Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 1 of 140 PageID #:
`1061
`
`EXHIBIT 11
`
`

`

`
`
`
`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 2 of 140 PageID #:
`1062
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`1[pre] A system for
`Without conceding that the preamble of Claim 1 of the ’455 Patent is limiting, Whoop Inc. (“Whoop”) has
`measuring one or
`made, used, offered to sell, sold in the United States, and/or has imported into the United States, and/or,
`more physiological
`continues to make, use, offer to sell, and sell within the United States, and/or import into the United States,
`parameters and for
`Accused Systems for measuring one or more physiological parameters and for use with a smart phone or
`use with a smart
`tablet, either literally or under the doctrine of equivalents.
`phone or tablet, the
`
`For example, Whoop provides a system including WHOOP 4.0, which measures physiological
`system comprising:
`parameters of a user, such as heart rate, blood oxygen level, temperature, and respiratory rate. WHOOP
`4.0 connects to an Accused Phone/Tablet via Bluetooth to sync data corresponding to measured
`physiological parameters. After downloading the Whoop App on an Accused Phone/Tablet and completing
`the initial Bluetooth pairing, WHOOP 4.0 transfers measured health data to the app whenever in range to the
`Accused Phone/Tablet. The app processes and analyzes the measured physiological parameters and provides
`insights into the user’s health and wellness.
`
`Whoop further offers and sells a membership-based service along with the Accused Wearable Device,
`where users pay a subscription fee for access to the Whoop App, data analysis, and health and wellness
`insights. The membership provides access to Whoop’s platform; a user must purchase the add-on Whoop
`membership in addition to an Accused Wearable Device to access all of the health features of the Accused
`Wearable Device.
`
`
`
`1 The Accused System includes a Whoop wearable device, such as WHOOP 1.0, WHOOP 2.0, WHOOP 3.0, and WHOOP 4.0 (each an
`“Accused Wearable Device”); a smartphone or tablet (an “Accused Phone/Tablet”), and a cloud (an “Accused Cloud”), which
`collectively provide a system for measuring one or more physiological parameters of a user. Smart phones and tablets from various
`manufacturers, such as Samsung, Apple, and OnePlus, and clouds provided by others, such as Strava and dbt Labs, may also be used as
`part of the Accused System. WHOOP 4.0 and various smart phones are charted here as representative of the Accused System and should
`not be understood to be limiting. The citations to evidence contained within this chart are illustrative and should not be understood to
`be limiting. Plaintiff expressly reserves the right to rely upon additional or different evidence, or to rely on additional citations to the
`evidence already cited herein.
`
`Ex. 11
`
`
`
`
`1
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 3 of 140 PageID #:
`1063
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`Source: https://discover.whoop.com/health-monitoring/.
`
`
`
`
`Ex. 11
`
`
`
`
`2
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 4 of 140 PageID #:
`1064
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`Source: https://www.whoop.com/us/en/.
`
`
`
`
`Ex. 11
`
`
`
`
`3
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 5 of 140 PageID #:
`1065
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`Source: https://join.whoop.com/us/en/membership/.
`
`
`
`
`Ex. 11
`
`
`
`
`4
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 6 of 140 PageID #:
`1066
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`Source: https://discover.whoop.com/health-monitoring/.
`
`
`
`
`Ex. 11
`
`
`
`
`5
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 7 of 140 PageID #:
`1067
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`Source: https://www.whoop.com/us/en/thelocker/measure-normal-blood-oxygen-levels/.
`
`
`
`
`Ex. 11
`
`
`
`
`6
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 8 of 140 PageID #:
`1068
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`Source: https://www.whoop.com/us/en/thelocker/measure-normal-blood-oxygen-levels/.
`
`
`
`
`Ex. 11
`
`
`
`
`7
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 9 of 140 PageID #:
`1069
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`
`
`
`
`
`
`Source: https://support.whoop.com/s/article/WHOOP-App-Minimum-Software-
`Requirements?language=en_US.
`
`
`Ex. 11
`
`
`
`
`8
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 10 of 140 PageID #:
`1070
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`
`Ex. 11
`
`
`
`
`9
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 11 of 140 PageID #:
`1071
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`
`
`
`Ex. 11
`
`
`
`
`10
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 12 of 140 PageID #:
`1072
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`
`Ex. 11
`
`
`
`
`11
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 13 of 140 PageID #:
`1073
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`Source: https://www.youtube.com/watch?v=pj5VWkAgyME&t=2s.
`
`
`
`
`
`
`
`
`
`
`
`Ex. 11
`
`
`
`
`12
`
`’455 Patent – Whoop
`
`

`

`
`
`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 14 of 140 PageID #:
`1074
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`1[a] a wearable
`The Accused System comprises a wearable device adapted to be placed on teeth, a wrist, or an ear of a
`user, and including a light source comprising a driver and a plurality of semiconductor sources, either
`device adapted to be
`placed on teeth, a
`literally or under the doctrine of equivalents.
`wrist, or an ear of a
`
`For example, the WHOOP 4.0 (“wearable device”) is adapted to be and is placed on a wrist of a user.
`user, and including a
`The WHOOP 4.0 includes a light source that comprises multiple LEDs, such as a green LED, red LED, and
`light source
`an infrared LED (“plurality of semiconductor sources”) as well as a driver.
`comprising a driver
`and a plurality of
`
`semiconductor
`sources,
`
`
`Source: https://discover.whoop.com/health-monitoring/.
`
`
`
`
`Ex. 11
`
`
`
`
`13
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 15 of 140 PageID #:
`1075
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`
`Ex. 11
`
`
`
`
`14
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 16 of 140 PageID #:
`1076
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`Source: https://www.youtube.com/watch?v=cxVN6zSjWPc.
`
`
`
`
`Ex. 11
`
`
`
`
`15
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 17 of 140 PageID #:
`1077
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`Source: https://www.youtube.com/watch?v=rlEsoMy-l4w.
`
`
`
`
`Ex. 11
`
`
`
`
`16
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 18 of 140 PageID #:
`1078
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`Source: https://www.youtube.com/watch?v=cxVN6zSjWPc.
`
`
`
`
`Ex. 11
`
`
`
`
`17
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 19 of 140 PageID #:
`1079
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`Source: https://www.whoop.com/us/en/difference/.
`
`
`
`
`Ex. 11
`
`
`
`
`18
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 20 of 140 PageID #:
`1080
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`Source: https://www.whoop.com/us/en/thelocker/measure-normal-blood-oxygen-levels/.
`
`
`
`
`Source: https://www.whoop.com/us/en/thelocker/a-look-behind-the-data-how-whoop-measures-heart-rate/.
`
`19
`
`’455 Patent – Whoop
`
`
`
`Ex. 11
`
`
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 21 of 140 PageID #:
`1081
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`
`
`Ex. 11
`
`
`
`
`20
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 22 of 140 PageID #:
`1082
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`
`
`Source: Product Teardown (WHOOP 4.0)
`
` A
`
` product teardown of WHOOP 4.0 reveals that it features, among other components, a pulse
`oximeter/heart rate sensor manufactured by Analog Devices (formerly Maxim Integrated) (e.g.,
`“MAX86171”). The sensor includes LED drivers.
`
`
`Ex. 11
`
`
`
`
`21
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 23 of 140 PageID #:
`1083
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`Source: https://www.analog.com/media/en/technical-documentation/data-sheets/MAX86171.pdf
`
`In the Accused Wearable Device, the plurality of semiconductor sources are configured to generate an
`output optical light having a plurality of optical wavelengths, either literally or under the doctrine of
`equivalents.
`
`For example, WHOOP 4.0 includes multiple LEDs (“semiconductor sources”), such as a green LED, a red
`LED, and an infrared LED. Different color LEDs and infrared LEDs each generate output optical light
`having different optical wavelengths (“a plurality of optical wavelengths”).
`
`22
`
`’455 Patent – Whoop
`
`1[b] the plurality of
`semiconductor
`sources configured
`to generate an output
`optical light having
`a plurality of optical
`wavelengths;
`
`Ex. 11
`
`
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 24 of 140 PageID #:
`1084
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`
`Source: https://www.youtube.com/watch?v=rlEsoMy-l4w.
`
`23
`
`
`
`’455 Patent – Whoop
`
`Ex. 11
`
`
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 25 of 140 PageID #:
`1085
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`
`Source: https://www.youtube.com/watch?v=cxVN6zSjWPc.
`
`“While the most familiar pulse oximeters are those that are placed on your finger, the same technology is
`utilized in many other devices, including the WHOOP 4.0, to monitor blood oxygen levels from the wrist.
`
`
`
`Ex. 11
`
`
`
`
`24
`
`’455 Patent – Whoop
`
`

`

`
`
`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 26 of 140 PageID #:
`1086
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`The WHOOP 4.0 does this by sending two wavelengths of light (red and infrared) through your skin
`where it is absorbed and reflected by blood vessels.”
`
`Source: https://www.whoop.com/us/en/thelocker/measure-normal-blood-oxygen-levels/.
`
`“WHOOP measures heart rate using advanced optical sensors with photoplethysmography (PPG)
`technology. It works by emitting green LED light into the skin, and then measuring the light that’s
`reflected back.”
`
`Source: https://www.whoop.com/us/en/thelocker/a-look-behind-the-data-how-whoop-measures-heart-rate/.
`
`LEDs outputting light at different colors do so at different optical wavelengths. For example, a green LED, a
`red LED, and an infrared LED all output light at different optical wavelengths:
`
`
`Ex. 11
`
`
`
`
`25
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 27 of 140 PageID #:
`1087
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`Source: https://www.photonics.com/Articles/Light-Emitting_Diodes_A_Primer/a36706.
`
`
`
`
`
`
`
`
`Ex. 11
`
`
`
`
`26
`
`’455 Patent – Whoop
`
`

`

`
`
`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 28 of 140 PageID #:
`1088
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`1[c] the wearable
`The Accused System comprises a wearable device comprising one or more lenses configured to receive
`at least a portion of the output optical light and to deliver a lens output light to tissue, either literally or
`device comprising
`one or more lenses
`under the doctrine of equivalents.
`configured to
`
`For example, the Accused Wearable Device (“wearable device”) comprises one or more lenses positioned
`receive at least a
`between each LED and the wrist of a user when worn by the user. The lenses receive output optical light
`portion of the output
`from the LEDs and deliver the lens output light to tissue of the user (e.g., skin, blood vessels, veins).
`optical light and to
`deliver a lens output
`
`light to tissue;
`
`
`Source: https://discover.whoop.com/health-monitoring/.
`
`
`
`
`Ex. 11
`
`
`
`
`27
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 29 of 140 PageID #:
`1089
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`Source: https://www.whoop.com/us/en/difference/.
`
`
`
`
`
`Source: https://www.whoop.com/us/en/thelocker/a-look-behind-the-data-how-whoop-measures-heart-rate/.
`
`
`
`
`Ex. 11
`
`
`
`
`28
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 30 of 140 PageID #:
`1090
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`
`
`Source: https://www.whoop.com/us/en/thelocker/measure-normal-blood-oxygen-levels/.
`
` A
`
` product teardown of WHOOP 4.0 reveals that it features, among other components, a pulse
`oximeter/heart rate sensor manufactured by Analog Devices (formerly Maxim Integrated) (e.g.,
`“MAX86171”).
`
`
`Ex. 11
`
`
`
`
`29
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 31 of 140 PageID #:
`1091
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`Source: https://www.techinsights.com/products/ddt-2111-806.
`
`
`
`
`Maxim Integrated MAX86171
`
`Source: Product Teardown (WHOOP 4.0)
`
`
`
`
`
`Ex. 11
`
`
`
`
`30
`
`’455 Patent – Whoop
`
`

`

`
`
`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 32 of 140 PageID #:
`1092
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`The product data sheet for MAX86171, shown below, states that MAX86171 includes nine LED driver
`outputs to support WHOOP 4.0’s multiple LEDs. The LEDs each include a lens that receives output
`optical light from the LED and delivers the light to the skin (and underlying tissue) on the user’s wrist
`(e.g., flat lens). WHOOP 4.0 further includes a material covering the array of LEDs (e.g., epoxy lens, flat
`lens), which is a lens that receives output optical light from the LED and delivers the light to the skin.
`WHOOP 4.0 further includes yet another material covering the array of LEDs and photodetectors, which is
`a lens that receives output optical light from the LED and delivers the light to the skin.
`
`
`
`
`
`
`
`
`
`Source: Analog Devices, “MAX86171: Low-Noise AFE for Pulse Oximeter and Heart Rate Monitor Data
`Sheet,” Rev.2, Mar. 24, 2022, at 1, available at https://www.analog.com/media/en/technical-
`documentation/data-sheets/MAX86171.pdf.
`
`
`
`Ex. 11
`
`
`
`
`31
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 33 of 140 PageID #:
`1093
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`
`
`
`
`32
`
`
`
`
`
`’455 Patent – Whoop
`
`
`
`Ex. 11
`
`
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 34 of 140 PageID #:
`1094
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`
`
`
`
`
`
`
`Ex. 11
`
`
`
`
`33
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 35 of 140 PageID #:
`1095
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`(Above and below: Cross-section of LEDs)
`
`
`
`Lens
`
`
`
`
`Source: Product Teardown (WHOOP 4.0)
`
`
`Lens (e.g., flat lens) on each LED
`
`Ex. 11
`
`
`
`
`34
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 36 of 140 PageID #:
`1096
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`
`
`
`
`Source: https://www.tralert.com/en/lighting-terms/led-lens/
`
`
`
`Ex. 11
`
`
`
`
`35
`
`’455 Patent – Whoop
`
`

`

`
`
`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 37 of 140 PageID #:
`1097
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`“Light emitting diodes (LEDs) are a general source of continuous light with a high luminescence efficiency,
`and are based on the general properties of a simple twin-element semiconductor diode encased in a clear
`epoxy dome that acts as a lens.” Source: https://www.olympus-lifescience.com/en/microscope-
`resource/primer/java/leds/basicoperation/
`
`
`
`Source: https://www.olympus-lifescience.com/en/microscope-resource/primer/java/leds/basicoperation/
`
`
`
`Ex. 11
`
`
`
`
`36
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 38 of 140 PageID #:
`1098
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`
`
`
`
`
`
`
`
`
`Lens
`
`Ex. 11
`
`
`
`
`37
`
`’455 Patent – Whoop
`
`

`

`
`
`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 39 of 140 PageID #:
`1099
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`Source: Maxim Integrated, Application Note 6846, “Guidelines for the Opto-Mechanical Integration of
`Heart-Rate Monitors in Wearable Wrist Devices,” available at
`https://pdfserv.maximintegrated.com/en/an/AN6846.pdf.
`
`
`
`
`Ex. 11
`
`
`
`
`38
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 40 of 140 PageID #:
`1100
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`Source: https://www.youtube.com/watch?v=cxVN6zSjWPc.
`
`Patent documents assigned to and/or owned by Whoop also describe Whoop’s wearable devices comprising
`one or more lenses configured to receive at least a portion of the output optical light and to deliver a
`lens output light to tissue. For example:
`
`
`
`
`Ex. 11
`
`
`
`
`39
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 41 of 140 PageID #:
`1101
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`
`
`40
`
`Ex. 11
`
`
`
`
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 42 of 140 PageID #:
`1102
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`
`
`
`
`41
`
`
`
`’455 Patent – Whoop
`
`Ex. 11
`
`
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 43 of 140 PageID #:
`1103
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`
`
`
`Ex. 11
`
`
`
`
`42
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 44 of 140 PageID #:
`1104
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`Source: US 10,799,162 at Abstract, FIGS. 1A-1D, FIG. 2A, FIGS. 4A-4B, 4:49-5:8, 5:16-21.
`
`See also US 10,092,228 at Abstract, FIGS. 1A-1D, FIG. 2A, FIGS 4-A-4B, 4:25-5:3, 5:11-16.
`
`
`
`
`
`
`
`
`
`
`
`Ex. 11
`
`
`
`
`43
`
`’455 Patent – Whoop
`
`

`

`
`
`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 45 of 140 PageID #:
`1105
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`1[d] the wearable
`The Accused Wearable Device of the Accused System comprises a detection system configured to
`receive at least a portion of the lens output light reflected from the tissue and to generate an output
`device further
`signal having a signal-to-noise ratio, either literally or under the doctrine of equivalents.
`comprising a
`detection system
`
`For example, WHOOP 4.0 comprises hardware components such as photodiodes and an integrated analog
`configured to
`receive at least a
`front end (“AFE”) optical data acquisition and sensor module (e.g., MAX86171 manufactured by Analog
`Devices) (individually and/or collectively, “a detection system”). The AFE sensor module is configured to:
`portion of the lens
`(a) receive light initially output from LEDs that is reflected from tissue of a user (“receive at least a
`output light reflected
`portion of the lens output light reflected from the tissue”), and (b) generate an output
`from the tissue and
`photoplethysmography (“PPG”) signal having a signal-to-noise ratio (“generate an output signal having a
`to generate an output
`signal-to-noise ratio”).
`signal having a
`signal-to-noise ratio,
`
`
`
`
`
`
`Ex. 11
`
`
`
`
`44
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 46 of 140 PageID #:
`1106
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`
`
`
`
`
`
`Source: https://www.whoop.com/us/en/thelocker/chief-technology-officer-whoop-4-0-accuracy/.
`
`“WHOOP measures heart rate using advanced optical sensors with photoplethysmography (PPG)
`technology. It works by emitting green LED light into the skin, and then measuring the light that’s
`
`45
`
`’455 Patent – Whoop
`
`Ex. 11
`
`
`
`

`

`
`
`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 47 of 140 PageID #:
`1107
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`reflected back.” https://www.whoop.com/us/en/thelocker/a-look-behind-the-data-how-whoop-measures-
`heart-rate/.
`
`
`
`Source: https://www.whoop.com/us/en/thelocker/metric-blood-oxygen-monitoring/.
`
`
`
`
`Ex. 11
`
`
`
`
`46
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 48 of 140 PageID #:
`1108
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`Source: https://www.techinsights.com/products/ddt-2111-806.
`
`
`
`
`Source: Product Teardown (WHOOP 4.0)
`
`
`
`47
`
`Ex. 11
`
`
`
`Maxim Integrated MAX86171
`
`
`
`’455 Patent – Whoop
`
`

`

`
`
`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 49 of 140 PageID #:
`1109
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`The sensor (“detection system”) in WHOOP 4.0—e.g., MAX86171—includes photodiodes to receive the
`LED light reflected back from the user’s skin (and underlying body tissues), and is configured to generate a
`PPG output signal from the reflected light. The PPG output signal has a signal-to-noise ratio (“SNR”).
`
`
`
`
`
`
`
`
`Ex. 11
`
`
`
`
`48
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 50 of 140 PageID #:
`1110
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`
`
`
`Ex. 11
`
`
`
`
`49
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 51 of 140 PageID #:
`1111
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`
`
`Ex. 11
`
`
`
`
`
`
`50
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 52 of 140 PageID #:
`1112
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`
`
`
`Ex. 11
`
`
`
`
`51
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 53 of 140 PageID #:
`1113
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`Source: Analog Devices, “MAX86171: Low-Noise AFE for Pulse Oximeter and Heart Rate Monitor Data
`Sheet,” Rev.2, Mar. 24, 2022, at 1, 2, 16, 30, 32, available at https://www.analog.com/media/en/technical-
`documentation/data-sheets/MAX86171.pdf.
`
`
`
`
`
`
`52
`
`’455 Patent – Whoop
`
`Ex. 11
`
`
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 54 of 140 PageID #:
`1114
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`
`
`
`
`
`Photodiodes
`
`Maxim Integrated MAX86171
`
`Source: Product Teardown (WHOOP 4.0)
`
`
`
`53
`
`Ex. 11
`
`
`
`
`
`’455 Patent – Whoop
`
`

`

`
`
`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 55 of 140 PageID #:
`1115
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`1[e] wherein the
`The detection system in the Accused Wearable Device is configured to be synchronized to the light
`source, either literally or under the doctrine of equivalents.
`detection system is
`configured to be
`
`For example, the integrated AFE optical sensor module (“detection system”) is connected to the light
`synchronized to the
`source containing multiple LEDs. It is configured to synchronize with the light source by controlling the
`light source;
`LED current and pulse rate using LED drivers. To measure heart rate, for example, green LEDs are used
`with a pre-determined intensity and pulse rate. Different LEDs are used to measure other parameters, such
`as blood oxygen levels. Green LEDs (“light source”) blink when measuring heart rate, and alternately, red
`and infrared LEDs (“light source”) emit light when measuring blood oxygen levels. This, among other
`evidence below, shows that the AFE optical sensor module (“detection system”) is synchronized with the
`light source.
`
`The optical sensor in the Accused Wearable Device features a biosensing AFE manufactured by Analog
`Devices (e.g., MAX86171). That AFE optical sensor module (“detection system”) is configured to be
`synchronized to the LEDs in the Accused Wearable Device (e.g., using oscillator and timing and control
`elements).
`
`
`Ex. 11
`
`
`
`
`54
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 56 of 140 PageID #:
`1116
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`Source: https://www.whoop.com/us/en/thelocker/a-look-behind-the-data-how-whoop-measures-heart-rate/.
`
`
`
`
`Ex. 11
`
`
`
`
`55
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 57 of 140 PageID #:
`1117
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`Source: https://www.whoop.com/us/en/thelocker/metric-blood-oxygen-monitoring/.
`
`
`
`
`Ex. 11
`
`
`
`
`56
`
`’455 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-11 Filed 02/03/25 Page 58 of 140 PageID #:
`1118
`U.S. Patent No. 11,160,455 (the “’455 Patent”)
` “Multi-wavelength wearable device for non-invasive blood measurements in tissue”
`
`’455 Patent Claim Whoop Accused System1
`
`
`
`
`Source: https://www.techinsights.com/products/ddt-2111-8