RingConn LLC v. Ouraring Inc

1. Case Identification

• Case #: IPR2025-00412
• Patent #: 11,868,178
• Filed: January 6, 2025
• Petitioner(s): Ringconn LLC
• Patent Owner(s): Ouraring, Inc.
• Challenged Claims: 1-18

2. Patent Overview

• Title: Finger-worn electronic device
• Brief Description: The ’178 patent discloses a finger-worn wearable electronic device in the shape of a ring. The device includes external and internal housing components that form a cavity containing a battery, a printed circuit board (PCB), and one or more sensors for monitoring a user.

3. Grounds for Unpatentability

Ground 1: Obviousness over Schröder - Claims 1-3 and 17-18 are obvious over Schröder in view of the knowledge of a Person of Ordinary Skill in the Art (POSITA).

• Prior Art Relied Upon: Schröder (Patent 10,303,867).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Schröder, which teaches a biometric “finger-ring,” discloses all elements of independent claim 1. Schröder’s device consists of two ring halves (an external and internal housing component) that form a recess (a cavity) containing an inlay with a chip module, battery, and biometric sensors. Petitioner contended that a POSITA would understand this inlay to be a PCB. For dependent claims 2 and 3, Petitioner asserted that arranging the battery and PCB in non-overlapping or partially overlapping portions of the cavity represents a simple design choice with a finite number of predictable solutions, making both configurations obvious.
  • Motivation to Combine (for §103 grounds): As this ground relies on a single reference, the motivation was framed as obvious design modifications. A POSITA would be motivated to arrange components in a non-overlapping manner (claim 2) to create a thinner, more comfortable ring, or in an overlapping manner (claim 3) to reduce the device's diameter and risk of lost electrical connections.
  • Expectation of Success (for §103 grounds): Success was expected because arranging components within a confined space is a routine aspect of electronic device design.

Ground 2: Obviousness over Schröder and Niwa - Claims 1-3 and 13-16 are obvious over Schröder in view of Niwa.

• Prior Art Relied Upon: Schröder (Patent 10,303,867) and Niwa (Application # 2012/0016245).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Schröder teaches the basic ring structure, while Niwa provides specific teachings on advanced sensor configurations relevant to claims 13-16. Niwa discloses a finger ring-type device for acquiring a plethysmogram, featuring a sensor with multiple light-emitting components (LEDs) that can emit light at different wavelengths (e.g., visible and near-infrared). Niwa also teaches arranging these LEDs at different radial positions around a central photodetector to improve measurement accuracy.
  • Motivation to Combine (for §103 grounds): A POSITA would combine these references to enhance the sensing capabilities of Schröder’s basic biometric ring. Incorporating Niwa’s multi-wavelength and multi-position sensor design into Schröder’s device would be a predictable way to capture a broader range of more accurate biometric data, a known goal in the field of wearable technology.
  • Expectation of Success (for §103 grounds): A POSITA would expect success in integrating Niwa’s well-understood sensor technologies into Schröder’s analogous ring device, as both relate to finger-worn biometric sensors and involve standard electronic components.

Ground 3: Obviousness over Schröder and Yuen - Claims 1, 4-11, and 13-16 are obvious over Schröder in view of Yuen.

• Prior Art Relied Upon: Schröder (Patent 10,303,867) and Yuen (Patent 8,954,135).

• Core Argument for this Ground:

  • Prior Art Mapping: Petitioner argued this combination renders claims related to power management and charging obvious. While Schröder provides the foundational ring device, Yuen teaches a wearable biometric monitor with features directly corresponding to the dependent claims. Yuen discloses using magnets to align a device with its charger (claim 4) for wireless energy transfer (claim 5). Yuen also explicitly teaches selectively adjusting sensor operational parameters—such as sampling periodicity—based on acquired data like user activity, heart rate, or sleep state (claims 6-9), or based on battery power level to conserve energy (claims 10-11).
  • Motivation to Combine (for §103 grounds): A POSITA would be motivated to add Yuen’s functionalities to Schröder’s ring to improve user convenience and device efficiency. Implementing magnetic alignment would make charging easier, and incorporating adaptive sensor operation would extend battery life, both of which are significant market drivers for wearable devices.
  • Expectation of Success (for §103 grounds): Success would be expected as the electronic components described in Yuen and Schröder are similar and scalable. Integrating known power management algorithms and magnetic charging mechanisms into a wearable device was a routine and predictable task for a POSITA.

• Additional Grounds: Petitioner asserted an additional obviousness challenge against claims 3 and 12 based on Schröder in view of Mestas (Application # 2014/0244009), which teaches a wearable device with a curved battery conforming to the device’s shape and an overlapping PCB/battery configuration.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that the Board should not exercise its discretion to deny institution under 35 U.S.C. §325(d) because the primary prior art references, Schröder and Niwa, were never presented to or considered by the examiner during prosecution. While Yuen was listed in an Information Disclosure Statement (IDS), it was one of 138 references, and the examiner’s failure to apply its clear teachings to the dependent claims constituted a material error.
• Petitioner also argued against denial under Fintiv, stating that the parallel district court litigation between the parties is stayed, which weighs heavily in favor of institution.

5. Relief Requested

• Petitioner requests institution of inter partes review (IPR) and cancellation of claims 1-18 of the ’178 patent as unpatentable.