Smartwatch Mobileconcepts LLC v. Timex Group USA, Inc.

CourtDistrict Court, D. Connecticut
DecidedFebruary 23, 2026
Docket3:24-cv-01294
StatusUnknown

This text of Smartwatch Mobileconcepts LLC v. Timex Group USA, Inc. (Smartwatch Mobileconcepts LLC v. Timex Group USA, Inc.) is published on Counsel Stack Legal Research, covering District Court, D. Connecticut primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Smartwatch Mobileconcepts LLC v. Timex Group USA, Inc., (D. Conn. 2026).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ---------------------------------------------------------------- x SMARTWATCH MOBILECONCEPTS LLC : : Plaintiff, : : v. : 3:24-CV-01294 (SFR) : TIMEX GROUP USA, INC. : : Defendant. : --------------------------------------------------------------- x

MEMORANDUM & ORDER

Plaintiff Smartwatch Mobileconcepts LLC (“Smartwatch”) brings this action against Timex Group USA, Inc. (“Timex”) for patent infringement. For the reasons below, I grant Timex’s Motion to Dismiss the Amended Complaint with leave to file a Second Amended Complaint. I. BACKGROUND A. Factual Background 1. The Patent Smartwatch brings this action alleging that the Timex FamilyConnect device infringes “one or more of claims 1-9” of United States Patent 10,362,480 (“the ‘480 patent”), entitled “Systems, methods and apparatuses for enabling wearable device user access to secured electronics systems.” Am. Compl. ¶¶ 6-7, 9. The ’480 patent “was duly and legally issued by the U.S. Patent and Trademark Office” on July 23, 2019. Am. Compl. ¶ 7. It describes a system whereby a “wearable device” “authenticates” a user and then provides access to a “secured electronic system.” ECF No. 30- 1, at 11 (“Patent”). The Patent’s “Background of the Invention” section explains that “wearable devices” include “‘smartwatches,’ such as Apple Corporation’s ‘Apple Watch’” and other similar devices, which sometimes can connect directly to cellular networks and at other times are

dependent on a user’s smartphone for connection to a cellular network. Patent 8. The figures accompanying the ‘480 patent include illustrations that are plainly identifiable as smartwatches. Id. at 4-5. In the “Detailed Description” of the Patent, several examples of authentication are provided. These include “password entry on the user interface (e.g., touch screen) of the smartwatch or by using the smartwatch to obtain biometric information,” including “voice or skin illumination measurements,” from the user. Id. at 10. This section also explains that a “secured electronic system” is “a system requiring electronic initiation for its

operation or to gain access to it” and examples include “electromechanical locking systems that can be operated (unlocked) electronically with access codes; wireless vehicle compartment access and ignition initiation; equipment (industrial, medical, laboratory) secured by electronic codes for access and use; automatic teller machines; payment mechanisms; points-of-sale; and secured server or databases including protected information (e.g., patient records/information).” Id. at 9. Given these illustrations and definitions, one example of an embodiment of this patent

might include a process by which: (1) a user is wearing a smartwatch; (2) the user enters a password on the user interface of the smartwatch; (3) the smartwatch establishes communication via Bluetooth with a nearby vehicle; and (4) the vehicle door is unlocked, granting the user access as a result of the user’s proximity to the vehicle. Id. at 6. Although the ’480 Patent description includes several distinct processes, each nonetheless involves some method by which a wearable device is used to authenticate and provide access to a secured electronic system. 2. The Infringement Allegations Smartwatch’s infringement allegations are found in a Claims Chart attached to the

Amended Complaint as Exhibit B, and relate to Claim 2. See ECF No. 30-2. Claim 2 states: A method for enabling a wearable device user to access secured electronic systems, said method comprising: placing a wearable device in contact with a user, said wearable device including a telecommunications carrier access identification module, a cellular RF communications module, and a short-range RF communications module; achieving secured, short-range RF communication between the wearable device and a secured electronic system; authenticating the user with at least one of the wearable device, a remote server via cellular communications supported by the telecommunications carrier access identification module and the cellular RF communications module, and the secured electronic system via the secured, short-range RF communication; and providing the user with access to or through the secured electronic system once authenticated; wherein said wearable device includes a GPS module for determining location of the wearable device user with respect to the secured electronic system, and wherein the step of providing a user access to or through the secured electronic systems is also dependent on the location of the wearable device user. Patent 11. In its Claims Chart, Smartwatch relies on screenshots of the Timex FamilyConnect device user manual, and references to Timex’s privacy policy, to plead its allegations of infringement. See ECF No. 30-2. Although it provides minimal detail or narrative description connecting these screenshots to the alleged infringement, Smartwatch alleges that “Timex FamilyConnect has a method for enabling a wearable device user to access secured electronic system.” Id. at 4. Smartwatch further alleges that the FamilyConnect device includes cellular and Bluetooth functions, and a “short-range RF communications module,” id. at 5, and “achieves ‘Bluetooth functions,’ i.e., secured short-range RF communication between the

wearable device and a secured electronic system,” id. at 6. Smartwatch says the “secured electronic system = Timex server’s database,” although it does not precisely specify what this “server’s database” is. Id. Smartwatch also alleges that FamilyConnect “describes ‘Name, Phone Number, Email Address and Password’, i.e., authenticating the user with the wearable device” and alleges that “authenticating the user = ‘My Account.’” Id. at 7. Smartwatch further alleges that FamilyConnect “provides the user with ‘My Account’, i.e., access to or through the secured

electronic system once authenticated.” Id. at 8. Finally, Smartwatch alleges that FamilyConnect includes a “GPS module for determining location of the wearable device user with respect to the secured electronic system, and the step of providing a user access to or through the secured electronic systems is also dependent on the location of the wearable device user.” Id. at 9. To support this statement, Smartwatch cites the user manual, which states that “[i]f the watch is inside a building or at a place where GPS reception is compromised, the child’s location may not be indicated precisely.” Id.

B. Procedural History Smartwatch filed the Complaint in this action on August 6, 2024. ECF No. 1. Timex filed a Motion to Dismiss on November 25, 2024. ECF No. 18. Smartwatch then filed an Amended Complaint on December 16, 2024. ECF No. 30. On December 17, 2024, the Court1 ordered Timex to either file a notice requesting the Court consider the merits of the first Motion to Dismiss as applied to the Amended Complaint or file a new response to the Motion. ECF

No. 31. On January 6, 2025, Timex filed an updated Motion to Dismiss, ECF No. 35, and supporting Memorandum, ECF No. 35-1 (“Def.’s Mem.”). Smartwatch filed a Memorandum in Opposition on January 27, 2025, ECF No. 39 (“Pl.’s Mem.”), and Timex filed its Reply on February 10, 2025, ECF No. 40 (“Def.’s Reply”). I found Timex’s initial Motion to Dismiss moot on June 27, 2025. ECF No. 44. On February 11, 2026, I held oral argument on the Motion to Dismiss. ECF No. 53. II. LEGAL STANDARD To survive a motion to dismiss for failure to state a claim pursuant to Fed. R. Civ. P.

12(b)(6), a complaint must contain “sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009); Kim v. Kimm, 884 F.3d 98, 103 (2d Cir.

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Smartwatch Mobileconcepts LLC v. Timex Group USA, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/smartwatch-mobileconcepts-llc-v-timex-group-usa-inc-ctd-2026.