Encelion LLC v. Firstbeat Tech Oy

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Encelion LLC (New Mexico)
  • Defendant: Firstbeat Technologies Oy (Finland)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-01105, E.D. Tex., 11/06/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign corporation.
• Core Dispute: Plaintiff alleges that Defendant’s products infringe a patent related to wearable pulse sensors that analyze pulse wave characteristics to infer a user's physiological state.
• Technical Context: The technology operates in the field of wearable health monitoring devices, a market focused on providing users with real-time data on biometrics like heart rate and, in this case, hydration levels.
• Key Procedural History: The complaint does not reference any prior litigation, inter partes review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 11,471,072 - Pulse sensor, system, and method for using a pulse sensor

The Invention Explained

• Problem Addressed: The patent describes the technical challenge of non-invasively monitoring a person's hydration status. It notes that as hydration decreases, blood viscosity increases, which in turn alters the shape and characteristics of the arterial pulse wave beyond just changing the heart rate (’072 Patent, col. 1:15-34).
• The Patented Solution: The invention proposes a sensor that uses a magnet positioned over an artery, such as on the wrist. The physical pulsation of the artery causes the magnet to move or tilt. A nearby magnetometer detects the resulting changes in the magnetic field (’072 Patent, Abstract; col. 6:54-62). By analyzing the full waveform of this detected signal—not just its frequency (pulse rate)—the system can measure the pulse "modulation," specifically the relationship between the main systolic peak and the secondary diastolic hump, to infer the user's hydration level (’072 Patent, col. 16:41-52; Fig. 10).
• Technical Importance: This approach purports to enable a wearable device to estimate hydration, a key physiological metric, without requiring more complex or invasive equipment like a blood pressure cuff (’072 Patent, col. 1:39-44).

Key Claims at a Glance

• The complaint alleges infringement of "one or more claims" and "exemplary claims" identified in an exhibit, but does not specify any claim numbers in the body of the complaint (Compl. ¶11). The referenced exhibit was not filed with the complaint. Independent claim 1 is representative of the invention's method:
• Independent Claim 1: A non-transitory computer readable medium carrying instructions for a method comprising:
  • measuring a physical periodic motion of a peripheral artery with a pulse sensor, each motion including a modulation and a pulse rate, wherein the modulation corresponds to a difference or ratio between systolic peak and diastolic hump;
  • receiving the modulation and pulse rate with a microcontroller and saving them to a buffer memory;
  • determining at least one limit (including modulation, pulse rate, and blood flow limits) from the saved history;
  • writing the limit to a non-transitory computer readable medium;
  • comparing one or more measured instances of modulation, blood flow rate, and pulse rate to the determined limit; and
  • outputting a prompt to a user if the measured instances fall outside the limit.

III. The Accused Instrumentality

Product Identification

The complaint refers to "Exemplary Defendant Products" that are identified in charts within Exhibit 2 (Compl. ¶11, ¶16). As Exhibit 2 was not filed with the complaint, the specific accused products are not identified in the provided documents.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused products' specific functionality or market context. The allegations are limited to general statements that the products "practice the technology claimed by the '072 Patent" (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint incorporates infringement allegations by reference to claim charts in an unattached exhibit (Compl. ¶17). It alleges that Defendant's products "satisfy all elements of the Exemplary '072 Patent Claims" (Compl. ¶16). Without the specific products, asserted claims, or claim charts, a detailed mapping of infringing functionality to claim elements is not possible based on the complaint alone.

No probative visual evidence provided in complaint.

Identified Points of Contention

The lack of detail in the complaint prevents a direct analysis of specific disputes, but the technology itself suggests potential areas of contention.

• Scope Questions: A central question may be whether the accused products "measure a physical periodic motion," as required by the claims, using the magnetic sensing method described in the patent. Many commercially available wearable sensors use optical methods (photoplethysmography or PPG) to detect blood volume changes. A dispute could arise over whether data from an optical sensor constitutes a measurement of "physical periodic motion" in the manner claimed.
• Technical Questions: The analysis of infringement will likely require a detailed technical examination of how the accused products derive pulse wave characteristics. A key question will be whether the accused devices actually measure a "diastolic hump" and calculate a "difference or ratio" as claimed, or if they use other proprietary algorithms to analyze the pulse signal that do not map onto the claim elements.

V. Key Claim Terms for Construction

• The Term: "modulation"
• Context and Importance: This term is central to the invention's asserted point of novelty—analyzing the pulse wave shape, not just its frequency. The definition of "modulation" will be critical for determining whether the accused devices perform the claimed analysis. Practitioners may focus on this term because its construction will likely determine whether the patent can read on technologies beyond the specific magnetic sensor embodiment.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: Claim 1 itself defines the term as corresponding "to a difference or ratio between systolic peak and diastolic hump corresponding to respective expansion of the peripheral artery" (’072 Patent, col. 21:25-29). This functional definition is not explicitly tied to any particular sensing hardware.
• Evidence for a Narrower Interpretation: A defendant may argue that the term should be limited by the embodiments described in the specification, which consistently teach measuring modulation via a magnetometer detecting the movement of a physical magnet responsive to arterial expansion (’072 Patent, col. 6:54-62, Fig. 1). This could support an interpretation that "modulation" requires a signal derived from this specific magnetic sensing mechanism.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in an infringing manner (Compl. ¶14).
• Willful Infringement: The complaint bases its allegation of knowledge of infringement on the service of the complaint itself (Compl. ¶13, ¶15). It does not allege any pre-suit knowledge, which may cabin the willfulness claim to post-filing conduct.

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

1. Technological Equivalence: A primary issue will be whether the sensing technology in the accused products, which is unspecified in the complaint, meets the claim limitations. The case may turn on whether the patent's claims, rooted in a magnetic sensing disclosure, can be asserted against devices that potentially use different methods, such as optical sensors, to obtain pulse data.
2. Claim Scope and Definition: The construction of the term "modulation" will be a central battleground. The key question for the court will be whether the term is defined purely by its functional outcome (a ratio of pulse wave peaks) or if it is implicitly limited to the specific magnetic means for detecting that outcome as detailed in the patent’s specification.
3. Specificity of Allegations: A significant procedural question is how the plaintiff will substantiate its infringement theory. The complaint's reliance on an unattached exhibit for foundational elements—the identity of the accused products, the asserted claims, and the infringement mapping—raises the question of what specific evidence will be presented to support these currently conclusory allegations.