DCT

2:26-cv-00472

Omni MedSci Inc v. OnePlus Technology Shenzhen Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:24-cv-01070, E.D. Tex., 06/12/2026
  • Venue Allegations: Venue is alleged to be proper for foreign defendants Samsung Electronics Co. Ltd., OnePlus, and Õura Health Oy under 28 U.S.C. § 1391(c)(3). For domestic defendants Samsung Electronics America and Fossil entities, venue is alleged to be proper under 28 U.S.C. § 1400(b) based on offering to sell or selling accused products to customers in the district and having a regular and established place of business in the district.
  • Core Dispute: Plaintiff alleges that Defendants' smartwatches, smart rings, and associated smartphone and cloud-based systems infringe seven U.S. patents related to the non-invasive optical measurement of physiological parameters.
  • Technical Context: The technology involves using light-based sensors in wearable consumer devices to measure biological metrics like heart rate and blood oxygen, a key feature in the rapidly growing health and wellness technology market.
  • Key Procedural History: The complaint alleges that Samsung had pre-suit knowledge of several asserted patents through a series of meetings and communications between Plaintiff's principal, Dr. Islam, and various Samsung executives and managers beginning in April 2017. It also alleges that Õura Health Oy had pre-suit notice of two asserted patents via a reference in one of Oura's own issued patents. These allegations of pre-suit knowledge are positioned to support claims for willful infringement.

Case Timeline

Date Event
2012-12-31 Earliest Priority Date for '533, '484, '304, '455, '790, and '475 Patents; Filing of initial patent applications by Omni MedSci
2015-06-16 '868 Patent Issued
2017-04-10 Plaintiff alleges meeting between Dr. Islam and Dr. Hong of Samsung where '868 Patent was discussed
2017-05-16 '533 Patent Issued
2017-07-17 Plaintiff alleges virtual meeting with Samsung manager where '868 and '533 Patents were discussed
2019-12-31 '484 Patent Issued
2020-12-29 '304 Patent Issued
2021-08-26 Plaintiff alleges meeting with Samsung subsidiary manager where '533, '484, and '304 Patents were identified
2021-10-22 Plaintiff alleges meeting where '484 and '304 Patents were presented
2021-11-02 '455 Patent Issued
2023-03-02 Plaintiff alleges meeting where '533, '484, '304, and '455 Patents were presented
2024-06-18 U.S. Patent No. 12,013,725 issues to Ōuraring Inc., allegedly providing notice of '455 and '533 Patents
2025-01-14 '790 Patent Issued
2025-04-08 '475 Patent Issued
2025-05-05 Plaintiff alleges Defendants had actual notice of the '475 Patent
2026-06-12 Third Amended Complaint Filed

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

U.S. Patent No. 9,055,868 - System and Method for Voice Control of Medical Devices

  • Patent Identification: U.S. Patent No. 9,055,868, "System and Method for Voice Control of Medical Devices," issued June 16, 2015 Compl. ¶68

The Invention Explained

  • Problem Addressed: The patent addresses the need for greater flexibility and convenience in operating and controlling physiological measurement devices, particularly from remote locations Compl. ¶74
  • The Patented Solution: The patent describes a system architecture combining an optical measurement device with a remote control system (such as a smartphone) that can wirelessly receive physiological data and also accept user inputs via voice or manual entry '868 Patent, 1:39-63 Compl. ¶74 This system connects to a host (such as a cloud server) that receives, stores, and processes the data, and can then communicate status information to other remote display devices '868 Patent, 1:63-2:33 Compl. ¶74
  • Technical Importance: This invention provided a framework for integrating wearable health sensors with the broader ecosystem of personal smart devices and cloud computing for enhanced data processing and accessibility Compl. ¶74

Key Claims at a Glance

  • The complaint asserts at least independent claim 7 and dependent claim 9 (Compl. ¶177).
  • The essential elements of independent claim 7, as summarized in the complaint, include Compl. ¶75:
    • A light source with semiconductor diodes for an input light beam.
    • A lens system to communicate the light beam to a user's body part containing blood.
    • A software application on a control system for generating physiological data.
    • A control system with touch-screen, voice, and manual inputs, circuitry for position information, and a wireless transceiver.
    • A host with a digital file for storing wireless data, control logic for processing data to generate a user status, and an output for communicating the status to remote display devices.
  • The complaint does not explicitly reserve the right to assert other claims but notes the selection is exemplary (Compl. ¶178).

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

  • Patent Identification: U.S. Patent No. 9,651,533, "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 identifies an unmet need for non-invasive physiological measurement techniques (e.g., glucose monitoring) that have adequate sensitivity, selectivity, and repeatability, which conventional systems lacked '533 Patent, 3:47-63 Compl. ¶84
  • The Patented Solution: The patent discloses using brighter light sources, including those with near-infrared wavelengths, to increase the signal level from blood constituents '533 Patent, 5:35-47 Compl. ¶84 The system includes a wearable measurement device, a personal device (e.g., a smartphone) for initial processing, and a remote device (e.g., a cloud platform) for storage and further processing, with data transmitted wirelessly between them '533 Patent, 5:54-6:3 '533 Patent, 26:27-56 Compl. ¶85
  • Technical Importance: The invention aimed to yield more accurate and reliable non-invasive physiological measurements by using techniques that generate a greater signal-to-noise ratio than prior art systems Compl. ¶87

Key Claims at a Glance

  • The complaint asserts at least claims 11 and 12 (Compl. ¶197).
  • The essential elements of these claims, as summarized in the complaint, include Compl. ¶86:
    • A light source with light emitting diodes generating an optical beam in the 700-2500 nanometer wavelength range.
    • A plurality of lenses to deliver an analysis beam to a sample.
    • A receiver to process the reflected beam and generate an output signal.
    • A personal device to receive, process, store, and display the signal.
    • A remote device to receive a wirelessly transmitted status and process it.
    • Claim 11 adds one or more filters at the receiver.
    • Claim 12 adds the capability to compare signals at different optical wavelengths.
  • The complaint does not explicitly reserve the right to assert other claims but notes the selection is exemplary (Compl. ¶198).

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

  • Patent Identification: U.S. Patent No. 10,517,484, "Semiconductor Diodes-Based Physiological Measurement Device with Improved Signal-to-Noise Ratio," issued December 31, 2019 (Compl. ¶89).
  • Technology Synopsis: The patent addresses the need for non-invasive measurement of bodily functions with better sensitivity and repeatability (Compl. ¶96). The solution improves the signal-to-noise ratio by increasing the intensity and pulse rate of a light source and comparing signals generated when the source is on versus off, which helps account for ambient light changes (Compl. ¶¶96-97). This data is then communicated wirelessly from a wearable device to a smartphone and a cloud platform (Compl. ¶98).
  • Asserted Claims: At least claims 3, 8, 9, and 10 are asserted (Compl. ¶238). Independent claims appear to be 3 and 8 (Compl. ¶99).
  • Accused Features: The accused features include smartwatches, phones, tablets, and cloud systems that allegedly form an infringing system for measuring physiological parameters (Compl. ¶¶99; Compl. ¶239).

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

  • Patent Identification: U.S. Patent No. 10,874,304, "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 patent expands on solutions for non-invasive physiological measurement (Compl. ¶109). It describes a system comprising a light source, a receiver for reflected light, a smartphone/tablet, and a cloud platform (Compl. ¶110). The invention improves signal-to-noise ratio by increasing light intensity, modulating light sources, or differencing signals captured when the light source is on versus off (Compl. ¶111).
  • Asserted Claims: At least claims 1, 2, 11, 14, 19, and 20 are asserted (Compl. ¶269). Independent claims appear to be 1, 11, and 19 (Compl. ¶110).
  • Accused Features: The accused systems comprise smartwatches, smart rings, phones, tablets, and cloud platforms (Compl. ¶269).

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

  • Patent Identification: U.S. Patent No. 11,160,455, "Multi-Wavelength Wearable Device for Non-Invasive Blood Measurements in Tissue," issued November 2, 2021 (Compl. ¶114).
  • Technology Synopsis: Also related to the '484 Patent, this invention describes a system with a light source, lenses, and a detection system with spaced detectors to generate a physiological signal (Compl. ¶121). The system improves signal-to-noise ratio by increasing light intensity or comparing signals when the light source is on versus off, and communicates the resulting data to a smartphone or tablet (Compl. ¶¶121-122).
  • Asserted Claims: At least claims 1, 2, 3, and 8 are asserted (Compl. ¶314). Independent claims appear to be 1, 8, and 15 (Compl. ¶121).
  • Accused Features: The accused systems comprise smartwatches, phones, tablets, and cloud platforms (Compl. ¶314).

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

  • Patent Identification: U.S. Patent No. 12,193,790, "Wearable Devices Comprising Semiconductor Diode Light Sources With Improved Signal-to-Noise Ratio," issued January 14, 2025 (Compl. ¶125).
  • Technology Synopsis: Also related to the '484 and '455 Patents, this invention describes a wrist-worn wearable device with semiconductor diodes, lenses, and spaced detectors (Compl. ¶¶131-132). The system is configured to increase the signal-to-noise ratio by, for example, increasing light intensity and comparing signals when the light source is on versus off (Compl. ¶133).
  • Asserted Claims: At least claim 7 is asserted (Compl. ¶345). Claim 7 is an independent claim (Compl. ¶132).
  • Accused Features: The accused systems are infringing optical systems, including smartwatches (Compl. ¶345).

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

  • Patent Identification: U.S. Patent No. 12,268,475, "Wearable Device for Differential Measurement on Pulse Rate and Blood Flow," issued April 8, 2025 (Compl. ¶136).
  • Technology Synopsis: Related to the preceding patents, this invention is directed to a wearable apparatus with a light source (LEDs), lenses, optical detectors, and a processor (Compl. ¶143). It improves the signal-to-noise ratio by comparing on/off signals, synchronizing detection to the light source, and modulating the source (Compl. ¶144).
  • Asserted Claims: At least claims 1, 5-8, and 11-13 are asserted (Compl. ¶376). Independent claims appear to be 1, 5, and 8 (Compl. ¶143).
  • Accused Features: The accused devices include smartwatches and smart rings, along with associated systems (Compl. ¶376).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are wearable health monitoring systems sold by the various Defendants. These systems are alleged to comprise a wearable device (e.g., Samsung Galaxy Watch, Samsung Galaxy Ring, OnePlus Smartwatch, Fossil Smartwatch, Õura Ring), a personal computing device running a specific application (e.g., a Samsung Phone with the Samsung Health App), and a corresponding cloud computing platform (e.g., Samsung Cloud) Compl. ¶¶163-175

Functionality and Market Context

  • The complaint alleges that when a user wears one of the accused devices, it measures physiological parameters such as heartbeat and blood oxygen level using hardware components like a "BioActive sensor" (Samsung) Compl. ¶¶165; Compl. ¶166 This information is then transferred to a compatible smartphone or tablet app, which in turn can transfer the data to a cloud platform for storage, processing, and display Compl. ¶¶165; Compl. ¶169; Compl. ¶172; Compl. ¶175 Defendants are alleged to actively market and support these integrated systems through their websites and other channels, selling them to retailers, distributors, and directly to consumers Compl. ¶¶163; Compl. ¶167; Compl. ¶170; Compl. ¶173

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references, but does not include, claim chart exhibits detailing its infringement allegations (Compl. ¶178; Compl. ¶198). The following table summarizes the infringement theory for the lead patents based on the narrative provided in the complaint.

'868 Patent Infringement Allegations

Claim Element (from Independent Claim 7) Alleged Infringing Functionality Complaint Citation Patent Citation
a light source comprising one or more semiconductor diodes generating an input light beam and a lens system The accused smartwatches and rings contain optical sensors, such as Samsung's "BioActive sensor," which use light-emitting diodes to shine light onto the user's skin. ¶165 '868 Patent, 1:39-63
a software application associated with a control system for generating data representing physiological information The accused systems include software applications (e.g., Samsung Health App) on smartphones that receive and process sensor data. ¶165 '868 Patent, 1:39-63
the control system having a touch-screen, voice and manual inputs capabilities... and a wireless transceiver The control system is alleged to be the associated smartphone, which has a touchscreen, voice assistant capabilities, and wireless transceivers (e.g., Bluetooth, Wi-Fi). ¶165 '868 Patent, 1:39-63
a host comprising a digital file for storing wireless data, control logic to process the wireless data to generate a stats of the user, and an output for communicating a portion of the status...to one or more remotely located display output devices The accused systems include cloud platforms (e.g., Samsung Cloud) that receive, process, and store user health data, and can communicate that data to other devices. ¶165 '868 Patent, 1:63-2:33

'533 Patent Infringement Allegations

Claim Element (from Independent Claim 11/12) Alleged Infringing Functionality Complaint Citation Patent Citation
a light source comprising light emitting diodes for generating an output optical beam with one or more optical wavelengths including at least a portion being in the wavelength range of between 700 and 2500 nanometers The accused wearables use light-emitting diodes to generate optical beams for measuring physiological parameters like blood oxygen, which involves wavelengths in the near-infrared spectrum. ¶163 '533 Patent, 5:35-47
a plurality of lenses...an delivering an analysis output beam to a sample The wearable devices' sensor modules contain lenses to direct the optical beam onto the user's tissue (the alleged "sample"). ¶165 '533 Patent, 5:47-54
a receiver to receive and process a portion of the analysis output beam reflected from the sample to generate an output signal The wearable devices' sensors detect and process the light reflected from the user's tissue to generate a signal indicative of physiological parameters. ¶165 '533 Patent, 5:47-54
a personal device configured to receive and process a portion of the output signal and to store and display the processed output signal The associated smartphone and application (e.g., OnePlus Health app) are configured to receive, process, and display the data from the wearable. ¶168 '533 Patent, 5:54-6:3
a remote device configured to receive a wirelessly transmitted output status...and to process the received output status The associated cloud platforms (e.g., Õura Cloud) are configured to receive data wirelessly from the personal device and process it. ¶174 '533 Patent, 26:27-56
  • Identified Points of Contention:
    • Scope Questions: The title of the '868 Patent is "System and Method for Voice Control of Medical Devices." A potential dispute is whether the accused consumer smartwatches and rings, which are primarily wellness products, qualify as "medical devices" within the meaning of the claims Compl. ¶68 Similarly, the title of the '533 Patent relates to detecting "Counterfeit or Illicit Drugs," which raises the question of whether its claims can be read to cover the non-invasive measurement of physiological parameters, despite specification support for the latter Compl. ¶78 Compl. ¶84
    • Technical Questions: A central technical question will be whether the accused products perform the specific signal-to-noise ratio enhancement techniques claimed in the '484, '304, '455, '790, and '475 patents. These patents claim methods such as increasing light intensity from a baseline and comparing signals when the light source is on versus off (Compl. ¶96; Compl. ¶111; Compl. ¶122; Compl. ¶133; Compl. ¶144). The litigation will likely require discovery into the precise operational details of the defendants' optical sensors to determine if they practice these claimed methods.

V. Key Claim Terms for Construction

  • For the '868 Patent:

    • The Term: "medical devices"
    • Context and Importance: The construction of this term is critical as the accused products are mass-market consumer electronics, not traditional, regulated medical devices Compl. ¶68 Compl. ¶¶163-175 Practitioners may focus on this term because a narrow construction limited to FDA-approved or clinical devices could be dispositive of infringement for the '868 patent.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The complaint alleges the invention provides for "control of physiological measurement devices" generally, which may support a broader reading beyond just clinical or regulated devices Compl. ¶74
      • Evidence for a Narrower Interpretation: The patent's title, "System and Method for Voice Control of Medical Devices," and potential language in the specification or prosecution history could be used to argue for a narrower definition tied to a clinical or diagnostic context, as distinguished from consumer wellness products Compl. ¶68

  • For the '533 Patent:

    • The Term: "a sample"
    • Context and Importance: The patent's title refers to detecting drugs and process control, suggesting "a sample" could be a pill or powder Compl. ¶78 Plaintiff asserts the claims against devices that measure blood constituents in a user's tissue Compl. ¶84 The construction of "a sample" will therefore be central to whether the claim scope can bridge the gap from pharmaceutical quality control to physiological monitoring.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification explicitly discloses using the technology to "increase the signal level from blood constituents" and discusses "wearable measurement devices," which strongly suggests "a sample" can encompass human tissue containing blood ('533 Patent, 5:35-47, cited in Compl. ¶84). The abstract of the related '484 Patent describes a "wearable device...to be placed on a wrist or an ear of a user" '484 Patent, abstract
      • Evidence for a Narrower Interpretation: Defendants may argue that the term "a sample," when read in light of the '533 patent's title ("Detecting Counterfeit or Illicit Drugs and Pharmaceutical Process Control"), should be limited to non-biological, ex-vivo items like pills or chemical batches Compl. ¶78

VI. Other Allegations

  • Indirect Infringement: Plaintiff alleges that all Defendants actively induce infringement by providing customers with the components of the accused systems (wearables, apps, cloud services) along with instructions, manuals, marketing, and technical support that encourage and enable users to combine them into an infringing system Compl. ¶¶182; Compl. ¶202; Compl. ¶222; Compl. ¶243; Compl. ¶275; Compl. ¶297; Compl. ¶308; Compl. ¶319; Compl. ¶339; Compl. ¶350; Compl. ¶370; Compl. ¶380; Compl. ¶399; Compl. ¶409 The complaint also alleges contributory infringement, stating the provided components are especially made or adapted for use in an infringing manner and are not staple articles of commerce Compl. ¶¶184; Compl. ¶204
  • Willful Infringement: The willfulness allegations are based on alleged pre-suit and post-suit knowledge. For Samsung, pre-suit knowledge is alleged based on a series of specific meetings starting in April 2017 where Dr. Islam, Plaintiff's principal, allegedly presented the patented technology, including the '868, '533, '484, '304, and '455 patents, to Samsung executives Compl. ¶¶148-160 For Õura, pre-suit knowledge of the '455 and '533 patents is alleged based on their citation in an Oura-owned patent Compl. ¶161 For all Defendants, continued infringement after receiving notice via the original and amended complaints is alleged as a basis for willfulness Compl. ¶147

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

  • A core issue will be one of definitional scope: can terms like "medical device" from a patent focused on voice control ('868 Patent) and "a sample" from a patent family titled for detecting counterfeit drugs ('533 Patent) be construed broadly enough to cover the accused consumer wellness smartwatches and the measurement of physiological parameters in human tissue?
  • A key evidentiary question will be one of operational equivalence: does the accused hardware and software, as a system, actually perform the specific signal-to-noise enhancement techniques recited in the patents, such as increasing light intensity from a baseline and comparing signals generated when the light source is on versus off? The complaint's allegations of infringement hinge on these detailed technical functions, which will require significant fact discovery.
  • A third central question will concern willfulness, particularly for Samsung. The complaint's detailed narrative of pre-suit meetings between the inventor and Samsung executives, if substantiated, could provide a strong basis for finding willful infringement and potential enhanced damages, making the pre-filing conduct of the parties a critical element of the case.
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