original Complaint Filed
2025-11-24 First Amended Complaint Filed

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

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

  • Issued: January 9, 2024

The Invention Explained

  • Problem Addressed: The patent background describes many contemporary wearable electronics as being "bulky and can be intrusive or interfere with a person's daily life," making them uncomfortable for extended wear (US 11868178B2, col. 1:43-47).
  • The Patented Solution: The invention is a wearable computing device in the form of a ring, which is designed to be worn for extended periods to take measurements and perform various functions (’178 Patent, col. 1:52-55). The core concept involves a specific structural arrangement where components like a battery and a flexible printed circuit board are disposed within a cavity formed between an inner and outer housing component (’178 Patent, Abstract; Fig. 4).
  • Technical Importance: This ring-based form factor provides a non-intrusive method for continuous physiological monitoring, addressing the comfort and wearability issues of larger wrist-worn devices (Compl. ¶1).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶41).
  • The essential elements of claim 1 include:
    • An external housing component
    • An internal housing component coupled with the external one
    • A battery positioned within a cavity formed between the two housing components
    • A printed circuit board also disposed between the housing components
    • One or more sensors electrically coupled to the board and battery, configured to acquire data through the internal housing component
  • The complaint reserves the right to assert additional claims (Compl. ¶41).

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

  • Issued: July 8, 2025

The Invention Explained

  • Problem Addressed: Like the ’178 Patent, the background addresses the problem that many wearable devices are bulky and not suitable for comfortable, long-term use (’244 Patent, col. 1:41-47).
  • The Patented Solution: The invention is a wearable ring device that tracks metrics like physical movement, skin temperature, heart rate, and blood oxygenation (Compl. ¶57). This patent specifies a particular construction comprising an "internal potting" material that encapsulates components, including a "curved battery," and sets forth specific dimensional ranges for the housing's diameter, width, and thickness (’244 Patent, Claim 1; Compl. ¶58).
  • Technical Importance: The claimed solution details a specific method of construction and component selection—including potting, a curved battery, and defined physical dimensions—to realize a functional and compact smart ring device (Compl. ¶57-58).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶59).
  • The essential elements of claim 1 include:
    • An external housing with specified dimensional ranges (interior/exterior diameter, width, thickness)
    • 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
  • The complaint reserves the right to assert additional claims (Compl. ¶59).

U.S. Patent No. 12,346,159 (’159 Patent) - “Wearable Computing Device”

  • Issued: July 1, 2025 (Compl. ¶73)
  • Technology Synopsis: The patent describes a wearable ring device with a specified internal construction, including external and internal housings, a curved battery, a printed circuit board, and a suite of sensors for health tracking (Compl. ¶75-76). The claims also specify dimensional ranges for the housing, similar to the ’244 Patent (Compl. ¶76).
  • Asserted Claims: At least Claim 1 (Compl. ¶77).
  • Accused Features: The complaint alleges that the Samsung Galaxy Ring’s physical construction, including its housing, curved battery, printed circuit board, and sensor array (accelerometer, temperature sensor, LEDs, light sensors), infringes the ’159 Patent (Compl. ¶79).

U.S. Patent No. 12,393,227 (’227 Patent) - “Wearable Computing Device”

  • Issued: August 19, 2025 (Compl. ¶91)
  • Technology Synopsis: This patent claims a method of manufacturing a wearable ring device. The claimed method comprises steps of constructing an external housing, inserting components such as a curved battery and printed circuit board, applying an "internal potting" to fill the internal space and cover the components, and polymerizing that potting to form the ring's interior surface (Compl. ¶94).
  • Asserted Claims: At least Claim 1 (Compl. ¶95).
  • Accused Features: The complaint alleges that Samsung’s process for manufacturing the Galaxy Ring infringes the claimed method (Compl. ¶96). Evidence of importation is provided via an image of the product packaging, which states "MADE IN VIETNAM BY SAMSUNG" (Compl. p. 42, Exhibit 17).

U.S. Patent No. 12,346,160 (’160 Patent) - “Wearable Computing Device”

  • Issued: July 1, 2025 (Compl. ¶108)
  • Technology Synopsis: The patent describes a wearable ring device with an external housing made of a "metallic material," along with an internal potting, a curved battery, a printed circuit board, and various sensors (Compl. ¶111). The claims also specify dimensional ranges for the housing (Compl. ¶111).
  • Asserted Claims: At least Claim 1 (Compl. ¶112).
  • Accused Features: The complaint accuses the Samsung Galaxy Ring, which is marketed as having a "Durable titanium frame," of infringing the '160 patent through its metallic construction and internal components (Compl. ¶114; p. 49).

U.S. Patent No. 12,422,889 (’889 Patent) - “Wearable Computing Device”

  • Issued: September 23, 2025 (Compl. ¶126)
  • Technology Synopsis: This patent discloses a wearable ring having an external housing made of a metallic material that includes a first and second "flange" to define an internal space (Compl. ¶129). It further claims an internal potting that partially surrounds the internal components and forms an interior surface that contacts the user's finger (Compl. ¶129).
  • Asserted Claims: At least Claim 1 (Compl. ¶130).
  • Accused Features: The complaint alleges the Samsung Galaxy Ring’s metallic housing, use of internal potting, and arrangement of its battery, PCB, and sensors infringes the ’889 Patent (Compl. ¶132).

U.S. Patent No. 12,429,909 (’909 Patent) - “Wearable Computing Device”

  • Issued: September 30, 2025 (Compl. ¶144)
  • Technology Synopsis: This patent claims a method of manufacturing a wearable ring by constructing an external housing with a first and second flange, inserting components, and applying an internal potting that partially fills the internal space and forms an interior surface to contact the user's finger (Compl. ¶147).
  • Asserted Claims: At least Claim 1 (Compl. ¶148).
  • Accused Features: Samsung’s manufacturing process for the Galaxy Ring is accused of infringing the ’909 Patent, with the complaint again citing importation of the finished product (Compl. ¶149, ¶153).

U.S. Patent No. 12,222,759 (’759 Patent) - “Wearable Computing Device”

  • Issued: February 11, 2025 (Compl. ¶161)
  • Technology Synopsis: The patent describes a wearable ring with a housing made of, at least in part, a metallic material (Compl. ¶164). The claimed device includes a curved battery, printed circuit board, and a plurality of sensors comprising light-emitting and light-receiving components, as well as a communication module (Compl. ¶164).
  • Asserted Claims: At least Claim 17 (Compl. ¶165).
  • Accused Features: The complaint alleges the Samsung Galaxy Ring, with its metallic housing and array of optical sensors and communication modules, infringes the ’759 Patent (Compl. ¶167).

III. The Accused Instrumentality

Product Identification

  • The accused products are the Samsung Galaxy Ring and its associated applications, including the Galaxy Wearable Application and the Samsung Health Application (collectively, the "Accused Product") (Compl. ¶42).

Functionality and Market Context

  • The Accused Product is a finger-worn wearable device designed for health and activity monitoring (Compl. ¶43, ¶47). Based on technical specifications provided in the complaint, the Galaxy Ring includes an accelerometer, a photoplethysmography (PPG) sensor comprising two photodetectors (PD) and three light-emitting diodes (LEDs) of red, green, and infrared wavelengths, and a skin temperature sensor (Compl. p. 14, 23). An image from Samsung's website describes the device as having a "Durable titanium frame" (Compl. p. 49).
  • Samsung's website allegedly describes the product as packing "the latest health tracking innovations into a compact design that fits comfortably around your finger" (Compl. ¶47). The complaint alleges the product is part of a market for smart ring wearables pioneered by Oura (Compl. ¶1, ¶5).

IV. Analysis of Infringement Allegations

’178 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a finger-worn wearable ring device, comprising: The Samsung Galaxy Ring is a finger-worn device. ¶43 col. 43:45-46
an external housing component... The Accused Product possesses an external housing. ¶43 col. 43:47-49
an internal housing component... The Accused Product possesses an internal housing. ¶43 col. 43:50-54
a battery positioned within a cavity formed between the internal housing component and the external housing component... The Accused Product possesses a battery, allegedly positioned within a cavity between housing components. ¶43 col. 43:58-67
a printed circuit board disposed between the internal housing component and the external housing components... The Accused Product possesses a printed circuit board, allegedly disposed between housing components. ¶43 col. 45:1-4
one or more sensors electrically coupled with the printed circuit board and the battery and configured to acquire data from the user through the internal housing component The Accused Product possesses multiple sensors, including PPG, accelerometer, and temperature sensors, which acquire data from the user. A marketing image shows these sensors on the interior of the ring (Compl. p. 13). ¶43 col. 45:5-9

’244 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a wearable ring device... comprising: The Samsung Galaxy Ring is a wearable ring device. ¶61 col. 43:45-46
an external housing... wherein the housing has an interior diameter between 12 mm and 24 mm, an exterior diameter between 18 mm and 30 mm, a width between 3 mm and 8 mm, and a thickness between 1.5 mm and 3 mm; The Accused Product's technical specifications list a width of 7.0mm and thickness of 2.6mm, which fall within the claimed ranges. ¶61; p. 23 col. 43:52-57
an internal potting...; The Accused Product is alleged to possess "an internal plotting" (presumed typo for potting). ¶61 col. 43:58-59
a curved battery...; The Accused Product is alleged to possess a curved battery. ¶61 col. 43:60
a printed circuit board...; The Accused Product possesses a printed circuit board. ¶61 col. 43:61
an accelerometer...; The Accused Product's specifications confirm it includes an accelerometer. ¶61; p. 23 col. 43:62
a temperature sensor...; The Accused Product's specifications confirm it includes a skin temperature sensor. ¶61; p. 23 col. 43:63
a first light emitting diode (LED)...; a second LED...; and one or more light sensors... The Accused Product's specifications list a PPG sensor with "2PD + 3LED (R / 2xG / IR)," satisfying these elements. A visual from Samsung's marketing materials depicts an optical bio-signal sensor, skin temperature sensor, and accelerometer (Compl. p. 22). ¶61; p. 23 col. 43:64-67

Identified Points of Contention

  • Structural Scope: For the ’178 Patent, a primary question may be whether the accused Galaxy Ring is constructed with distinct "internal housing" and "external housing" components that form a "cavity," as required by the claim. The defense may argue for a different structural characterization (e.g., a unitary housing with potted-in components) that falls outside the claim's scope.
  • Technical Evidence: For the ’244 Patent, a key factual question will be what evidence demonstrates that the accused product contains "internal potting." The complaint's use of the term "plotting" (Compl. ¶61) suggests this may be an area of dispute, and its resolution will depend on evidence of Samsung's actual manufacturing materials and processes. Additionally, infringement will depend on whether the unspecified dimensions of the Galaxy Ring (e.g., interior/exterior diameter) meet the specific ranges recited in claim 1.

V. Key Claim Terms for Construction

"internal housing component" and "external housing component" (’178 Patent, Claim 1)

  • Context and Importance: The infringement analysis for the ’178 Patent hinges on whether the Galaxy Ring’s structure can be mapped onto these two claimed components. Practitioners may focus on this term because the defense could argue that the Galaxy Ring utilizes a single, unitary housing into which components are placed and encapsulated, rather than a structure made of two distinct "housing components" that are coupled together.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification of the patent family sometimes refers to these elements more generally as an "interior wall" and an "exterior wall" (’178 Patent, col. 1:56-58), which could support an interpretation where these are functional regions of a single structure rather than separate physical parts.
    • Evidence for a Narrower Interpretation: Figure 4 of the ’178 Patent depicts the "HOUSING" (412) as a distinct outer piece, separate from the internal assembly containing the battery and flex circuit. This figure may be used to argue that the claims require two physically separate and subsequently coupled pieces to be considered distinct "components."

"internal potting" (’244 Patent, Claim 1)

  • Context and Importance: This term is critical because infringement of the ’244 Patent, as well as the '159, '160, '889, '227, and '909 patents, depends on Samsung using a material that meets this definition. The complaint's typo ("plotting") suggests uncertainty, and the defense may argue that its encapsulation material or process (e.g., injection overmolding) is technically distinct from "potting."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The '244 patent's family describes potting as a material that can "seal the assembly" and be "transparent to allow light to pass through" (’244 Patent, col. 15:51-54). This functional language may support a broader definition that covers any encapsulant serving these purposes.
    • Evidence for a Narrower Interpretation: The specification also refers to "potting epoxy" as an example material (’244 Patent, col. 15:52). This could support an argument that "potting" is limited to a specific class of materials (like epoxy resins) applied in a specific manner (i.e., filling a pre-existing cavity), as distinct from other manufacturing techniques like transfer molding.

VI. Other Allegations

Indirect Infringement

  • The complaint alleges both induced and contributory infringement. Inducement allegations are based on Samsung’s user guides, website, and advertising, which allegedly instruct customers to use the Galaxy Ring in an infringing manner (Compl. ¶46-47, ¶64-65). Contributory infringement is alleged on the basis that Samsung supplies the Galaxy Ring hardware and software, knowing it to be especially made for use in an infringing manner and not a staple article of commerce (Compl. ¶49-50, ¶67-68).

Willful Infringement

  • Willfulness allegations for the ’178 Patent are based on alleged pre-suit knowledge, citing Samsung’s declaratory judgment complaint filed on May 30, 2024 (Compl. ¶51). For the other seven patents-in-suit, willfulness is alleged based on knowledge since at least the filing of the original complaint on October 24, 2025 (Compl. ¶69, ¶87, ¶104, ¶122, ¶140, ¶157, ¶175).

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

  1. A core issue will be one of structural interpretation: can the physical construction of the Samsung Galaxy Ring, particularly its housing and encapsulation method, be proven to meet the specific claim limitations of an "internal housing component" and "external housing component" (’178 Patent) or the use of "internal potting" (’244 Patent and related patents)? Resolution will likely depend on expert testimony regarding the product's tear-down and manufacturing process.
  2. A second key issue will be patent validity in a crowded portfolio: given the assertion of eight patents with significant overlap in their specifications and claimed subject matter, the case may involve extensive arguments over claim differentiation and validity, including potential double-patenting or obviousness-type double-patenting challenges from the defense.
  3. A significant legal question will be willfulness: does Samsung's pre-suit filing of a declaratory judgment action and a Post Grant Review against the '178 Patent establish an "objectively high likelihood" of infringement sufficient to support a finding of willfulness for that patent, potentially exposing Samsung to enhanced damages if found liable?