Mobile Health Innovative Solutions LLC v. Montblanc North America LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Mobile Health Innovative Solutions, LLC (Wyoming)
  • Defendant: Montblanc North America, LLC (Delaware)
  • Plaintiff’s Counsel: DNL Zito
• Case Identification: 3:25-cv-03333, N.D. Tex., 12/04/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Texas because Defendant maintains a regular and established place of business within the district, specifically citing a retail location in Dallas.
• Core Dispute: Plaintiff alleges that Defendant’s Montblanc Summit 3 smartwatch, which includes a feature for calculating and displaying a user's stress level, infringes a patent related to determining a user's physiological load level using data from a mobile device.
• Technical Context: The technology at issue operates in the field of wearable health monitoring, a market focused on leveraging sensors in consumer electronic devices to provide users with insights into their physiological and psychological state.
• Key Procedural History: U.S. Patent No. 11,468,984 was the subject of an ex parte reexamination requested on June 25, 2024. The USPTO issued a Reexamination Certificate on December 3, 2024, confirming the patentability of all challenged claims, including independent claim 12, which is asserted in this litigation.

Case Timeline

Date	Event
2012-08-01	'984 Patent Priority Date
2022-10-11	'984 Patent Issue Date
2024-06-25	Ex Parte Reexamination of '984 Patent Requested
2024-12-03	Ex Parte Reexamination Certificate Issued for '984 Patent
2025-12-04	Complaint Filing Date

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

U.S. Patent No. 11,468,984 - "Device, Method and Application for Establishing a Current Load Level"

• Patent Identification: U.S. Patent No. 11,468,984, "Device, Method and Application for Establishing a Current Load Level," issued October 11, 2022.

The Invention Explained

• Problem Addressed: The patent describes prior art methods for determining stress levels as being disadvantaged because they rely on "very few biometric data" (e.g., only a single vital function), require special dedicated hardware that can be costly and cumbersome to wear, or depend on high-effort, subjective user questionnaires (’984 Patent, col. 2:5-34).
• The Patented Solution: The invention claims a system and method that uses a general-purpose mobile terminal, like a smartphone, to establish a user's stress level. It does this by collecting a "multiplicity of biometric data" from two sources: "signal data" from the device's integrated sensors (e.g., gyroscope, microphone) and "use data" from other software applications on the device (e.g., telephony, SMS messaging) (’984 Patent, col. 2:55-65; col. 3:28-34). An evaluation unit then processes this diverse dataset, potentially using artificial neural networks, to determine a more reliable and nuanced stress level without requiring the user to wear a special-purpose device (’984 Patent, Abstract; col. 6:13-19).
• Technical Importance: This approach sought to leverage the increasingly powerful and sensor-rich smartphones already carried by users to provide sophisticated health monitoring that was previously only possible with specialized equipment (’984 Patent, col. 2:41-53).

Key Claims at a Glance

• The complaint asserts at least independent claim 12 (’984 Patent, col. 28:12-62).
• Claim 12 is a method claim with essential elements including:
  • Starting a further application installed on a mobile end unit.
  • Calculating biometric data of the user by means of the further application, where the data is recorded from user data (from using a plurality of applications) and calculated from at least one signal data (produced by at least one sensor).
  • Dividing the biometric data into a plurality of categories.
  • Evaluating the biometric data with an evaluation unit to determine a current load level.
  • The use of a network of interacting artificial neural networks.
  • Displaying the determined current load level to the user via the mobile end unit.
• The complaint states infringement of "one or more claims, including at least Claim 12," preserving the right to assert additional claims (Compl. ¶25).

III. The Accused Instrumentality

Product Identification

• The Montblanc Summit 3 smartwatch (Compl. ¶25).

Functionality and Market Context

• The complaint alleges the accused product is a smartwatch that "calculates and displays a user's stress level" (Compl. ¶25). It is alleged to include a "Stress application" that "continuously monitors biometric data such as heart rate and breathing rate to determine the stress score/levels" (Compl. ¶25). The resulting stress level is allegedly categorized as Low, Medium, or High, and presented with an hourly graph and a weekly score on a 0–100 scale (Compl. ¶25-26).

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint states that a claim chart comparing Claim 12 to the accused product is attached as Exhibit B, but this exhibit was not provided with the complaint (Compl. ¶31). The infringement theory must therefore be summarized from the narrative allegations. Plaintiff alleges that the Montblanc Summit 3 smartwatch practices the claimed method by running a "Stress application" that monitors biometric data (heart rate, breathing rate) from its sensors, uses this data to calculate a stress score, and displays the result to the user (Compl. ¶25).

Identified Points of Contention

• Scope Questions: Claim 12 requires calculating biometric data from two distinct sources: (1) "user data that is recorded from using a plurality of applications" and (2) "at least one signal data produced by at least one sensor." The complaint's allegations focus exclusively on sensor data (heart rate, breathing rate) (Compl. ¶25). This raises the question of whether the complaint provides any factual basis to suggest the accused product meets the "user data from a plurality of applications" limitation, which is a required element of the asserted claim.
• Technical Questions: The claim requires dividing the input biometric data into a "plurality of categories." The complaint alleges the final output is categorized ("Low, Medium, or High") (Compl. ¶26). What evidence does the complaint provide that the accused product categorizes its input data—such as heart rate and breathing rate—into distinct groups before evaluation, as required by the claim?

V. Key Claim Terms for Construction

The Term: "biometric data...recorded at least from user data that is recorded from using a plurality of applications present and available on the mobile end unit by the user, and calculated from at least one signal data produced by at least one sensor"

• Context and Importance: This composite term defines the required inputs for the claimed method. The central infringement question appears to be whether the accused product's data inputs satisfy both prongs of this definition.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification lists a wide array of potential data sources, from telephony and SMS logs to gyroscope and microphone signals, suggesting the term is meant to be capacious (’984 Patent, col. 4:49-63). A party could argue that any data originating from the device falls within its general scope.
  • Evidence for a Narrower Interpretation: A party could argue that the claim's use of "and" creates a mandatory two-part requirement: the system must use data from other applications (e.g., call logs) in addition to data from physical sensors. The patent's background criticizes prior art for using "very few biometric data," and the solution is repeatedly framed as combining multiple, different types of data for a more holistic analysis (’984 Patent, col. 2:6-13; col. 2:55-57).

The Term: "plurality of categories"

• Context and Importance: This term dictates how the input data must be organized before evaluation. Infringement depends on whether the accused product performs this specific data-structuring step.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party could argue that any logical grouping of data meets this limitation, such as separating "heart rate data" from "breathing rate data" into two distinct categories.
  • Evidence for a Narrower Interpretation: Practitioners may focus on this term because the patent specification and dependent claim 5 provide specific examples of categories, such as "sleep, speech, motor skills, social interaction, economic data, personal information, and questionnaire data" (’984 Patent, col. 27:60-65). A party could argue this context implies that "plurality of categories" requires functionally distinct behavioral or physiological groupings, rather than merely organizing data by its sensor of origin.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement based on Defendant providing "product literature and website materials" that instruct end users on how to use the accused Stress application in a manner that allegedly infringes (Compl. ¶28, ¶29). It also alleges contributory infringement, asserting the accused features are specially designed for infringement and lack substantial non-infringing uses (Compl. ¶30).
• Willful Infringement: Willfulness is alleged based on knowledge of the '984 Patent obtained "at least as of the service of the present complaint" (Compl. ¶23). The allegations appear to support a claim for post-suit willfulness rather than pre-suit willfulness.

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

• A central issue will be one of factual correspondence: does the complaint provide a basis to believe that the accused Montblanc Summit 3 smartwatch calculates stress levels using data from a "plurality of applications" (such as call or message logs), in addition to its physical sensor data, as expressly required by the asserted independent claim?
• A key question of claim construction will be the required scope of "plurality of categories." The dispute may turn on whether this term can be satisfied by simply separating raw sensor inputs by source, or if it must be construed more narrowly to require the distinct behavioral and physiological groupings (e.g., "sleep," "speech," "motor functions") described in the patent's specification.
• Finally, the procedural history of the patent is significant. The fact that asserted claim 12 recently survived an ex parte reexamination may influence litigation strategy regarding invalidity defenses, as the patent carries a strengthened presumption of validity on the issues considered by the USPTO.