Encelion LLC v. Suunto Oy

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Encelion LLC (New Mexico)
  • Defendant: Suunto Oy (Finland)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-01108, E.D. Tex., 11/06/2025
• Venue Allegations: Plaintiff alleges venue is proper because the defendant is a foreign corporation.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to a wearable pulse sensor that uses magnetic fields to measure pulse characteristics for purposes including hydration monitoring.
• Technical Context: The technology at issue falls within the domain of wearable health and fitness monitors, a market where biometric sensing accuracy and power efficiency are significant competitive factors.
• Key Procedural History: The complaint does not reference any prior litigation, licensing history, or administrative proceedings involving 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 a need to infer physiological states, such as hydration, by analyzing not just the rate of a person's pulse, but also its qualitative characteristics or shape (’072 Patent, col. 1:11-15). The patent notes that changes in blood viscosity due to dehydration affect the shape of the pulse wave, specifically the relationship between the main systolic peak and the secondary diastolic peak (’072 Patent, col. 1:35-46).
• The Patented Solution: The invention proposes a non-optical sensor that uses at least one magnet placed near an artery, which moves or tilts in response to the physical pulsation of blood (’072 Patent, Abstract; Fig. 1). A magnetometer measures the resulting periodic changes in the magnetic field to determine not only the pulse rate but also the "modulation"—the shape of the pulse wave, including the systolic peak and a subsequent "diastolic hump" (’072 Patent, col. 7:1-5; col. 16:30-41). This data is then used to infer a user's hydration status and prompt them if dehydration is detected (’072 Patent, Abstract; col. 2:43-49).
• Technical Importance: The use of a magnetic sensor offers an alternative to the more common photoplethysmography (PPG) optical sensors, potentially providing advantages related to power consumption and rejection of spurious measurements from user motion (’072 Patent, col. 9:20-29; col. 4:25-29).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims" of the ’072 Patent without specifying which claims are asserted (Compl. ¶11). The complaint references an external claim chart exhibit, which was not provided with the pleading (Compl. ¶16).
• Independent claim 1, a representative system claim embodied on a non-transitory medium, includes these essential elements:
  • Measuring a physical periodic motion of a peripheral artery with a pulse sensor, where each motion includes a modulation and a pulse rate.
  • The modulation corresponds to a difference or ratio between a systolic peak and a diastolic hump.
  • Receiving and saving the modulation and pulse rate data to a buffer memory as a history.
  • Determining at least one limit (for modulation, pulse rate, and/or blood flow) from the history.
  • Writing the limit to a non-transitory computer readable medium.
  • Comparing measured instances of modulation, blood flow, and pulse rate to the limit.
  • Outputting a prompt to a user if the measured instances fall outside the limit.

III. The Accused Instrumentality

Product Identification

The complaint accuses "Exemplary Defendant Products" which it states are identified in charts incorporated by reference as Exhibit 2 (Compl. ¶11, ¶16).

Functionality and Market Context

The complaint does not name any specific accused products or describe their functionality. It states that Exhibit 2, which was not filed with the complaint, contains charts comparing the patent claims to the accused products (Compl. ¶16). The complaint therefore does not provide sufficient detail for analysis of the accused instrumentality.

IV. Analysis of Infringement Allegations

The complaint’s infringement allegations are asserted through "charts comparing the Exemplary '072 Patent Claims to the Exemplary Defendant Products," which are contained in an Exhibit 2 that was incorporated by reference but not provided with the pleading (Compl. ¶16-17). The complaint alleges that these charts demonstrate that the accused products "practice the technology claimed by the '072 Patent" and "satisfy all elements of the Exemplary '072 Patent Claims" (Compl. ¶16). Without access to the referenced charts, a detailed element-by-element analysis is not possible.

No probative visual evidence provided in complaint.

• Identified Points of Contention: Based on the patent’s claims and the general nature of the dispute, the infringement analysis may raise several technical and legal questions for the court:
  • Scope Questions: A central question may be whether the accused products, which likely use common optical PPG sensors, perform a measurement that can be considered a "physical periodic motion" as required by the claims, which are rooted in a magnetic sensing embodiment (’072 Patent, col. 7:40-43).
  • Technical Questions: What evidence does the complaint provide that the accused products measure a "diastolic hump" and calculate a "difference or ratio" between it and a "systolic peak" to determine "modulation" for the purpose of hydration monitoring, as specifically required by claim 1 of the ’072 Patent?

V. Key Claim Terms for Construction

• The Term: "modulation"
• Context and Importance: This term is central to the invention's contribution. Claim 1 explicitly defines it as corresponding to "a difference or ratio between systolic peak and diastolic hump corresponding to respective expansion of the peripheral artery" (’072 Patent, col. 21:24-28). The patent links this specific measurement to inferring hydration (’072 Patent, col. 16:30-46). Whether the accused products perform this specific calculation, or a more generic pulse wave analysis, will be a critical infringement question.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: Parties seeking a broader reading may argue that "corresponds to" allows for measurements that are functionally related to the peak/hump difference, even if not a direct calculation.
  • Evidence for a Narrower Interpretation: The explicit definition within claim 1 provides strong evidence for a narrow construction. The specification's detailed description and illustration of the systolic maximum (1004) and diastolic hump (1006) in Figure 10 further anchors the term to this specific feature of a pulse waveform (’072 Patent, Fig. 10; col. 16:37-41).

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement, stating on information and belief 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).
• Willful Infringement: The complaint does not use the term "willful." It pleads "Actual Knowledge of Infringement" will be established upon "The service of this Complaint, in conjunction with the attached claim charts" (Compl. ¶13). This allegation appears aimed at establishing a basis for potential post-filing willful infringement.

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

1. A Foundational Evidentiary Question: The primary issue is the lack of specificity in the complaint itself. A threshold question will be identifying precisely which of Defendant’s products are accused and determining their method of operation, details the complaint defers to an unprovided exhibit.
2. A Question of Technical Equivalence: Does the method of pulse analysis in the accused products, which likely relies on optical sensing, meet the specific claim limitations of measuring a "physical periodic motion" and calculating "modulation" based on a systolic peak-to-diastolic hump relationship for hydration assessment?
3. A Question of Definitional Scope: The case will likely hinge on the construction of "modulation." The central legal question will be whether this term is limited to the specific ratio/difference calculation described in the patent for hydration analysis, or if it can be construed more broadly to cover other forms of pulse wave analysis common in the wearable device industry.