DCT

2:24-cv-01070

Omni MedSci Inc v. Samsung Electronics Co Ltd

Log In
Key Events
Amended Complaint
complaint Intelligence

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:24-cv-01070, E.D. Tex., 08/12/2025
  • Venue Allegations: Venue for foreign defendants Samsung Electronics, Co. Ltd., OnePlus, and Ōura is alleged under 28 U.S.C. § 1391(c)(3). Venue for domestic defendants Samsung Electronics America, Inc. and Fossil is alleged under 28 U.S.C. § 1400(b) based on having a regular and established place of business in the district and having offered for sale or sold accused products to customers in the district.
  • Core Dispute: Plaintiff alleges that Defendants' smartwatches, smart rings, and associated smartphone and cloud platforms infringe seven patents related to the non-invasive optical measurement of physiological parameters.
  • Technical Context: The technology involves using light-based sensors in wearable devices to monitor physiological parameters like heart rate and blood oxygen, a core feature in the growing consumer health and wellness market.
  • Key Procedural History: The filing is a Third Amended Complaint. The complaint details extensive pre-suit communications between Plaintiff's principal, Dr. Islam, and representatives of Samsung and its subsidiaries, beginning in April 2017. During these meetings, Plaintiff alleges it presented its patented technology, including specific identification of the '868, '533, '484, '304, and '455 patents. The complaint also alleges that Ōura had notice of the '455 and '533 patents through its own patenting activities. These allegations form the basis for claims of willful infringement.

Case Timeline

Date Event
2012-12-31 Earliest Priority Date for all Asserted Patents ('868, '533, '484, '304, '455, '790, '475)
2015-06-16 U.S. Patent No. 9,055,868 Issued
2017-04-10 Plaintiff allegedly disclosed '868 Patent to Samsung
2017-05-16 U.S. Patent No. 9,651,533 Issued
2017-07-17 Plaintiff allegedly disclosed '868 and '533 Patents to Samsung
2019-12-31 U.S. Patent No. 10,517,484 Issued
2020-12-29 U.S. Patent No. 10,874,304 Issued
2021-08-26 Plaintiff allegedly disclosed '533, '484, '304 Patents to Samsung subsidiary
2021-10-22 Plaintiff allegedly disclosed '484 and '304 Patents to Samsung subsidiary
2021-11-02 U.S. Patent No. 11,160,455 Issued
2023-03-02 Plaintiff allegedly disclosed '533, '484, '304, '455 Patents to Samsung subsidiary
2025-01-14 U.S. Patent No. 12,193,790 Issued
2025-04-08 U.S. Patent No. 12,268,475 Issued
2025-05-05 Alleged actual notice date for the '475 Patent
2025-08-12 Third Amended Complaint Filed

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

U.S. Patent No. 9,055,868 ("the '868 Patent") - "System and Method for Voice Control of Medical Devices"

Issued June 16, 2015 Compl. ¶68

The Invention Explained

  • Problem Addressed: The patent addresses the lack of flexibility and convenience in prior art optical diagnostic systems, which had limited capabilities for remote operation, control, and data processing Compl. ¶74
  • The Patented Solution: The invention provides a system where a control unit, remote from an optical measurement device, can wirelessly receive physiological data and also accept voice and manual inputs from a user (Compl. ¶74; citing '868 Patent at 1:39-63). This data is transmitted to a host system capable of storing, processing, and communicating the user's status to other remote display devices, thereby enhancing data processing and accessibility (Compl. ¶74; citing '868 Patent at 1:63-2:33).
  • Technical Importance: The technology integrated non-invasive optical sensing with mobile control and remote data management, offering enhanced flexibility in the operation of physiological measurement devices Compl. ¶74

Key Claims at a Glance

  • The complaint asserts at least claims 7 and 9, which depend from independent claim 1 Compl. ¶177 Compl. ¶75
  • The asserted claims comprise a system with the following essential physical components:
    • a light source with semiconductor diodes generating an input light beam Compl. ¶75
    • a lens system to direct the light beam onto a part of a user's body containing blood Compl. ¶75
    • a software application for generating data representing physiological information Compl. ¶75
    • a control system with a touch-screen, wireless transceiver, and, per dependent claim 7, voice/manual inputs and a location sensor Compl. ¶75
    • a host with a digital file for storing wireless data, control logic for processing, and an output for communicating the status to remote display devices Compl. ¶75
  • The complaint notes that asserted dependent claims further recite specific features, such as a multiplexer (claim 8) and adaptation for spectroscopic blood diagnostics (claim 9) Compl. ¶75

U.S. Patent No. 9,651,533 ("the '533 Patent") - "Short-Wave Infrared Super-Continuum Lasers for Detecting Counterfeit or Illicit Drugs and Pharmaceutical Process Control"

Issued May 16, 2017 Compl. ¶78

The Invention Explained

  • Problem Addressed: The patent describes an unmet need for non-invasive physiological measurement techniques (e.g., glucose monitoring) that could provide adequate sensitivity, selectivity, and repeatability, which conventional systems failed to do (Compl. ¶84; citing '533 Patent at 3:47-61; '533 Patent at 3:61-63).
  • The Patented Solution: The invention discloses wearable measurement devices that use brighter light sources with near-infrared wavelengths to increase the signal level from blood constituents (Compl. ¶84; citing '533 Patent at 5:35-47). The system uses pattern matching and spectral fingerprinting to identify different blood constituents and can wirelessly communicate data to a personal device (e.g., a smartphone) and then to the cloud for storage and processing (Compl. ¶84; Compl. ¶85; citing '533 Patent at 4:18-28; '533 Patent at 5:54-6:3).
  • Technical Importance: The technology aimed to improve the signal-to-noise ratio of non-invasive measurements by using higher intensity light and advanced signal processing, yielding more accurate and reliable results than prior art systems Compl. ¶87

Key Claims at a Glance

  • The complaint asserts at least independent claims 11 and 12 Compl. ¶197 Compl. ¶86
  • Claim 11 requires a system with at least:
    • a light source with light emitting diodes generating an optical beam in the 700-2500 nanometer range Compl. ¶86
    • a plurality of lenses to deliver the beam to a sample Compl. ¶86
    • a receiver with filters and detectors to process the reflected beam and generate an output signal Compl. ¶86
    • a personal device to receive, process, store, and display the signal Compl. ¶86
    • a remote device to receive a wirelessly transmitted status from the personal device Compl. ¶86
  • Claim 12 is similar to claim 11 but recites generating the output signal in part by comparing signals at different optical wavelengths, rather than using filters in the receiver Compl. ¶86

U.S. Patent No. 10,517,484 ("the '484 Patent") - "Semiconductor Diodes-Based Physiological Measurement Device with Improved Signal-to-Noise Ratio"

Issued December 31, 2019 Compl. ¶89

Technology Synopsis

The patent addresses the unmet need for non-invasive measurement of bodily functions with sufficient sensitivity, selectivity, and repeatability (Compl. ¶96; citing '484 Patent at 2:57-3:15). The invention improves on prior art systems by synchronizing a detection system to a light source, increasing the light's intensity and pulse rate, and comparing signals when the light source is on versus off to account for ambient light, thereby increasing the signal-to-noise ratio Compl. ¶96 Compl. ¶97

Asserted Claims

At least claims 3, 8, 9, and 10 Compl. ¶238

Accused Features

The accused features include wearable devices, semiconductor light sources, lenses, detectors, smartphones or tablets with wireless receivers, and cloud computing platforms provided by Samsung, OnePlus, and Fossil Compl. ¶99 Compl. ¶¶238, 248, 258

U.S. Patent No. 10,874,304 ("the '304 Patent") - "Semiconductor Source Based Near Infrared Measurement Device with Improved Signal-to-Noise Ratio"

Issued December 29, 2020 Compl. ¶103

Technology Synopsis

Related to the '484 Patent, this invention discloses systems for non-invasive measurement of physiological parameters Compl. ¶109 It improves signal-to-noise ratio by increasing light intensity, modulating light sources, and differencing signals generated when semiconductor sources are on versus off Compl. ¶111 The system includes a light source, a receiver, a smartphone/tablet, and a cloud computing platform Compl. ¶110

Asserted Claims

At least claims 1, 2, 11, 14, 19, and 20 Compl. ¶269

Accused Features

The accused features are the integrated systems of all Defendants, comprising wearable devices, smartphones/tablets, and cloud platforms that perform non-invasive measurements Compl. ¶¶110, 269

U.S. Patent No. 11,160,455 ("the '455 Patent") - "Multi-Wavelength Wearable Device for Non-Invasive Blood Measurements in Tissue"

Issued November 2, 2021 Compl. ¶114

Technology Synopsis

This patent, related to the '484 Patent, describes a system for non-invasive physiological monitoring Compl. ¶120 It aims to increase the signal-to-noise ratio by increasing light intensity or by comparing signals generated when light sources are on versus off Compl. ¶122 Specific claims recite using wavelengths between 600 nm and 1000 nm to measure oxy-hemoglobin and deoxy-hemoglobin Compl. ¶123

Asserted Claims

At least claims 1, 2, 3, and 8 Compl. ¶314

Accused Features

The accused features include the light source, lenses, detection system, and smartphone/tablet components of the systems sold by Samsung, OnePlus, and Fossil Compl. ¶121 Compl. ¶¶314, 324, 334

U.S. Patent No. 12,193,790 ("the '790 Patent") - "Wearable Devices Comprising Semiconductor Diode Light Sources With Improved Signal-to-Noise Ratio"

Issued January 14, 2025 Compl. ¶125

Technology Synopsis

Related to the '484 and '455 patents, this invention describes an optical system with a wearable device for a user's wrist Compl. ¶¶131-132 The system is configured to compensate for signal artifacts and increase signal-to-noise ratio by, for example, increasing light intensity and comparing signals when semiconductor sources are on versus off Compl. ¶133

Asserted Claims

At least claim 7 Compl. ¶345

Accused Features

The accused systems are the optical systems comprising a wearable device, light source, lenses, and detection system made by Samsung, OnePlus, and Fossil Compl. ¶132 Compl. ¶¶345, 355, 365

U.S. Patent No. 12,268,475 ("the '475 Patent") - "Wearable Device for Differential Measurement on Pulse Rate and Blood Flow"

Issued April 8, 2025 Compl. ¶136

Technology Synopsis

This patent is directed to a wearable apparatus for non-invasive physiological monitoring, related to the other asserted patents Compl. ¶¶142, 146 It recites increasing the signal-to-noise ratio by comparing signals when semiconductor sources are on versus off, synchronizing the detection system, and modulating the light source Compl. ¶144

Asserted Claims

At least claims 1, 5-8, and 11-13 Compl. ¶376

Accused Features

The accused features are the wearable devices sold by all Defendants, which include a light source, lenses, optical detectors, and a processor Compl. ¶143 Compl. ¶¶376, 385, 394, 404

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are wearable smart devices and their associated systems provided by each Defendant Compl. ¶54 These include:

  • Samsung: Galaxy Watch series, Galaxy Ring, Samsung Phones, Samsung Tablets, and the Samsung Cloud platform Compl. ¶¶163-166
  • OnePlus: OnePlus Watch series, OnePlus Phones, OnePlus Tablets, and the OnePlus Cloud platform Compl. ¶¶167-168
  • Fossil: Fossil Gen 1 through Gen 6 series smartwatches Compl. ¶170
  • Ōura: Ōura Ring Gen 1 through Gen 4 series smart rings and the Ōura Cloud platform Compl. ¶¶173-174

Functionality and Market Context

The complaint alleges that each Defendant provides an integrated system for physiological monitoring Compl. ¶¶165, 169, 172, 175 A user wears a device (smartwatch or ring) which measures parameters such as heartbeat and blood oxygen level using hardware components like optical sensors (e.g., Samsung's "BioActive sensor") Compl. ¶¶163, 165 The device then transfers this information to a compatible mobile application on a smartphone or tablet, which in turn can transfer the data to a cloud computing platform for storage, processing, and display Compl. ¶¶165, 169, 172, 175 The complaint alleges that Defendants actively market and support these integrated systems through their websites and other channels Compl. ¶¶163, 167, 170, 173

IV. Analysis of Infringement Allegations

The complaint provides infringement allegations in exhibits incorporated by reference, which are not included in the provided document (Compl. ¶178, Compl. ¶188, Compl. ¶191, Compl. ¶194, Compl. ¶198, Compl. ¶etc.). Therefore, a claim chart table cannot be constructed. The narrative infringement theory is summarized below.

No probative visual evidence provided in complaint.

'868 Patent Infringement Allegations

The complaint alleges that Defendants directly and indirectly infringe at least claims 7 and 9 by making, using, and selling diagnostic systems that embody the claimed inventions Compl. ¶177 Compl. ¶179 The infringement theory posits that the combination of a Defendant's smartwatch/ring (the "optical measurement device"), a corresponding smartphone/tablet (the "control system"), and a cloud backend (the "host") forms the claimed infringing system Compl. ¶¶177, 180 End-users are alleged to directly infringe by assembling and using these components together as intended to measure, monitor, and track their health information Compl. ¶180 Compl. ¶181

'533 Patent Infringement Allegations

The complaint alleges direct and indirect infringement of at least claims 11 and 12 Compl. ¶197 Compl. ¶199 The theory asserts that Defendants' systems-comprising a smartwatch or smart ring (the measurement device with a light source, lenses, and receiver), a smartphone (the "personal device"), and a cloud service (the "remote device")-embody the elements of the claims Compl. ¶¶86, 197 Users are alleged to directly infringe by combining and using these components to measure physiological parameters, with the data being processed and stored across the phone and cloud as claimed Compl. ¶200

Identified Points of Contention

  • Scope Questions: A central issue may be whether the term "medical devices" as used in the '868 Patent can be construed to cover general-purpose consumer wellness products like smartwatches and smart rings, as opposed to traditional clinical diagnostic tools Compl. ¶68 Similarly, for the '533 Patent, which is titled for detecting counterfeit drugs and pharmaceutical process control, a dispute may arise over whether its claims can extend to physiological sensing in consumer electronics Compl. ¶78
  • Technical Questions: A key technical question will be whether the specific hardware and software architecture of the accused products maps onto the claimed elements. For instance, for the '868 Patent, a question is whether a Defendant's cloud service performs the specific functions of the claimed "host" and whether a smartphone performs the functions of the claimed "control system" Compl. ¶75 For the '533 Patent, a technical question is whether the accused devices' light sources operate within the claimed wavelength range of 700 to 2500 nanometers Compl. ¶86

V. Key Claim Terms for Construction

Term ('868 Patent): "medical devices"

Context and Importance

The '868 Patent is titled "System and Method for Voice Control of Medical Devices" Compl. ¶68 Practitioners may focus on this term because its construction will determine whether the patent's scope is limited to traditional clinical equipment or is broad enough to cover the accused consumer-grade smartwatches and rings marketed for general wellness Compl. ¶10 Compl. ¶30

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The complaint describes the patented invention as improving "optical diagnostic systems" for "non-invasive optical measurement of physiological parameters," language which may support application beyond a formal clinical setting Compl. ¶74 Compl. ¶76
  • Evidence for a Narrower Interpretation: The patent title itself explicitly uses the term "Medical Devices," which may suggest a narrower scope tied to regulated healthcare apparatus, rather than general consumer electronics Compl. ¶68

Term ('868 Patent): "host"

Context and Importance

Practitioners may focus on this term because claim 1 requires a "host" that is distinct from the "control system" and performs specific functions like storing wireless data and processing it to generate a user "status" Compl. ¶75 The infringement theory maps this to Defendants' cloud platforms Compl. ¶11 Compl. ¶178 The term's construction will be critical to determining if a distributed cloud service architecture meets the requirements of a singular "host" as described in the patent.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The specification's description of the host as "receiving, storing, and processing wireless data" and communicating information to "remote display devices" could be argued to align with the functions of a modern cloud computing platform Compl. ¶74
  • Evidence for a Narrower Interpretation: The patent language of a "host" with a "digital file for storing" data might be argued to contemplate a more localized, singular computer or server, rather than a diffuse, multi-server cloud environment Compl. ¶75

Term ('533 Patent): "a sample"

Context and Importance

The '533 Patent is titled in the context of detecting counterfeit drugs and pharmaceutical process control, suggesting the "sample" is an external substance being analyzed Compl. ¶78 Practitioners may focus on this term because infringement hinges on whether it can be construed to cover in-vivo, non-invasive measurement of human tissue, as is performed by the accused smartwatches Compl. ¶84

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The specification discloses using the technology to "identify different constituents in the blood," which may support an interpretation that includes in-vivo analysis of human tissue as the "sample" Compl. ¶84
  • Evidence for a Narrower Interpretation: The patent's title and background relating to "Counterfeit or Illicit Drugs and Pharmaceutical Process Control" may support a narrower construction limited to ex-vivo analysis of chemical or pharmaceutical substances Compl. ¶78

VI. Other Allegations

Indirect Infringement

The complaint alleges both induced infringement and contributory infringement against all Defendants for all asserted patents (e.g., '868 Patent, Compl. ¶¶179, 184). Inducement is primarily based on Defendants allegedly providing instructions, documentation, marketing materials, and technical support that encourage and enable end-users to combine the separate components (wearable, phone, cloud) and use them in an infringing manner Compl. ¶¶182, 202 Contributory infringement is based on allegations that Defendants provide components that are especially made or adapted for use in the infringing system and are not staple articles of commerce suitable for substantial non-infringing use Compl. ¶¶184, 204

Willful Infringement

The complaint alleges willful infringement against all Defendants, asserting that the infringement was and continues to be "intentional and deliberate" Compl. ¶186 The basis for willfulness includes alleged pre-suit knowledge from direct meetings between Plaintiff and Samsung Compl. ¶¶148-160, alleged notice to Ōura from its own patenting activities Compl. ¶161, and notice to all Defendants from the filing of the original and subsequent complaints Compl. ¶147

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

  1. A central issue will be one of definitional scope: Can terms rooted in specific technical fields, such as "medical devices" from the '868 Patent and concepts from a patent on "detecting counterfeit drugs" ('533 Patent), be construed broadly enough to cover the accused general-purpose consumer wellness smartwatches and rings?
  2. A key question of claim construction and mapping will be whether the Defendants' distributed product ecosystems-comprising a wearable device, a smartphone app, and a cloud service-satisfy the distinct structural elements of a "control system" and a "host" as required by the '868 Patent's claims, or a "personal device" and a "remote device" as required by the '533 Patent's claims.
  3. A pivotal issue for damages will be one of willfulness: Does the complaint's detailed narrative of pre-suit meetings between Plaintiff and Samsung executives, where specific patents were allegedly discussed, provide a sufficient factual basis to establish pre-suit knowledge and support a finding of willful infringement?
Loading Amended Complaint