Samsung Electronics Co Ltd v. Oura Health Oy

1. Case Identification

• Case #: PGR2024-00038
• Patent #: 11,874,701
• Filed: June 28, 2024
• Petitioner(s): Samsung Electronics Co., Ltd.; Samsung Electronics America, Inc.
• Patent Owner(s): Ouraring, Inc.
• Challenged Claims: 1-7, 11, and 13-20

2. Patent Overview

• Title: Wearable Electronic Device for Gesture Recognition
• Brief Description: The ’701 patent relates to a wearable electronic device, such as a smart ring, that uses an embedded accelerometer to measure and identify gestures performed by a user. The device is configured to match identified gestures to a library of stored gesture patterns and, based on a match, transmit a control signal to an external device or provide feedback to the user.

3. Grounds for Unpatentability

Ground 1: Obviousness over Sun - Claims 1-7, 11, 13-16, and 18-20 are obvious over Sun.

• Prior Art Relied Upon: Sun (Application # 2011/0080339).
• Core Argument:
  • Prior Art Mapping: Petitioner argued that Sun teaches all elements of the challenged claims. Sun disclosed a wearable wrist/finger mouse with a housing containing an electronic part (a motion sensor with accelerometers) configured to acquire acceleration data from a user's gestures. Sun’s device included one or more processors (a microcontroller unit) communicatively coupled to the sensor. These processors were configured to: receive the acceleration data, identify a performed gesture by comparing it to a stored library of gesture patterns, determine if the gesture matched a pattern, and generate a message (an input signal) that caused a communication component to transmit a command signal to an external device (e.g., a computer). Petitioner asserted that Sun also explicitly taught dependent claim features, such as using an acceleration threshold to identify gestures (claim 2), implementing a "training mode" for new gestures (claim 3), authenticating a user via a gesture-based password (claim 11), and using the device as a finger-worn wearable (claim 18).

Ground 2: Obviousness over Kruse - Claims 1, 6-7, and 13-20 are obvious over Kruse.

• Prior Art Relied Upon: Kruse (Patent 8,031,172).
• Core Argument:
  • Prior Art Mapping: Petitioner contended that Kruse independently taught the core invention. Kruse disclosed a wearable electronic device (a haptic ring) with a housing and an internal accelerometer to acquire acceleration data from a user's finger movements. A processor within Kruse’s device was configured to receive this data and identify a gesture by filtering out extraneous, non-command movements. The processor then determined if the identified gesture matched a gesture pattern established during a calibration process. Upon finding a match, the device generated a message configured to both transmit a command signal to an external device and, crucially, cause a feedback component (a haptic output device) to provide haptic feedback to the user, confirming the recognized command. Petitioner argued this system met the limitations of the independent claims, including providing both external control and user feedback.

Ground 3: Obviousness over Sun in view of Kruse - Claims 4 and 17 are obvious over Sun in view of Kruse.

• Prior Art Relied Upon: Sun (Application # 2011/0080339), Kruse (Patent 8,031,172).

• Core Argument:

  • Prior Art Mapping: This ground primarily addressed claims requiring feedback to the user (claim 17) and commands performed at least in part by the wearable device itself (claim 4). Petitioner argued that Sun provided the primary gesture recognition system, while Kruse supplied the motivation and means to add a feedback component.
  • Motivation to Combine: A POSITA would combine Sun's gesture-controlled mouse with Kruse's haptic feedback system to improve the user experience. Petitioner asserted that providing confirmation that a gesture was successfully recognized—especially when the external device’s response is not immediate or obvious—would reduce user confusion and frustration. This enhancement was presented as a known method for improving human-computer interaction in the field of wearable devices.
  • Expectation of Success: Petitioner argued a POSITA would have a reasonable expectation of success because integrating a haptic feedback mechanism (as taught by Kruse) into a wearable gesture controller (as taught by Sun) was a straightforward and predictable engineering task. The components and system architectures were well-understood and compatible.

• Additional Grounds: Petitioner asserted additional obviousness challenges, including Kruse in view of Sun for claims 2-5 and 13, which argued for implementing Sun's acceleration thresholds and training mode into Kruse's device. Petitioner also presented a ground that claim 6 is invalid as indefinite under 35 U.S.C. §112, arguing that a "message" itself cannot "perform" a command.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that the Board should not exercise its discretion to deny institution under 35 U.S.C. § 314(a) based on Fintiv factors. The primary reason provided was that there was no pending parallel district court litigation against Petitioner involving the ’701 patent at the time of filing.

5. Relief Requested

• Petitioner requests institution of post-grant review and cancellation of claims 1-7, 11, and 13-20 as unpatentable.