2:25-cv-01126
Ouraring Inc v. Zepp Health Corp
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Ouraring Inc. (Delaware)
- Defendant: Zepp Health Corporation (Cayman Islands)
- Plaintiff’s Counsel: Patton, Tidwell, & Schroeder, LLP; Mayer Brown LLP
- Case Identification: 2:25-cv-01126, E.D. Tex., 11/17/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is not a resident of the United States and may be sued in any judicial district. The complaint also alleges that Defendant conducts regular business and makes sales within the Eastern District of Texas.
- Core Dispute: Plaintiff alleges that Defendant’s Helio Ring smart ring and associated Zepp Amazfit App infringe eight U.S. patents related to the design, construction, and manufacturing methods of wearable computing devices.
- Technical Context: The technology at issue is in the wearable health-tracking market, specifically concerning finger-worn "smart rings" that integrate various sensors to monitor a user's biometric data.
- Key Procedural History: The complaint highlights a prior International Trade Commission (ITC) investigation where Plaintiff asserted U.S. Patent No. 11,868,178 against competitors Ultrahuman and RingConn. That investigation reportedly resulted in an initial determination of infringement and validity, followed by final exclusion and cease-and-desist orders, which became effective in October 2025. Plaintiff leverages this prior action to assert Defendant’s pre-suit knowledge of at least the ’178 Patent.
Case Timeline
| Date | Event |
|---|---|
| 2013-11-29 | Earliest Priority Date for all Patents-in-Suit ('178, ’244, ’159, ’227, ’160, ’889, ’909, ’759 Patents) |
| 2015-01-01 | Oura Ring Gen. 1 Launch |
| 2018-01-01 | Oura Ring Gen. 2 Launch |
| 2021-01-01 | Oura Ring Gen. 3 Launch |
| 2024-01-01 | Oura Ring Gen. 4 Launch |
| 2024-01-09 | U.S. Patent No. 11,868,178 Issued |
| 2024-03-01 | Plaintiff files ITC complaint asserting '178 Patent |
| 2024-04-12 | ITC institutes investigation regarding '178 Patent |
| 2025-02-11 | U.S. Patent No. 12,222,759 Issued |
| 2025-04-01 | ITC issues initial determination finding infringement of '178 Patent |
| 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 |
| 2025-08-01 | ITC issues final orders in investigation involving '178 Patent |
| 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 |
| 2025-10-21 | ITC exclusion and cease-and-desist orders become effective |
| 2025-11-17 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,868,178
- Patent Identification: U.S. Patent No. 11,868,178, “Wearable Computing Device,” issued January 9, 2024 (the “’178 Patent”).
- The Invention Explained:
- Problem Addressed: The patent background describes conventional wearable electronics as often being "bulky and can be intrusive or interfere with a person's daily life," making them uncomfortable for extended wear (’178 Patent, col. 1:41-46).
- The Patented Solution: The invention is a finger-worn computing device in a ring form factor designed for comfort during extended use (’178 Patent, col. 1:50-55). It achieves this compact design by arranging its main components—specifically a battery and a printed circuit board (PCB)—within a cavity formed between an inner and an outer housing component. The patent claims a specific spatial arrangement where the battery occupies a "first portion" of this cavity and the PCB extends through a "second portion" different from the first (’178 Patent, Claim 1). An exemplary assembly is shown in Figure 4 of the patent, which illustrates the housing (412), formed flex circuit (415), and battery (480) components (’178 Patent, Fig. 4; Compl. ¶32).
- Technical Importance: This architectural approach allows for the integration of complex electronics and a power source into a small, aesthetically pleasing ring, addressing the market's need for less intrusive and more comfortable wearable health monitors (Compl. ¶1).
- Key Claims at a Glance:
- The complaint asserts at least independent claim 1 (Compl. ¶33).
- The essential elements of independent claim 1 include:
- A finger-worn wearable ring device comprising an external housing component and an internal housing component that together form a cavity.
- A battery positioned within a "first portion" of the cavity.
- A printed circuit board extending through a "second portion of the cavity different from the first portion."
- One or more sensors coupled to the PCB and battery, configured to acquire data from the user through the internal housing.
- The complaint reserves the right to pursue additional claims (Compl. ¶34).
U.S. Patent No. 12,353,244
- Patent Identification: U.S. Patent No. 12,353,244, “Wearable Computing Device,” issued July 8, 2025 (the “’244 Patent”).
- The Invention Explained:
- Problem Addressed: The complaint suggests the technology is directed to packing a specific suite of physiological sensors into a compact, finger-worn device with specific, wearable dimensions (Compl. ¶¶49-50). The challenge is to integrate these components without compromising the device's form factor or comfort.
- The Patented Solution: The patent discloses a wearable ring device defined by both its components and its physical dimensions. The claimed device includes an external housing, "an internal potting," a curved battery, a PCB, and a sensor suite comprising an accelerometer, a temperature sensor, a "first light emitting diode (LED)," a "second LED," and "one or more light sensors" (’244 Patent, Claim 1, as described in Compl. ¶50). A key aspect of the claimed invention is the specific dimensional constraints: an interior diameter between 12-24 mm, an exterior diameter between 18-30 mm, a width between 3-8 mm, and a thickness between 1.5-3 mm (Compl. ¶50).
- Technical Importance: By claiming both a specific sensor suite and precise dimensional ranges, the invention defines a complete product architecture for a functional and commercially viable smart ring capable of monitoring metrics like heart rate and blood oxygenation (Compl. ¶49).
- Key Claims at a Glance:
- The complaint asserts at least independent claim 1 (Compl. ¶51).
- The essential elements of independent claim 1 include:
- A wearable ring device with an external housing and "an internal potting."
- A component set including a curved battery, a PCB, an accelerometer, and a temperature sensor.
- An optical sensor suite including a first LED, a second LED, and one or more light sensors.
- Specific dimensional limitations for the housing's interior/exterior diameter, width, and thickness.
- The complaint reserves the right to pursue additional claims (Compl. ¶52).
Multi-Patent Capsules
Patent Identification: U.S. Patent No. 12,346,159, "Wearable Computing Device," issued July 1, 2025 (the “’159 Patent”).
Technology Synopsis: This patent is directed to a wearable ring device for tracking physical movement, skin temperature, and blood oxygenation. The claims cover a specific combination of structural components (external and internal housing, curved battery, PCB) and a sensor suite (accelerometer, temperature sensor, two LEDs, light sensors) within defined dimensional ranges. (Compl. ¶¶67-68).
Asserted Claims: At least independent claim 1 (Compl. ¶69).
Accused Features: The complaint alleges the Helio Ring’s structure, components (including its housing, curved battery, accelerometer, temperature sensor, and optical sensors), and physical dimensions infringe the ’159 Patent (Compl. ¶71).
Patent Identification: U.S. Patent No. 12,393,227, "Wearable Computing Device," issued August 19, 2025 (the “’227 Patent”).
Technology Synopsis: This patent claims a method of manufacturing a wearable ring device. The claimed method comprises constructing an external housing, inserting components including a curved battery and PCB, and applying an "internal potting" that partially fills the internal space and is subsequently polymerized to form an interior surface of the ring. (Compl. ¶86). The patent also claims specific dimensional ranges for the final product.
Asserted Claims: At least independent claim 1 (Compl. ¶87).
Accused Features: The complaint alleges that Zepp Health infringes by making, using, importing, or selling the Helio Ring, which is purportedly manufactured according to the claimed method (Compl. ¶¶87-89).
Patent Identification: U.S. Patent No. 12,346,160, "Wearable Computing Device," issued July 1, 2025 (the “’160 Patent”).
Technology Synopsis: This patent is directed to a wearable ring device with an external housing made of a "metallic material." It claims a structure including this metallic housing, an internal potting, a curved battery, a PCB, and a suite of sensors (accelerometer, temperature sensor, two LEDs, light sensors) within specific dimensional constraints. (Compl. ¶103).
Asserted Claims: At least independent claim 1 (Compl. ¶104).
Accused Features: The Helio Ring is accused of infringing based on its titanium alloy external housing, its internal resin potting, its component set, and its dimensions (Compl. ¶¶106, 54).
Patent Identification: U.S. Patent No. 12,422,889, "Wearable Computing Device," issued September 23, 2025 (the “’889 Patent”).
Technology Synopsis: This patent describes a wearable ring with a "metallic material" external housing that includes a first and second flange defining an internal space. The claims cover the arrangement of a curved battery and PCB within this flanged housing, along with an internal potting that partially surrounds the components and forms an interior surface that contacts the user's finger. (Compl. ¶121).
Asserted Claims: At least independent claim 1 (Compl. ¶122).
Accused Features: The Helio Ring is alleged to embody the claimed structure, including its metallic housing, internal potting, and arrangement of internal components (Compl. ¶124).
Patent Identification: U.S. Patent No. 12,429,909, "Wearable Computing Device," issued September 30, 2025 (the “’909 Patent”).
Technology Synopsis: This patent claims a method of manufacturing a wearable ring. The method involves constructing an external housing with a first and second flange, inserting a curved battery and PCB, and applying an internal potting that at least partially fills the housing and covers the components. The potting forms an interior surface configured to contact the user's finger. (Compl. ¶139).
Asserted Claims: At least independent claim 1 (Compl. ¶140).
Accused Features: The complaint alleges the Helio Ring is manufactured using the claimed method, thereby infringing the ’909 Patent (Compl. ¶¶141-142).
Patent Identification: U.S. Patent No. 12,222,759, "Wearable Computing Device," issued February 11, 2025 (the “’759 Patent”).
Technology Synopsis: This patent is directed to a wearable ring where at least a portion of the housing (interior surface, exterior surface, or both) is made of a "metallic material." The claims cover a structure with a curved battery and PCB disposed within this housing, a plurality of sensors (light-emitting and light-receiving components), and a communication module. (Compl. ¶156).
Asserted Claims: At least independent claim 17 (Compl. ¶157).
Accused Features: The Helio Ring is accused of infringing based on its metallic housing, its internal component layout, and its sensor and communication modules (Compl. ¶159).
III. The Accused Instrumentality
- Product Identification: The accused instrumentality consists of the "Helio Ring" smart ring and the accompanying "Zepp Amazfit App" (collectively, the "Accused Product") (Compl. ¶34).
- Functionality and Market Context: The Helio Ring is a finger-worn electronic device designed to track physiological data such as sleep quality, heart rate, blood-oxygen saturation, and stress levels (Compl. ¶¶8, 12-13). Data is synchronized with the Zepp Amazfit App for user review and analysis (Compl. p. 12). The complaint alleges the Helio Ring is an "imitation" of Plaintiff's Oura Ring in its appearance and function, utilizing similar sensors, materials (titanium alloy outer ring, resin inner ring), and a curved battery architecture (Compl. ¶9). Marketing materials cited in the complaint promote the Helio Ring for its ability to provide "performance, recovery, and insights" (Compl. p. 12) and a "comprehensive recovery" score based on sleep data (Compl. p. 14). A screenshot from Defendant's website shows the internal components of the Helio Ring arranged circumferentially inside the housing (Compl. p. 12).
IV. Analysis of Infringement Allegations
11,868,178 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a finger-worn wearable ring device, comprising: | The Accused Product is a finger-worn wearable ring device. | ¶35 | col. 45:1 |
| an external housing component...; an internal housing component... coupled with the external housing component | The Helio Ring has an outer ring of "Titanium alloy" (external housing) and an inner ring of "Resin" (internal housing). | ¶35; p. 13 | col. 45:3-9 |
| a battery positioned within a cavity formed between the internal housing component and the external housing component... wherein the battery extends through at least a first portion of the cavity... | The Helio Ring contains a battery, including a "curved battery component," positioned within the cavity between the outer and inner rings. | ¶9, 35; p. 13 | col. 45:10-15 |
| a printed circuit board disposed between the internal housing component and the external housing component, wherein the printed circuit board extends through at least a second portion of the cavity of the finger-worn wearable ring device different from the first portion | The Helio Ring contains a printed circuit board with electronic components arranged circumferentially within the ring's housing. | ¶35; p. 12 | col. 45:16-20 |
| 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 Helio Ring includes sensors like a PPG heart rate sensor and temperature sensor that acquire data from the user through the inner resin ring. | ¶35; p. 13 | col. 45:21-25 |
- Identified Points of Contention:
- Scope Questions: A central dispute may concern the interpretation of "a first portion of the cavity" and "a second portion of the cavity... different from the first portion." The question for the court will be whether this language requires two physically distinct and non-overlapping regions for the battery and PCB, or if it can read on a more integrated or overlapping arrangement of components within the accused device's circular cavity.
- Technical Questions: A key factual question will be what evidence demonstrates the precise placement of the battery and PCB within the Helio Ring. The infringement analysis will depend on technical evidence from product teardowns showing whether these components occupy distinct or different portions of the internal cavity as required by the claim.
12,353,244 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a wearable ring device comprising: an external housing; an internal potting; | The Helio Ring has an "Outer ring: Titanium alloy" (external housing) and an "Inner ring: Resin" which the complaint alleges functions as the internal potting. | ¶53; p. 24 | col. 45:5-6 |
| a curved battery; a printed circuit board; | The Helio Ring is alleged to possess a curved battery and a printed circuit board. | ¶53; p. 24 | col. 45:8-9 |
| an accelerometer; a temperature sensor; | The Helio Ring's "Tech Specs" list a "3-Axis Acceleration Sensor" and a "Temperature sensor." | ¶53; p. 24 | col. 45:11-12 |
| a first light emitting diode (LED); a second LED; and one or more light sensors | The Helio Ring's "BioTracker™ PPG heart rate sensor" is described as having "1 dual-color LED + 2PD," which are alleged to meet these limitations. | ¶53; p. 24 | col. 45:13-15 |
| 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 Helio Ring is advertised with a width of 8mm, a thickness of 2.6mm, and exterior diameters such as 24mm and 27.3mm, all falling within the claimed ranges. | ¶50; p. 12, 24 | col. 45:16-20 |
- Identified Points of Contention:
- Scope Questions: The definition of "internal potting" may be a central issue. The question will be whether the Helio Ring's pre-molded "Resin" inner ring constitutes "potting," a term that may imply a material applied in a flowable state to encapsulate components, rather than a solid structural part.
- Technical Questions: An evidentiary question may arise regarding the "first LED" and "second LED" elements. The court may need to determine if the "1 dual-color LED" in the accused product's specification technically satisfies the requirement for two distinct LEDs as claimed.
V. Key Claim Terms for Construction
'178 Patent
- The Term: "a first portion of the cavity" and "a second portion of the cavity ... different from the first portion"
- Context and Importance: This language defines the fundamental architecture of the device in claim 1 by requiring a specific spatial separation between the battery and the PCB. The infringement determination for the ’178 Patent may hinge on whether the Helio Ring’s internal layout meets this structural limitation. Practitioners may focus on this term because it appears to be a key point of novelty intended to define how to successfully package electronics into a ring form factor.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification does not appear to provide a precise geometric definition of "portion" or "different from," which may support an argument that any non-identical regions where the battery and PCB are primarily located meet the limitation, even with some overlap (’178 Patent, col. 45:10-20).
- Evidence for a Narrower Interpretation: The use of distinct ordinal numbers ("first" and "second") suggests the patentee intended to claim two discrete, non-overlapping, or minimally overlapping regions. The patent's Figure 4, referenced in the complaint, depicts the battery (480) and flex circuit (415) as separate components assembled into the housing, which may support a narrower reading requiring physically distinct placement (’178 Patent, Fig. 4).
'244 Patent
- The Term: "an internal potting"
- Context and Importance: This term is a key structural element of claim 1 of the ’244 Patent (and several other asserted patents). The infringement analysis will likely turn on whether the accused Helio Ring's "Inner ring: Resin" component is properly construed as "potting."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification describes potting material as forming an "interior wall of the smart ring" and encapsulating components (’178 Patent, Abstract). Parties may argue that any material, including a pre-molded resin piece, that serves this encapsulating and sealing function meets the definition of "potting."
- Evidence for a Narrower Interpretation: The term "potting" in electronics manufacturing often refers to the process of filling a complete enclosure with a liquid compound that then solidifies. Figures 14D and 14E of the related ’227 method patent, for example, show the "application of potting" material into the internal space, suggesting a process-based limitation that a pre-formed solid component might not meet (Compl. p. 41).
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement for all asserted patents. The inducement allegations are based on Defendant's provision of user manuals, websites, and marketing materials that allegedly instruct customers on how to use the Helio Ring in an infringing manner (Compl. ¶¶38-40, 56-58). The contributory infringement allegations assert that the Helio Ring contains components that are a material part of the patented inventions and are not staple articles of commerce suitable for substantial non-infringing use (Compl. ¶¶41-42, 59-60).
- Willful Infringement: Willfulness is alleged for all asserted patents. For all patents, the claim is based at least on post-suit knowledge from the filing of the complaint (Compl. ¶¶43, 61). For the ’178 Patent, the complaint specifically alleges pre-suit knowledge stemming from a "widely publicized" prior ITC investigation involving the ’178 Patent, which resulted in exclusion orders against other smart ring competitors (Compl. ¶¶13, 44).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of manufacturing process versus product structure: For the method patents (’227 and ’909), can Plaintiff prove that the Helio Ring is manufactured by "applying an internal potting" that is then "polymerized," or will Defendant show it uses a distinct assembly process? For the apparatus patents, this question transforms into one of definitional scope: can the term "internal potting," rooted in a process of application, be construed to cover the accused ring's pre-molded "Resin" inner component?
- A second central issue will be one of architectural scope: For the ’178 Patent, does the claim language requiring a battery in a "first portion" and a PCB in a "second portion... different from the first" demand strict spatial separation, or can it read on the potentially more integrated design of the Helio Ring's internal components?
- A key question for damages will be the impact of pre-suit knowledge: While willfulness is alleged across all patents based on the filing of the suit, the specific allegation that Defendant knew of the ’178 Patent from the prior, public ITC litigation creates a significant question for the court regarding the potential for enhanced damages on that patent.