Encelion LLC v. Oura Health Oy

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Encelion LLC (New Mexico)
  • Defendant: Oura Health Oy (Finland)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-01107, E.D. Tex., 11/06/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign corporation and has committed acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s products infringe a patent related to wearable pulse sensors that use magnetic fields to measure arterial movement.
• Technical Context: The technology relates to non-optical methods for pulse sensing in wearable devices, a field critical for health and fitness trackers seeking to improve accuracy and power efficiency.
• Key Procedural History: The complaint does not reference any prior litigation, licensing history, or specific prosecution history events relevant to claim scope.

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"

• Issued: October 18, 2022.

The Invention Explained

• Problem Addressed: The patent describes a need for wearable sensors that can infer a user's state of hydration by correlating heart rate with blood volume changes. It notes that during dehydration, blood viscosity increases, which alters the characteristics of the arterial pulse wave (’072 Patent, col. 1:16-32).
• The Patented Solution: The invention proposes a non-invasive pulse sensor that uses at least one magnet placed adjacent to a user's artery. As the artery expands and contracts with each pulse, the magnet moves, causing a change in its magnetic field. A magnetometer detects these periodic field changes to measure the pulse (’072 Patent, col. 6:54-65; Fig. 1). The system then analyzes the shape of the resulting pulse wave, specifically the ratio between the main systolic peak and a smaller "diastolic hump," to derive a "modulation" value that can be correlated with hydration levels (’072 Patent, col. 16:40-47).
• Technical Importance: This magnetic-based approach offers a potential alternative to common photoplethysmography (PPG) sensors, which use light to measure blood flow and can be affected by skin tone, tattoos, and motion artifacts.

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims" of the ’072 Patent, including at least the "Exemplary '072 Patent Claims" identified in an attached exhibit (Compl. ¶11). Independent claim 1 is representative.
• Independent Claim 1: A method performed by a portable device, with steps comprising:
  • measuring a physical periodic motion of a peripheral artery with a pulse sensor;
  • each measurement including a "modulation" and a pulse rate, where 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 memory;
  • determining at least one limit from the modulation and pulse rate history;
  • writing the limit to a non-transitory computer readable medium;
  • comparing measured instances of modulation, blood flow rate, and pulse rate to the limit; and
  • outputting a prompt if the measured instances fall outside the limit.
• The complaint does not explicitly reserve the right to assert dependent claims, but refers generally to "one or more claims" (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint accuses "at least the Defendant products identified in the charts incorporated into this Count" (Compl. ¶11). The products are referred to as the "Exemplary Defendant Products" but are not explicitly named in the body of the complaint provided (Compl. ¶11, ¶16).

Functionality and Market Context

The complaint does not describe the specific functionality or market context of the accused products. It alleges that the products "practice the technology claimed by the ’072 Patent" (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint incorporates by reference "Exhibit 2," which it states includes "charts comparing the Exemplary '072 Patent Claims to the Exemplary Defendant Products" (Compl. ¶16-17). This exhibit was not provided. The complaint's narrative infringement theory alleges that the "Exemplary Defendant Products practice the technology claimed" and "satisfy all elements of the Exemplary '072 Patent Claims" either literally or under the doctrine of equivalents (Compl. ¶11, ¶16). No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: The analysis may turn on whether the accused products' sensing mechanism, if not explicitly magnetic, can be considered equivalent to the claimed "pulse sensor" that measures "physical periodic motion."
• Technical Questions: A central question will be whether the accused products calculate a "modulation" value as specifically defined in the claim: "a difference or ratio between systolic peak and diastolic hump corresponding to respective expansion of the peripheral artery" (’072 Patent, col. 21:24-28). The complaint does not provide evidence detailing how the accused products analyze pulse waveforms.

V. Key Claim Terms for Construction

The Term: "modulation"

Context and Importance

This term is central to the invention's purported novelty and the infringement allegation. The patent links this specific calculation to the estimation of hydration status. The infringement case may depend entirely on whether the accused products perform a calculation that meets this definition.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The claim language uses the word "corresponds to," which may suggest that an indirect or related calculation could suffice, rather than a direct measurement of the peak-to-hump ratio. The specification also refers to modulation more generally as representing the "systolic peak to diastolic hump arterial expansion ratio" (col. 1:59-62), which could be argued to encompass various ways of quantifying this relationship.
• Evidence for a Narrower Interpretation: Claim 1 explicitly defines modulation as corresponding to "a difference or ratio between systolic peak and diastolic hump" (’072 Patent, col. 21:24-26). The patent specification repeatedly emphasizes this specific feature, describing how "the ratio of systolic maximum 1004 to diastolic hump maximum 1006 is covariant with hydration" and showing these distinct features in Figure 10 (’072 Patent, col. 16:40-43). This focus on a specific waveform analysis could support a narrower construction limited to direct calculations of this ratio or difference.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials inducing end users...to use its products in the customary and intended manner that infringes the '072 Patent" (Compl. ¶14). The allegation states knowledge arises "at least since being served by this Complaint" (Compl. ¶15).

Willful Infringement

The complaint does not contain a separate count for willful infringement but lays the groundwork for it. It alleges that the "service of this Complaint, in conjunction with the attached claim charts...constitutes actual knowledge of infringement" and that Defendant's continued activities thereafter are undertaken despite this knowledge (Compl. ¶13-14). This frames a theory of post-filing willfulness.

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

The resolution of this dispute may hinge on the following open questions:

• A core issue will be one of definitional scope: How will the court construe the term "modulation"? Can it be interpreted broadly to cover any advanced pulse wave analysis performed by the accused products, or will it be limited to the specific "systolic peak to diastolic hump" ratio described in the patent?
• A key evidentiary question will be one of technical proof: What evidence can Plaintiff provide to demonstrate that the accused products, on a technical level, actually perform the specific measurement, calculation, and user-prompting steps required by the asserted claims?
• A third question concerns indirect infringement: Given that the allegations of knowledge for inducement are tied to the filing of the complaint itself, the viability of this claim will depend on whether Plaintiff can later establish pre-suit knowledge or if the claim is limited to post-filing conduct.