Unaliwear Inc v. Samsung Electronics Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: UnaliWear, Inc. (Delaware)
  • Defendant: Samsung Electronics Co., Ltd. (South Korea) and Samsung Electronics America, Inc. (New York)
  • Plaintiff’s Counsel: Russ August & Kabat
• Case Identification: 2:25-cv-01214, E.D. Tex., 12/12/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant Samsung Electronics America, Inc. maintains a regular and established place of business within the Eastern District of Texas, and Defendant Samsung Electronics Co., Ltd. is a foreign corporation, for which venue is proper in any judicial district.
• Core Dispute: Plaintiff alleges that Defendant’s Samsung Galaxy Watch products infringe two patents related to wearable devices that monitor a user’s activity, learn their patterns, and provide assistance based on deviations from those learned patterns, including for fall detection.
• Technical Context: The technology relates to the mobile personal emergency response services (mPERS) market, specifically wearable devices that use sensor data and machine learning to provide proactive safety monitoring for vulnerable populations.
• Key Procedural History: The complaint notes the filing of a companion action in the International Trade Commission concerning the same patents and infringement allegations.

Case Timeline

Date	Event
2013-09-19	Priority Date for ’410 and ’193 Patents
2018-08-14	U.S. Patent No. 10,051,410 Issues
2020-06-16	U.S. Patent No. 10,687,193 Issues
2025-12-12	Complaint Filed

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

U.S. Patent No. 10,051,410 - "Assist Device and System"

The Invention Explained

• Problem Addressed: The patent addresses the lack of devices for monitoring elderly or infirm persons that are "accurate, convenient, unobtrusive, and socially acceptable" (’410 Patent, col. 1:30-34). Existing solutions did not adequately monitor activity patterns, detect falls, or recognize deviations from normal life patterns in a dignified manner (’410 Patent, col. 1:28-37).
• The Patented Solution: The invention is a wearable device that learns a user's activity patterns through communication with a server. The device gathers sensor data and sends it to a server, which analyzes the data to create or update "behavioral rules" specific to the wearer (’410 Patent, col. 2:1-18). These rules are then sent back to the device, which compares its ongoing sensor readings against the rules to determine if the user has deviated from their normal patterns and may need assistance (’410 Patent, Abstract).
• Technical Importance: This server-device feedback loop enabled a shift from reactive panic buttons to a proactive, personalized monitoring system that could anticipate needs based on learned behavior (Compl. ¶3).

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶29).
• Claim 1 of the ’410 Patent requires:
  • A wearable device with a power source, processor, physiologic sensor, user interface, network interface, and memory.
  • The device is caused by program instructions to perform steps including:
    • Collecting activity data from the sensor to determine a wearer's physical activity pattern.
    • Providing the collected data to a server for processing to create or update "behavioral rules" based on historical wearer data (e.g., location mapping, sleep/wake cycles).
    • Receiving the "behavioral rules" from the server.
    • Providing assistance to the wearer when a check of the wearer's activity against the received behavioral rules indicates a deviation.

U.S. Patent No. 10,687,193 - "Assist Device and Systems"

The Invention Explained

• Problem Addressed: As a continuation-in-part, the ’193 Patent addresses the same problem as the ’410 Patent: the need for an unobtrusive and intelligent monitoring system for vulnerable individuals living independently (’193 Patent, col. 1:30-49).
• The Patented Solution: The solution is again a wearable device that communicates with a remote computer to create a personalized monitoring profile. This patent refines the concept by describing the profile as a "parameterized rule-based custom data model" (’193 Patent, Abstract). The device collects activity data, sends it to the remote computer to create or update this model, receives the model back, and compares current activity to the model to detect inconsistencies that may signal a need for assistance (’193 Patent, col. 2:25-44).
• Technical Importance: The introduction of a "parameterized rule-based custom data model" suggests an evolution toward a more structured and computationally defined method of personalizing user monitoring, aiming to improve accuracy and reduce false alarms (Compl. ¶3).

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶43).
• Claim 1 of the ’193 Patent requires:
  • A wearable device with a power source, processor, physiologic sensor, user interface, network interface, and memory.
  • The device is caused by program instructions to perform steps including:
    • Collecting physical activity data related to "times and locations of physical activity" of the wearer.
    • Providing the data to a remote computer for processing to create or update a "parameterized rule-based custom data model."
    • Receiving the "parameterized rule-based custom data model" from the remote computer.
    • Communicating with the wearer when a comparison of current activity against the model indicates the wearer's activity is "not consistent" with the model.

III. The Accused Instrumentality

Product Identification

• The accused products are Samsung wearable products, including the Samsung Galaxy Watch line, specifically naming the Samsung Galaxy Watch8 (Compl. ¶1, 10).

Functionality and Market Context

• The complaint alleges the Accused Products incorporate "activity tracking technology including for automatic fall detection" (Compl. ¶1). It asserts that the customary use of these products involves the collection and processing of user-specific data, such as motion and location data, to provide support for wearers (Compl. ¶2-3).
• The complaint does not provide sufficient detail for a deeper technical analysis of the Accused Products' specific architecture or operational methods, instead referencing external exhibits not included with the complaint (Compl. ¶26, 40).

IV. Analysis of Infringement Allegations

The complaint references, but does not include, claim chart exhibits detailing its infringement theories (Compl. ¶26, 40). The narrative allegations are summarized below. No probative visual evidence provided in complaint.

U.S. Patent No. 10,051,410 Infringement Allegations

• The complaint alleges that the normal and customary use of the Samsung Galaxy Watch products infringes at least claim 1 of the ’410 Patent (Compl. ¶29). The implied theory is that the accused watches contain the hardware elements of the claim (processor, sensors, network interface, etc.) and perform the claimed method steps. Specifically, the watch allegedly collects user activity data, transmits it to a Samsung-operated server for processing into what Plaintiff contends are "behavioral rules," receives those rules back, and uses them on the device to monitor the user and provide assistance, such as fall detection alerts (Compl. ¶1, 24, 29).

U.S. Patent No. 10,687,193 Infringement Allegations

• The complaint makes parallel allegations for claim 1 of the ’193 Patent (Compl. ¶43). The infringement theory alleges that the Samsung Galaxy Watch products collect activity data related to time and location, provide it to a remote computer (server) for processing, and that this processing results in what Plaintiff contends is a "parameterized rule-based custom data model" (’193 Patent, cl. 1). The device then allegedly receives this model and uses it to detect activity that is inconsistent with the user's learned patterns (Compl. ¶38, 43).

Identified Points of Contention

• Scope Questions: A primary dispute may concern whether the data models generated and used by the Samsung ecosystem qualify as "behavioral rules" under the ’410 Patent or a "parameterized rule-based custom data model" under the ’193 Patent.
• Technical Questions: What is the specific data-processing architecture of the accused system? The claims require the wearable device to receive the rules/model from the server and perform the comparison on the device. An evidentiary question will be whether the Samsung watches perform these steps locally, or if the comparison and alert-triggering logic resides entirely on the server, which may raise questions about whether the accused device itself performs all the claimed steps.

V. Key Claim Terms for Construction

The Term: "behavioral rules" (from ’410 Patent, claim 1)

• Context and Importance: This term is central to the invention of the ’410 Patent. Its scope will determine whether Samsung's method of analyzing user data and detecting deviations constitutes infringement. Practitioners may focus on whether this term requires a set of explicit, human-readable rules or if it can encompass the output of a more generalized machine learning model.
  • Intrinsic Evidence for a Broader Interpretation: The specification describes the rules as being based on a wide array of data, including "location data, identify sleep/wake cycles, identify activity patterns, identify normal ranges of physiologic parameters and the like," which may support a broad definition covering various forms of user modeling (’410 Patent, col. 2:9-12).
  • Intrinsic Evidence for a Narrower Interpretation: The patent provides specific examples, such as a rule based on a user typically waking "between 7 am and 9 am" (’410 Patent, col. 14:52-55). This could support an interpretation requiring discrete, conditional logic rather than a probabilistic model.

The Term: "parameterized rule-based custom data model" (from ’193 Patent, claim 1)

• Context and Importance: This term distinguishes the ’193 Patent from its parent and appears more technically specific. Its construction is critical to determining infringement of the later patent, and a court may construe it more narrowly than "behavioral rules."
  • Intrinsic Evidence for a Broader Interpretation: The patent describes the model as being "representative of an activity profile of the times and locations of physical activity" and being created from collected data, which could be argued to broadly cover any user-specific model with adjustable variables (’193 Patent, cl. 1).
  • Intrinsic Evidence for a Narrower Interpretation: The explicit inclusion of "rule-based" and "parameterized" suggests a specific technical structure. The specification discusses providing "update parameters" for the model from the remote computer, which could imply a structure where defined rules exist on the device and the server only sends updated values for their parameters, a potentially limiting architectural requirement (’193 Patent, col. 3:34-37).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Samsung encourages and instructs customers to use the Accused Products in an infringing manner through "user manuals and online instruction materials on its website" (Compl. ¶28, 42).
• Willful Infringement: Willfulness is alleged based on Samsung’s purported knowledge of the patents or willful blindness to its infringement (Compl. ¶30, 44). The complaint alleges Defendants have had "full access to study Plaintiff's public IP portfolio" as a basis for this knowledge (Compl. ¶23, 37).

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

• A core issue will be one of definitional scope: Can the terms "behavioral rules" (’410 Patent) and the more specific "parameterized rule-based custom data model" (’193 Patent) be construed to read on the proprietary algorithms and user profiles generated by Samsung’s wearable device ecosystem?
• A key evidentiary question will be one of architectural congruence: Do the accused Samsung watches perform the specific sequence required by the claims—namely, receiving a complete rule-set or model from a server and executing the comparison logic locally on the device—or does the critical analysis and decision-making occur on Samsung's servers, potentially creating a mismatch with the claim language?