Unaliwear Inc v. Apple Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: UnaliWear, Inc. (Delaware)
  • Defendant: Apple Inc. (California)
  • Plaintiff’s Counsel: Russ August & Kabat
• Case Identification: 7:25-cv-00570, W.D. Tex., 12/12/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant Apple has committed acts of infringement and maintains a regular and established place of business in the District, including a significant physical presence with a major corporate campus and thousands of employees in Austin.
• Core Dispute: Plaintiff alleges that Defendant’s Apple Watch products infringe patents related to wearable devices that use activity tracking and learned behavioral patterns for automatic fall detection and user assistance.
• Technical Context: The technology operates in the mobile personal emergency response services (mPERS) field, which aims to provide monitoring and emergency alerts for vulnerable populations through wearable devices.
• Key Procedural History: The complaint notes that a companion action detailing infringement allegations against the Defendant has also been filed in the International Trade Commission (ITC).

Case Timeline

Date	Event
2013-09-19	Priority Date for ’410 and ’193 Patents
2018-08-14	’410 Patent Issued
2020-06-16	’193 Patent Issued
2025-12-12	Complaint Filed

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

U.S. Patent No. 10,051,410, "Assist Device and System" (Issued Aug. 14, 2018)

The Invention Explained

• Problem Addressed: The patent background describes a need for technology that allows ill, elderly, or infirm individuals to live independently by providing monitoring that is "accurate, convenient, unobtrusive, and socially acceptable" (’410 Patent, col. 1:21-37). Existing systems are noted as lacking in their ability to effectively monitor activity, detect falls, and recognize deviations from a person's normal life patterns (’410 Patent, col. 1:29-34).
• The Patented Solution: The invention is a system centered on a wearable device that learns a user's individual activity patterns over time to provide personalized assistance (’410 Patent, col. 1:40-48). The device gathers sensor data (e.g., location, movement) and sends it to a server, which processes the data to create "behavioral rules" based on the user's history, such as typical sleep/wake cycles and home area boundaries (’410 Patent, Abstract; col. 2:1-18). The device then receives these rules from the server and uses them locally to compare against the wearer's current activity, triggering an offer of assistance if a significant deviation is detected (’410 Patent, Abstract).
• Technical Importance: This approach aims to create a more intelligent and less intrusive personal alert system by tailoring its monitoring logic to an individual's unique habits, which may reduce the high rate of false activations that cause users to abandon such devices (Compl. ¶3).

Key Claims at a Glance

• The complaint asserts multiple claims, including independent claim 1 (Compl. ¶28).
• Essential Elements of Independent Claim 1:
  • A wearable device with a power source, processor, physiologic sensor, user interface, and network interface.
  • The device is programmed to collect activity data over time.
  • The device provides this collected data to a server for processing to "create or update behavioral rules for the wearer," with the rules being based on historical data like "location mapping," "sleep/wake cycles," and "physiological sensor measurements."
  • The device receives the "behavioral rules from the server."
  • The device compares received activity data to the behavioral rules.
  • The device provides assistance information via the user interface if the comparison indicates a deviation from the user's activity profile.

U.S. Patent No. 10,687,193, "Assist Device and System" (Issued June 16, 2020)

The Invention Explained

• Problem Addressed: As a continuation-in-part of the application leading to the ’410 Patent, this patent addresses the same technical problem of providing unobtrusive, intelligent monitoring for individuals who require assistance to live independently (’193 Patent, col. 1:24-40).
• The Patented Solution: The invention describes a wearable device and remote computer system that work in concert to monitor a user (’193 Patent, col. 2:14-42). The device collects physical activity data and sends it to a remote computer, which processes the data to create or update a "parameterized rule-based custom data model" for that specific wearer (’193 Patent, Abstract). This custom model is then sent back to the wearable device, which uses it to perform local comparisons with newly collected activity data to determine if the wearer's activity is inconsistent with their established patterns (’193 Patent, Abstract).
• Technical Importance: The system's focus on creating a "custom data model" for each user reflects an approach to personalize emergency response technology, potentially improving its reliability and user acceptance by learning an individual's baseline behaviors (Compl. ¶2-3).

Key Claims at a Glance

• The complaint asserts multiple claims, including independent claim 1 (Compl. ¶41).
• Essential Elements of Independent Claim 1:
  • A wearable device with a power source, processor, physiologic sensor, user interface, and network interface.
  • The device collects physical activity data related to the "times and locations of physical activity of the wearer over time."
  • The device provides this data to a remote computer for processing to "create or update a parameterized rule-based custom data model for the wearer."
  • The device receives the "parameterized rule-based custom data model from the remote computer."
  • The device communicates with the wearer if a comparison of current activity against the received model indicates the activity is "not consistent with the... custom data model."

III. The Accused Instrumentality

Product Identification

The Accused Products are "Apple wearable products, including Apple Watch products such as the Apple Watch Series 10" (Compl. ¶1, ¶8).

Functionality and Market Context

The complaint alleges that the Accused Products incorporate "activity tracking technology including for automatic fall detection" (Compl. ¶1). It identifies them as certain "infringing products in the United States" sold by Apple (Compl. ¶24, ¶38). The complaint does not provide specific technical details regarding the operational architecture of the accused features, such as the data flow between the device and any backend servers for processing activity data or fall detection events. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references, but does not include, claim chart exhibits that purportedly detail the infringement (Compl. ¶25, ¶38). The narrative infringement theory is summarized below.

10,051,410 Infringement Allegations

The complaint alleges that Apple directly infringes, induces infringement, and contributes to the infringement of the ’410 Patent through its making, using, and selling of the Accused Products (Compl. ¶23). The infringement theory, which the complaint states is detailed in a chart in Exhibit 3, is that the "normal and customary use" of the Accused Products by customers meets the limitations of at least claim 1 (Compl. ¶25, ¶28). This suggests an allegation that the Apple Watch collects user activity data, which is processed by Apple's systems to establish behavioral patterns, and this information is then used on the device to trigger alerts like fall detection.

10,687,193 Infringement Allegations

The complaint presents a parallel infringement theory for the ’193 Patent, alleging that Apple's activities related to the Accused Products constitute direct infringement, inducement, and contributory infringement (Compl. ¶37, ¶39). The complaint states that a chart in Exhibit 4 details how the "normal and customary use" of the Accused Products meets the limitations of at least claim 1 of the ’193 Patent (Compl. ¶38, ¶41). This implies an allegation that the Apple Watch system creates a personalized data model for its users based on their activity, which is then employed on the device to monitor for deviations.

Identified Points of Contention

• Scope Questions: A central question may be whether Apple's fall detection and activity monitoring algorithms constitute the "behavioral rules" (’410 Patent) or a "parameterized rule-based custom data model" (’193 Patent) as claimed. The dispute could focus on whether Apple's system creates a personalized model that is then transmitted back to the device for local comparison, or if the system architecture operates differently (e.g., analysis and alerts are primarily cloud-based, or the on-device model is not created and updated in the manner claimed).
• Technical Questions: The complaint does not specify the data-processing architecture of the accused Apple Watch features. A key technical question for the case will be establishing the actual data flow: what sensor data is collected on the device, what information is transmitted to Apple's servers, what specific processing occurs on those servers, what resulting data or instructions are sent back to the device, and how the device uses that information for local decision-making regarding alerts. The claims appear to require a specific device-server-device feedback loop.

V. Key Claim Terms for Construction

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

• Context and Importance: This term is the foundation of the claimed invention in the ’410 Patent. Its construction will determine whether the output of Apple's data processing (e.g., algorithms, machine learning models) can be classified as the claimed "rules."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent specification states that the server may "create a map based on location data, identify sleep/wake cycles, identify correlations between time and location, identify activity patterns," suggesting that "rules" could encompass any data set or algorithm derived from historical user data that governs the device's alert logic (’410 Patent, col. 2:8-12).
  • Evidence for a Narrower Interpretation: The detailed description provides a specific example where a rule is articulated as: "A user typically wakes up and wanders around her home between 7 am and 9 am" (’410 Patent, col. 14:52-54). This could support an argument that "rules" must be more akin to explicit, conditional logic rather than an unarticulated, complex machine learning model.

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

• Context and Importance: This term is the core of the asserted claim in the ’193 Patent. Whether Apple's system creates and uses something that meets this definition will be a critical issue. Practitioners may focus on this term because its multi-part structure ("parameterized," "rule-based," "custom," "model") offers several potential avenues for claim construction disputes.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The abstract states the system is for processing data to "create or update a parameterized rule-based custom data model for the wearer," emphasizing the personalized and evolving nature of the model. This language may support a broad reading that covers any personalized analytical model derived from user data (’193 Patent, Abstract).
  • Evidence for a Narrower Interpretation: The term "rule-based" may be argued to require a model founded on explicit, definable rules, as opposed to a purely statistical or "black-box" neural network model where the logic is not easily articulated as a set of rules. The specification does not provide an explicit definition to distinguish it from other models, but this phrasing could be a focal point for argument.

VI. Other Allegations

Indirect Infringement

The complaint alleges inducement of infringement, stating that Apple encourages and instructs its customers to use the Accused Products in infringing ways through its "user manuals and online instruction materials on its website" (Compl. ¶27, ¶40).

Willful Infringement

The complaint alleges willfulness based on Apple having known or been "willfully blind to the fact" that its actions would constitute infringement (Compl. ¶29, ¶42). The basis for this alleged knowledge includes Apple's "full access to study Plaintiff's public IP portfolio" and the filing of this complaint and the companion ITC action (Compl. ¶22, ¶36).

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

1. Architectural Congruence: A central issue will be whether the operational architecture of the Apple Watch's fall detection and activity monitoring features matches the specific device-server-device data loop required by the asserted claims. Does Apple's system generate a distinct "behavioral rule" or "custom data model" on a server that is then transmitted to the wearable device for local comparative analysis, or does it employ a different technical architecture?
2. Definitional Scope: The case will likely turn on a question of claim construction: can the terms "behavioral rules" and "parameterized rule-based custom data model" be interpreted to cover the proprietary machine learning models and algorithms Apple uses for its health and safety features, or do the patents require a more specific structure that the accused system does not possess?
3. Evidentiary Substantiation: A key evidentiary question will be what discovery reveals about the inner workings of Apple's technology. The complaint's allegations are not supported by detailed technical descriptions of the accused functionality, making the actual implementation of the accused system a critical factual issue to be resolved.