DCT

2:25-cv-01181

Samsung Electronics Co Ltd v. Oura Health Oy

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-1181, E.D. Tex., 12/01/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign corporation that may be sued in any judicial district. The complaint further alleges that Defendant has committed acts of infringement in the district, purposefully sold products to consumers in the district, and availed itself of the jurisdiction by filing its own lawsuits in the district and announcing plans for a Texas manufacturing facility.
  • Core Dispute: Plaintiff alleges that Defendant’s Oura Ring smart ring products and associated software infringe six U.S. patents related to wearable health and fitness tracking technology.
  • Technical Context: The technology at issue involves wearable smart rings designed to monitor biometric data, track fitness activities, and provide personalized health insights, a significant and competitive sector of the consumer electronics market.
  • Key Procedural History: The complaint notes that Defendant has previously filed its own patent litigation in the Eastern District of Texas. For U.S. Patent No. 7,662,065, the complaint highlights a prosecution history where the applicant allegedly overcame a § 101 patent-eligibility rejection by amending claims to be more concrete, a point raised to preemptively defend the patent's validity.

Case Timeline

Date Event
2006-09-01 '065 Patent Priority Date
2007-11-28 '065 Patent Non-Final Rejection mentioned in complaint
2008-02-28 '065 Patent Amendment mentioned in complaint
2008-05-30 '065 Patent Final Rejection mentioned in complaint
2009-10-13 '065 Patent Notice of Allowance mentioned in complaint
2009-11-09 '973 Patent Priority Date
2010-02-16 '065 Patent Issue Date
2014-06-18 '973 Patent Non-Final Rejection mentioned in complaint
2015-02-26 '973 Patent Notice of Allowance mentioned in complaint
2015-02-27 '655 Patent Priority Date
2015-04-14 '973 Patent Issue Date
2018-04-05 '849 Patent Priority Date
2021-01-06 '152 Patent Priority Date
2023-09-01 Oura's prior lawsuit filed in E.D. Tex. mentioned in complaint
2023-09-21 '672 Patent Priority Date
2025-03-25 '672 Patent Issue Date
2025-04-22 '849 Patent Issue Date
2025-06-10 '655 Patent Issue Date
2025-08-12 '152 Patent Issue Date
2025-12-01 Complaint Filing Date

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

U.S. Patent No. 7,662,065 - Method and apparatus to provide daily goals in accordance with historical data, issued February 16, 2010

The Invention Explained

  • Problem Addressed: The patent addresses perceived deficiencies in prior art exercise systems that were limited to simple activity logging or setting static, non-personalized goals (Compl. ¶33).
  • The Patented Solution: The invention is a computer-implemented system that first identifies a "daily raw target exercise level" for a user. It then applies a "goal setting algorithm," selected from a plurality of such algorithms, to adjust that target based on a "motivational analysis" of the user. The system then displays the adjusted target to the user. (Compl. ¶33; '065 Patent, claim 1). The system is described as using device integration (e.g., receiving data from a pedometer) and user-specific thresholds to implement these adaptive goals (Compl. ¶35; '065 Patent, col. 2:4-6).
  • Technical Importance: The claimed invention represents a shift from one-size-fits-all fitness targets to personalized, adaptive goal-setting systems that respond to user behavior and context (Compl. ¶33).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶38).
  • Essential elements of Claim 1 include:
    • identifying with a computer a daily raw target exercise level for a user;
    • applying a goal setting algorithm with a computer to adjust the daily raw target exercise level, where the adjustment is made in accordance with a motivational analysis of the user;
    • displaying an adjusted target exercise level to the user; and
    • utilizing at least one of a plurality of goal setting algorithms that adjust the daily raw target exercise level.

U.S. Patent No. 9,008,973 - Wearable sensor system with gesture recognition for measuring physical performance, issued April 14, 2015

The Invention Explained

  • Problem Addressed: The patent's background describes existing exercise tracking technology as being confined to specialized devices for activities like running, or to large, "sectorized" machines in gyms, which were often cumbersome. Tracking free-form exercise, such as with free weights, typically required sophisticated and expensive laboratory equipment. ('973 Patent, col. 1:15-56; Compl. ¶47).
  • The Patented Solution: The invention proposes using a body-mounted sensor, specifically a finger-mounted ring containing an accelerometer, that communicates with an information processor. The system works by first recognizing a "start gesture," then tracking the sensor's movement as the user performs a physical exercise, and finally calculating motion parameters from that tracked movement. ('973 Patent, claim 14; Compl. ¶48).
  • Technical Importance: This approach provided a user-friendly and simplified method for tracking a broader range of physical activities, using gestures to demarcate the start and stop of an exercise set without relying on multiple sensors or manual inputs on a separate device (Compl. ¶49).

Key Claims at a Glance

  • The complaint asserts at least independent claim 14 (Compl. ¶50).
  • Essential elements of Claim 14 include:
    • communicating the movement of a body-mounted sensor including an accelerometer to an information processor;
    • recognizing at least one start gesture that involves movement of the accelerometer;
    • after recognizing the start gesture, tracking movement of the sensor while a user performs physical exercise with exercise equipment; and
    • calculating motion parameters of the physical exercise from the tracked movement.

U.S. Patent No. 12,260,672 - Wearable electronic device for obtaining biometric information, issued March 25, 2025

  • Technology Synopsis: The patent is directed to a ring-type wearable device for obtaining biometric information. The claimed solution involves a specific physical arrangement of a light source and two sensors at different distances from the source to obtain information, such as oxygen saturation, based on light received by the sensors via the user's finger. (Compl. ¶¶ 59-60; '672 Patent, Abstract).
  • Asserted Claims: At least independent claim 1 (Compl. ¶62).
  • Accused Features: The complaint alleges that the Oura Ring products use a combination of light sources and sensors to obtain biometric data in a manner that infringes the '672 Patent (Compl. ¶62).

U.S. Patent No. 12,279,849 - Method for performing wireless communication by using biosensor and electronic device therefor, issued April 22, 2025

  • Technology Synopsis: This patent discloses a system comprising a wearable device and a wireless charger. The invention covers a method where the wearable device, while positioned on the charger, uses its light emitting unit (part of its biosensor) to transmit infrared (IR) signals containing information, such as charging status or notifications, to the wireless charger. (Compl. ¶¶ 71-72; '849 Patent, claim 1).
  • Asserted Claims: At least independent claim 1 (Compl. ¶74).
  • Accused Features: The complaint alleges that the Oura Ring and its accompanying wireless charger infringe by transmitting IR signals from the ring to the charger while the ring is charging (Compl. ¶74).

U.S. Patent No. 12,324,655 - Method for measuring biological signal and wearable electronic device for the same, issued June 10, 2025

  • Technology Synopsis: The patent addresses challenges in measuring resting heart rate, such as inconvenience and battery drain from continuous measurement. The invention provides a method for a wearable device to identify a resting pulse rate by measuring biological signals only when the device's movement is below a predetermined threshold, and disregarding signals when movement is greater than the threshold. (Compl. ¶¶ 83-84; '655 Patent, claim 7).
  • Asserted Claims: At least independent claim 7 (Compl. ¶86).
  • Accused Features: The Oura Ring products are accused of infringing by using movement detection to determine when a user is in a resting state in order to measure resting pulse rate (Compl. ¶86).

U.S. Patent No. 12,383,152 - Electronic device including multiple optical sensors and method for controlling the same, issued August 12, 2025

  • Technology Synopsis: The patent aims to improve conventional ring-type devices by enabling them to discriminate between different user states. The invention uses a motion sensor to determine if a user is in an "exercise state or sleep state" and then selectively drives a different number of light emitters based on that identified state, which may conserve power and improve measurement reliability. (Compl. ¶¶ 94, 96; '152 Patent, claim 1).
  • Asserted Claims: At least independent claim 1 (Compl. ¶97).
  • Accused Features: The Oura Ring products are alleged to infringe by utilizing a motion sensor to determine the user's state and selectively activating light emitters based on that determination (Compl. ¶97).

III. The Accused Instrumentality

Product Identification

  • The "Accused Products" are identified as the Oura Ring Gen 2, Gen 3, and Gen 4 series of smart rings, as well as the accompanying Oura App software that runs on smartphones and tablets (Compl. ¶¶ 6, 28).

Functionality and Market Context

  • The complaint describes the Accused Products as smart ring systems that compete directly with Samsung's own wearable products, including its Galaxy Ring (Compl. ¶¶ 6, 8). The Oura Ring is alleged to be a health and fitness tracking device that monitors biometric data to provide users with health insights (Compl. ¶8). The system consists of the physical ring worn by the user and a software application for data processing and display (Compl. ¶30).

IV. Analysis of Infringement Allegations

The complaint references claim-chart exhibits that are not provided; therefore, the narrative infringement theories are summarized below in prose.

'065 Patent Infringement Allegations

  • The complaint alleges that the Oura Ring system infringes at least claim 1 of the '065 Patent (Compl. ¶38). The infringement theory appears to be that the Oura App, in conjunction with the Oura Ring, performs the claimed method by setting daily activity goals for the user (the "daily raw target"), adjusting those goals based on the user's historical activity, sleep, and other contextual data (the "motivational analysis" using "goal setting algorithms"), and displaying the resulting adjusted goals to the user within the app (the "displaying" step).

'973 Patent Infringement Allegations

  • The complaint alleges that the Oura Ring system infringes at least claim 14 of the '973 Patent (Compl. ¶50). The infringement theory appears to be that the Oura Ring, as a "body-mounted sensor including an accelerometer," communicates its movement to a smartphone, which acts as the "information processor" (Compl. ¶48). The system is alleged to recognize a "start gesture" (e.g., by automatically detecting the start of a workout), subsequently track the user's movements during the exercise, and then calculate "motion parameters" (e.g., activity type, duration, intensity) from the tracked data.

Identified Points of Contention

  • Scope Questions: For the '065 Patent, a central question may be whether the Oura system's method of adjusting goals qualifies as "utilizing at least one of a plurality of goal setting algorithms" based on a "motivational analysis," or if it constitutes a single, integrated algorithm outside the claim's scope. For the '973 Patent, a key definitional dispute may arise over the term "exercise equipment" and whether it can be construed to cover activities where no external equipment is used.
  • Technical Questions: A primary technical question for the '973 Patent will be what evidence supports the allegation that the Oura Ring "recogniz[es] at least one start gesture." The analysis may focus on whether the accused system's automatic workout detection is equivalent to the claimed step, or if it represents a fundamentally different, non-infringing technical approach (e.g., continuous monitoring followed by retrospective classification rather than a prospective, gesture-triggered tracking session).

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

'065 Patent - Claim 1

  • The Term: "motivational analysis"
  • Context and Importance: This term is central to the novel aspect of the claim: adjusting a goal based on user-specific factors beyond simple performance history. The definition will be critical for determining whether the accused product's algorithm, which considers factors like readiness and sleep, performs this claimed step. Practitioners may focus on this term because its potential breadth or narrowness could be dispositive of infringement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim itself defines the term functionally as being "based on at least one factor that incites the user to reach the daily raw target exercise level" ('065 Patent, claim 1). The complaint reinforces this broad view by describing it as being "driven by defined data about the user's behavior and context" (Compl. ¶33).
    • Evidence for a Narrower Interpretation: The specification may provide specific embodiments of "motivational analysis," such as analyses based on user-selected personality types or explicit feedback, which could support a narrower construction than merely adapting to activity levels.

'973 Patent - Claim 14

  • The Term: "recognizing at least one start gesture"
  • Context and Importance: This term defines the trigger for the claimed tracking method. Infringement analysis will depend on whether the accused product's automatic workout detection functionality can be characterized as "recognizing a... gesture." If the term is construed to require a specific, deliberate, non-exercise motion by the user, automatic detection of an exercise's natural starting motion may not infringe.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language only requires that the gesture "involves movement of the accelerometer" ('973 Patent, claim 14), which could arguably encompass the initial movements of the exercise itself.
    • Evidence for a Narrower Interpretation: The patent describes the invention as providing an "intuitive, simplified user experience... that does not rely on... cumbersome means for the user to provide notification of exercise start and stop points" (Compl. ¶49; '973 Patent, col. 7:9-19). This may suggest that a "gesture" is a deliberate, simplified command intended to replace a button press, potentially narrowing the term to exclude the exercise motion itself.

VI. Other Allegations

  • Indirect Infringement: For each asserted patent, the complaint alleges both induced and contributory infringement. Inducement is alleged based on Defendant knowingly and intentionally encouraging infringement by customers and end-users (e.g., Compl. ¶¶ 40, 52). Contributory infringement is alleged on the basis that the Accused Products are especially designed for use in an infringing manner and have no substantial non-infringing uses (e.g., Compl. ¶¶ 41, 53).
  • Willful Infringement: Willfulness is alleged for all asserted patents on the basis of post-suit conduct. The complaint asserts that Defendant has notice of the patents "at least since the filing of this Complaint, and yet has continued its infringing activities" (e.g., Compl. ¶¶ 43, 55).

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

  • A core issue will be one of definitional scope and claim construction: For the '065 patent, what constitutes a "motivational analysis" and the use of a "plurality of goal setting algorithms"? For the '973 patent, can an automated, algorithm-driven workout detection process be construed to meet the claim limitation of "recognizing at least one start gesture," or does that term require a discrete, user-initiated command?
  • A second central issue will be one of technical evidence and operational sequence: For the '973 patent specifically, the case may turn on whether Plaintiff can demonstrate that the accused system performs the claimed steps in the required order—first recognizing a start gesture, and only after that recognition, beginning to track movement for the purpose of calculating exercise parameters.
  • Finally, a key strategic question will be how the parties manage the complexity of a six-patent case spanning disparate technologies, from software-based behavioral goal-setting ('065 Patent) and gesture recognition ('973 Patent) to specific hardware implementations for biometric sensing ('672, '152 Patents), power management ('655 Patent), and device-charger communication ('849 Patent).