Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 1 of 156 PageID #: 780
`Case 1:25-cv-00140-JLH Document1-9
`Filed 02/03/25
`Page 1 of 156 PagelD #: 780
`
`EXHIBIT 9
`
`EXHIBIT 9
`
`

`

`
`
`
`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 2 of 156 PageID #: 781
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`7[pre] A system for
`Without conceding that the preamble of Claim 7 of the ’484 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
`
`
`1 Whoop infringes multiple claims of the ’484 Patent, including at least Claims 8-10. Claims 8-10 depend either directly or indirectly
`on independent Claim 7. Accordingly, Claim 7 is provided in this chart to show exemplary evidence of Whoop’s infringement of the
`limitations of Claim 7, which are included in Claims 8-10.
`2 The Accused System includes a Whoop fitness tracker 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, 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. The WHOOP 4.0 and various mobile devices 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. 9
`
`
`
`1
`
`’484 Patent – Whoop
`
`

`

`
`
`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 3 of 156 PageID #: 782
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`membership in addition to an Accused Wearable Device to access all of the health features of the Accused
`Wearable Device.
`
`
`
`Source: https://discover.whoop.com/health-monitoring/.
`
`
`
`
`
`
`
`
`Ex. 9
`
`2
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 4 of 156 PageID #: 783
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`Source: https://www.whoop.com/us/en/.
`
`
`
`
`
`
`
`
`Ex. 9
`
`3
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 5 of 156 PageID #: 784
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`Source: https://join.whoop.com/us/en/membership/.
`
`
`
`
`
`
`
`
`Ex. 9
`
`4
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 6 of 156 PageID #: 785
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`Source: https://discover.whoop.com/health-monitoring/.
`
`
`
`
`
`
`
`
`Ex. 9
`
`5
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 7 of 156 PageID #: 786
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`Source: https://www.whoop.com/us/en/thelocker/measure-normal-blood-oxygen-levels/.
`
`
`
`
`
`
`
`
`Ex. 9
`
`6
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 8 of 156 PageID #: 787
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`Source: https://www.whoop.com/us/en/thelocker/measure-normal-blood-oxygen-levels/.
`
`
`
`
`
`
`
`
`Ex. 9
`
`7
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 9 of 156 PageID #: 788
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`
`
`
`
`
`
`Source: https://support.whoop.com/s/article/WHOOP-App-Minimum-Software-
`Requirements?language=en_US.
`
`
`
`
`
`
`Ex. 9
`
`8
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 10 of 156 PageID #:
`789
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`
`
`
`
`
`Ex. 9
`
`9
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 11 of 156 PageID #:
`790
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`
`
`
`
`
`
`
`Ex. 9
`
`10
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 12 of 156 PageID #:
`791
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`
`
`
`
`
`Ex. 9
`
`11
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 13 of 156 PageID #:
`792
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`
`
`Source: https://www.youtube.com/watch?v=pj5VWkAgyME&t=2s.
`
`The Accused System comprises a wearable device adapted to be placed on a wrist or an ear of a user,
`and including a light source comprising a plurality of semiconductor sources, either literally or under
`the doctrine of equivalents.
`
`For example, the WHOOP 4.0 (“wearable device”) is adapted to be and is worn on the wrist of a user.
`The WHOOP 4.0 includes a light source that comprising multiple LEDs, such as a green LED, red LED,
`and an infrared LED (“plurality of semiconductor sources”).
`
`
`12
`
`’484 Patent – Whoop
`
`7[a] a wearable
`device adapted to be
`placed on a wrist or
`an ear of a user, and
`including a light
`source comprising a
`plurality of
`semiconductor
`sources,
`
`
`
`
`
`Ex. 9
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 14 of 156 PageID #:
`793
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`Source: https://discover.whoop.com/health-monitoring/.
`
`
`
`
`
`
`
`
`Ex. 9
`
`13
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 15 of 156 PageID #:
`794
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`
`
`
`
`
`Ex. 9
`
`14
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 16 of 156 PageID #:
`795
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`Source: https://www.youtube.com/watch?v=cxVN6zSjWPc.
`
`
`
`
`
`
`
`
`Ex. 9
`
`15
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 17 of 156 PageID #:
`796
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`Source: https://www.youtube.com/watch?v=rlEsoMy-l4w.
`
`
`
`
`
`
`
`
`Ex. 9
`
`16
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 18 of 156 PageID #:
`797
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`Source: https://www.youtube.com/watch?v=cxVN6zSjWPc.
`
`
`
`
`
`
`
`
`Ex. 9
`
`17
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 19 of 156 PageID #:
`798
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`Source: https://www.whoop.com/us/en/difference/.
`
`
`
`
`
`
`
`
`Ex. 9
`
`18
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 20 of 156 PageID #:
`799
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`Source: https://www.whoop.com/us/en/thelocker/measure-normal-blood-oxygen-levels/.
`
`
`
`
`
`
`
`
`
`
`
`
`Ex. 9
`
`19
`
`’484 Patent – Whoop
`
`

`

`
`
`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 21 of 156 PageID #:
`800
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`Source: https://www.whoop.com/us/en/thelocker/a-look-behind-the-data-how-whoop-measures-heart-rate/.
`
`
`
`
`
`
`
`
`
`Ex. 9
`
`20
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 22 of 156 PageID #:
`801
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`
`
`Source: Product Teardown (WHOOP 4.0)
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Ex. 9
`
`21
`
`’484 Patent – Whoop
`
`

`

`
`
`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 23 of 156 PageID #:
`802
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`7[b] each of the
`In the Accused Wearable Device, each of the semiconductor sources configured to generate an output
`light having one or more optical wavelengths, either literally or under the doctrine of equivalents.
`semiconductor
`sources configured
`
`For example, WHOOP 4.0 includes multiple LEDs (“semiconductor sources”), such as a green LED, a red
`to generate an output
`LED, and an infrared LED. Different color LEDs and infrared LEDs each generate output light having
`light having one or
`different optical wavelengths (“one or more optical wavelengths”).
`more optical
`
`wavelengths;
`
`
`Source: https://www.youtube.com/watch?v=rlEsoMy-l4w.
`
`
`
`
`
`
`
`
`Ex. 9
`
`22
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 24 of 156 PageID #:
`803
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`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.
`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.”
`
`
`
`23
`
`’484 Patent – Whoop
`
`
`
`
`
`Ex. 9
`
`

`

`
`
`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 25 of 156 PageID #:
`804
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`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. 9
`
`24
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 26 of 156 PageID #:
`805
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`Source: https://www.photonics.com/Articles/Light-Emitting_Diodes_A_Primer/a36706.
`
`
`
`
`
`
`
`
`
`
`
`
`Ex. 9
`
`25
`
`’484 Patent – Whoop
`
`

`

`
`
`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 27 of 156 PageID #:
`806
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`7[c] the wearable
`The Accused System comprises a wearable device comprising one or more lenses configured to receive
`a portion of at least one of the output lights 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 a portion of
`between each LED and the wrist of a user when worn by the user. The lenses receive output light from the
`at least one of the
`LEDs and deliver the light to tissue of the user (e.g., skin, blood vessels, veins).
`output lights and to
`deliver a lens output
`
`light to tissue;
`
`
`Source: https://discover.whoop.com/health-monitoring/.
`
`
`
`
`
`
`
`
`Ex. 9
`
`26
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 28 of 156 PageID #:
`807
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`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. 9
`
`27
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 29 of 156 PageID #:
`808
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`
`
`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. 9
`
`28
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 30 of 156 PageID #:
`809
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`Source: https://www.techinsights.com/products/ddt-2111-806.
`
`
`
`
`Maxim Integrated MAX86171
`
`Source: Product Teardown (WHOOP 4.0)
`
`
`
`
`
`
`
`
`
`Ex. 9
`
`29
`
`’484 Patent – Whoop
`
`

`

`
`
`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 31 of 156 PageID #:
`810
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`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 light
`from the LED and delivers the light to the skin (and underlying tissue) on the user’s wrist (e.g., flat lens,
`epoxy lens). WHOOP 4.0 further includes a material covering the array of LEDs, which is a lens that
`receives output light from the LED and delivers the light to the skin (e.g., flat lens, epoxy lens).
`WHOOP 4.0 further includes yet another material covering the array of LEDs and photodetectors (e.g.,
`epoxy lens), which is a lens that receives output 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. 9
`
`30
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 32 of 156 PageID #:
`811
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`
`
`
`31
`
`
`
`
`
`’484 Patent – Whoop
`
`
`
`
`
`
`
`Ex. 9
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 33 of 156 PageID #:
`812
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Ex. 9
`
`32
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 34 of 156 PageID #:
`813
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`(Above and below: Cross-section of LEDs)
`
`
`
`Lens
`
`
`Source: Product Teardown (WHOOP 4.0)
`
`
`
`Lens (e.g., flat lens) on each LED
`
`
`
`
`
`
`
`Ex. 9
`
`33
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 35 of 156 PageID #:
`814
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`
`
`
`
`Source: https://www.tralert.com/en/lighting-terms/led-lens/
`
`
`
`
`
`
`
`Ex. 9
`
`34
`
`’484 Patent – Whoop
`
`

`

`
`
`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 36 of 156 PageID #:
`815
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`“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. 9
`
`35
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 37 of 156 PageID #:
`816
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`
`
`
`
`
`
`
`
`
`Lens
`
`
`
`
`
`Ex. 9
`
`36
`
`’484 Patent – Whoop
`
`

`

`
`
`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 38 of 156 PageID #:
`817
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`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. 9
`
`37
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 39 of 156 PageID #:
`818
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`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 a portion of at least one of the output lights and to deliver a
`lens output light to tissue. For example:
`
`
`
`
`
`
`
`
`Ex. 9
`
`38
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 40 of 156 PageID #:
`819
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`
`
`
`
`
`
`
`Ex. 9
`
`39
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 41 of 156 PageID #:
`820
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`
`
`
`
`
`
`
`
`
`Ex. 9
`
`40
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 42 of 156 PageID #:
`821
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`
`
`
`
`
`
`
`Ex. 9
`
`41
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 43 of 156 PageID #:
`822
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`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.
`
`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
`signal having a signal-to-noise ratio, either literally or under the doctrine of equivalents.
`
`For example, WHOOP 4.0 comprises hardware components such as photodiodes and an integrated analog
`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:
`(a) receive light initially output from LEDs that is reflected from tissue of a user (“receive at least a
`portion of the lens output light reflected from the tissue”), and (b) generate an output
`photoplethysmography (“PPG”) signal having a signal-to-noise ratio (“generate an output signal having a
`signal-to-noise ratio”).
`
`42
`
`’484 Patent – Whoop
`
`7[d] the wearable
`device further
`comprising a
`detection system
`the lens output light
`reflected from the
`tissue and to
`generate an output
`signal having a
`signal-to-noise ratio,
`
`
`
`
`
`
`Ex. 9
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 44 of 156 PageID #:
`823
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Ex. 9
`
`43
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 45 of 156 PageID #:
`824
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`
`
`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
`reflected back.” https://www.whoop.com/us/en/thelocker/a-look-behind-the-data-how-whoop-measures-
`heart-rate/.
`
`
`
`
`
`
`Ex. 9
`
`44
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 46 of 156 PageID #:
`825
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`Source: https://www.whoop.com/us/en/thelocker/metric-blood-oxygen-monitoring/.
`
`
`
`
`
`
`
`
`Ex. 9
`
`45
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 47 of 156 PageID #:
`826
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`Source: https://www.techinsights.com/products/ddt-2111-806.
`
`
`
`
`Maxim Integrated MAX86171
`
`Source: Product Teardown (WHOOP 4.0)
`
`
`
`
`46
`
`’484 Patent – Whoop
`
`
`
`
`
`Ex. 9
`
`

`

`
`
`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 48 of 156 PageID #:
`827
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`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. 9
`
`47
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 49 of 156 PageID #:
`828
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`
`
`
`
`
`
`
`Ex. 9
`
`48
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 50 of 156 PageID #:
`829
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`
`
`
`
`
`
`Ex. 9
`
`
`
`49
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 51 of 156 PageID #:
`830
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`
`
`
`
`
`
`
`Ex. 9
`
`50
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 52 of 156 PageID #:
`831
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`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.
`
`
`
`
`
`51
`
`’484 Patent – Whoop
`
`
`
`
`
`Ex. 9
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 53 of 156 PageID #:
`832
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`
`
`
`
`
`Photodiodes
`
`Maxim Integrated MAX86171
`
`Source: Product Teardown (WHOOP 4.0)
`
`
`
`
`52
`
`’484 Patent – Whoop
`
`
`
`
`
`Ex. 9
`
`

`

`
`
`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 54 of 156 PageID #:
`833
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`7[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. 9
`
`53
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 55 of 156 PageID #:
`834
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2
`
`
`
`
`Source: https://www.whoop.com/us/en/thelocker/a-look-behind-the-data-how-whoop-measures-heart-rate/.
`
`
`
`
`
`
`
`
`Ex. 9
`
`54
`
`’484 Patent – Whoop
`
`

`

`Case 1:25-cv-00140-JLH Document 1-9 Filed 02/03/25 Page 56 of 156 PageID #:
`835
`U.S. Patent No. 10,517,484 (the “’484 Patent”)
`“Semiconductor diodes-based physiological measurement device with improved signal-to-noise ratio”
`
`’484 Patent Claim1 Whoop Accused System2