DCT
4:22-cv-01042
Precision Point Devices LLC v. Huawei Tech USA Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Precision Point Devices LLC (Delaware)
- Defendant: Huawei Technologies USA, Inc. (Texas)
- Plaintiff’s Counsel: Budo Law P.C.
- Case Identification: 4:22-cv-01042, E.D. Tex., 12/13/2022
- Venue Allegations: Venue is alleged to be proper in the Eastern District of Texas because Defendant is a Texas corporation that has transacted business within the district.
- Core Dispute: Plaintiff alleges that Defendant’s wearable health-tracking devices infringe two patents related to dynamically selecting and utilizing sensors to provide information services.
- Technical Context: The dispute is situated in the field of wearable sensor technology, specifically devices that monitor personal health and fitness data for users.
- Key Procedural History: The '452 Patent is subject to a terminal disclaimer over a related application in the same patent family, a fact which may become relevant to analyses of non-statutory double patenting. The complaint does not mention any other prior litigation or administrative proceedings involving the patents-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2009-03-05 | Priority Date for '060 Patent |
| 2009-03-13 | Priority Date for '452 Patent |
| 2013-10-22 | '060 Patent Issued |
| 2013-11-12 | '452 Patent Issued |
| 2022-12-13 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,566,060 - “Information service providing system, information service providing device, and method therefor,” issued October 22, 2013
The Invention Explained
- Problem Addressed: The patent describes the challenge of providing various information services (e.g., navigation, health monitoring) on a device with multiple sensors. The optimal sensor for a task may vary based on environmental conditions, such as GPS being effective outdoors but not underground, requiring a switch to other sensors to maintain service quality (’060 Patent, col. 2:38-50).
- The Patented Solution: The invention is a device that can automatically select the most appropriate sensor or combination of sensors from a plurality of available options based on a user’s request for a specific information service. The selection is guided by predefined "associating information" that links services to necessary sensors and processing programs, allowing the device to adapt its sensor usage to the context and provide a variety of services by combining sensors and software modules (’060 Patent, Abstract; col. 2:63-3:9).
- Technical Importance: The technology addresses the need for context-aware adaptability in devices equipped with numerous sensors, a foundational challenge in mobile and wearable computing (’060 Patent, col. 2:10-14).
Key Claims at a Glance
- The complaint asserts at least independent claim 10 (Compl. ¶29).
- Essential elements of Claim 10 (a method claim) include:
- Accepting an external input specifying an information service.
- Selecting sensor driving program modules and processing program modules to implement the service, based on pre-associated information.
- Executing the selected modules and delivering information between them to implement the service.
- Outputting a result of the service, where the sensor modules drive sensors to detect information and the processing modules process that information.
U.S. Patent No. 8,583,452 - “Health check system, health check apparatus and method thereof,” issued November 12, 2013
The Invention Explained
- Problem Addressed: This patent focuses specifically on health-monitoring services. It notes that providing a health check may require changing sensor settings (e.g., sensitivity of a blood pressure sensor) for different users or changing the data processing logic based on a user's normal condition (’452 Patent, col. 2:12-24).
- The Patented Solution: The invention is a health check apparatus that selects optimal sensors for a specified health check from among those available. The system uses a predefined priority scheme to select the best available combination of sensors and sets appropriate parameters for both the sensors and the data processing programs to deliver a tailored health check service (’452 Patent, Abstract; col. 2:35-42).
- Technical Importance: The invention provides a framework for delivering personalized and adaptive health monitoring on multi-sensor devices by automatically managing sensor selection and configuration based on service requirements and sensor availability (’452 Patent, col. 2:2-6).
Key Claims at a Glance
- The complaint asserts at least independent claim 11 (Compl. ¶46).
- Essential elements of Claim 11 (a method claim) include:
- Receiving an input specifying a health check service.
- Selecting sensor drive modules and service execution modules based on association information.
- Executing the selected modules to realize the health check service.
- Outputting a result, where the sensor modules drive physiological sensors to detect information.
- A specific limitation requiring that "priority is assigned to the respective physiological sensors" and that the device executes sensor modules "in accordance with the priority".
III. The Accused Instrumentality
Product Identification
The Accused Products include, but are not limited to, the Huawei Watch GT, Band 3 series, Band 4 series, Band 2 series, TalkBand, Watch 2, and Honor Band Z113 (Compl. ¶21).
Functionality and Market Context
The Accused Products are wearable electronic devices equipped with multiple sensors. They are alleged to provide users with health and fitness information, such as heart rate, oxygen level, step count, and calories burned, during various user-selected activities including running, swimming, walking, golf, and yoga (Compl. ¶21). The complaint does not provide sufficient detail for analysis of the products' specific market positioning or commercial importance.
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint.
'060 Patent Infringement Allegations
| Claim Element (from Independent Claim 10) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a method for providing an information service, comprising: accepting external input specifying one or more of a plurality of information services; | Users of the Accused Products specify an information service by selecting a workout or activity type (e.g., "run," "swim," "yoga") on the device interface. | ¶21 | col. 30:9-11 |
| selecting the one or more sensor driving program modules to implement one or more of the specified information services, and the one or more processing program modules, on the basis of associating information... | The Accused Products are alleged to select appropriate sensors (e.g., heart rate sensor, GPS) and corresponding software modules based on the activity chosen by the user, thereby implementing an information service. | ¶14, ¶21 | col. 30:12-19 |
| executing the selected sensor driving program module and processing program modules and delivering information input-output between these so as to be adapted to the implementation of the specified information service... | The Accused Products allegedly execute the selected software modules to operate the chosen sensors, gather data, and process the data to generate health metrics. | ¶21, ¶28 | col. 30:20-25 |
| outputting one or more result of the implemented information service, wherein each of the executed processing program modules processes the information of sensor which is output from the executed sensor driving program... | The Accused Products display health and workout metrics such as heart rate, calories burned, and step count to the user as the result of the information service. | ¶21 | col. 30:26-34 |
'452 Patent Infringement Allegations
| Claim Element (from Independent Claim 11) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| An information service delivering method which is a health check method, comprising: receiving an input specifying a health check service; | Users of the Accused Products specify a health check service by selecting a physical activity mode, which triggers health monitoring functions. | ¶21 | col. 30:46-48 |
| selecting one or more sensor drive modules and one or more service execution modules to realize the health check service based on association information... | The Accused Products are alleged to select the necessary sensors (e.g., heart rate, blood oxygen) and software modules required to perform the health monitoring functions associated with the user-selected activity. | ¶14, ¶21 | col. 30:49-56 |
| wherein priority is assigned to the respective physiological sensors in the health check service such that the execution device is configured to execute at least one of the selected one or more sensor drive modules... | The complaint's general allegations suggest that the Accused Products' selection of the "most appropriate sensor" inherently involves a priority system, though specific facts detailing this priority mechanism are not provided. | ¶14 | col. 31:1-7 |
| wherein the respective executed one or more service execution modules are configured to process the physiological sensor information outputted from the executed sensor drive module and output a processing result... | The Accused Products process the raw data from the physiological sensors (e.g., pulse readings, accelerometer data) to calculate and output metrics like heart rate and step count as the result of the health check service. | ¶21 | col. 31:8-13 |
Identified Points of Contention
- Scope Questions: A central question will be whether a user selecting a pre-configured "workout mode" on a watch meets the claim limitation of "selecting ... modules ... on the basis of associating information." The defense may argue the claims require a more dynamic, table-based selection process as detailed in the patents' specifications, rather than the activation of a static, pre-defined set of functions for a given mode.
- Technical Questions: For the '452 Patent, a key factual dispute will be whether the Accused Products implement a "priority" system for sensor selection as explicitly required by claim 11. The complaint does not provide specific evidence that the devices choose between multiple available sensors for the same task based on a pre-assigned priority (e.g., preferring GPS over an accelerometer for location data when both are available and functional).
V. Key Claim Terms for Construction
Term 1 ('060 Patent): "selecting ... on the basis of associating information"
- Context and Importance: This phrase captures the core intelligence of the claimed invention. Its construction will determine whether the claim covers any system that links a user input to sensor activation or if it is limited to a more complex, context-aware selection mechanism.
- Intrinsic Evidence for a Broader Interpretation: The claim language itself is general and does not explicitly require a specific data structure or algorithm for the selection, potentially supporting a construction that covers any logical association between a service and the modules needed to perform it.
- Intrinsic Evidence for a Narrower Interpretation: The specification repeatedly describes the selection process as being based on a "table of service definition" that includes sensor priorities (’060 Patent, FIG. 6; col. 9:11-40). A defendant could argue that this detailed disclosure limits the claim scope to systems that employ a similar table-driven, priority-based selection architecture.
Term 2 ('452 Patent): "priority is assigned to the respective physiological sensors"
- Context and Importance: This limitation distinguishes claim 11 of the '452 Patent from claim 10 of the '060 Patent and is critical for proving infringement of the '452 Patent. The case may turn on whether the accused devices can be shown to use a "priority" scheme.
- Intrinsic Evidence for a Broader Interpretation: Plaintiff may argue that any implicit or operational preference (e.g., a device defaulting to GPS for location tracking when a signal is available, and only using other sensors as a fallback) constitutes an assigned "priority."
- Intrinsic Evidence for a Narrower Interpretation: The specification provides examples of an explicit, numerical priority system (e.g., "the highest priority 1," "the next priority 2") assigned to different sensor combinations to achieve the best possible result given sensor availability (’452 Patent, col. 19:20-33). This may support a narrower construction requiring a predefined, ranked hierarchy for sensor selection.
VI. Other Allegations
Indirect Infringement
The complaint alleges inducement of infringement based on Defendant's advertising and user instructions, available on its public websites, which allegedly encourage and direct customers to use the Accused Products in an infringing manner (e.g., by selecting workout modes that activate the patented methods) (Compl. ¶¶33-34, 50-51). Contributory infringement is alleged on the basis that the accused features have no substantial non-infringing uses (Compl. ¶¶38, 55).
Willful Infringement
The complaint does not contain an explicit allegation of willful infringement. However, it alleges that Defendant possessed the requisite knowledge for indirect infringement at least as of the filing of the suit, and the prayer for relief requests attorneys' fees under 35 U.S.C. § 285, which may be awarded in exceptional cases (Compl. ¶¶32, 49, 57(d)).
VII. Analyst’s Conclusion: Key Questions for the Case
This case will likely center on two fundamental questions of claim scope and evidentiary proof:
- A core issue will be one of implementation and scope: Do the Accused Products, which allow users to select from a menu of pre-set activity modes, perform the specific, dynamic "selection" of software modules based on "associating information" as claimed in the patents, or do they simply activate a hard-coded set of functions?
- A key evidentiary question, particularly for the '452 Patent, will be one of functional operation: Does the complaint provide sufficient factual support to demonstrate that the Accused Products utilize a "priority" system to choose between different available sensors to perform a task, as explicitly required by claim 11, or is there a fundamental mismatch in the alleged and claimed technical operations?