InMode v. BTL Industries: Infringement Action Transferred to Massachusetts
InMode, Ltd. filed suit against BTL Industries, Inc. in California’s Central District asserting US8961511B2 — a patent covering energy-based body contouring and intimate wellness devices — against BTL’s UltraFemme 360, EmFemme 360, and related platforms. After 404 days of proceedings, the court granted BTL’s transfer motion, moving the case to the District of Massachusetts.
Venue battle shapes InMode’s patent campaign against BTL
InMode, Ltd., an Israeli medical aesthetics company with U.S. operations, filed this infringement action on October 11, 2023 in the Central District of California, asserting US8961511B2 against a range of BTL Industries’ energy-based intimate wellness and body contouring platforms — including the UltraFemme 360, EmFemme 360, EmFemme Platform, Exilis Ultra 360, Exion Platform, and UltraFemme 360 Platform. The asserted patent relates to radio-frequency and energy-based tissue treatment technology, a core area of competition between the two companies.
BTL Industries, headquartered in Massachusetts, moved to transfer the case to the District of Massachusetts on the grounds of venue propriety or convenience. The court granted that motion, and the case was formally closed in California on November 18, 2024 — 404 days after filing. A transfer order does not resolve the merits; the infringement claims travel with the case and will be adjudicated in the receiving court.
The 404-day duration before transfer is consistent with contested venue disputes in multi-product patent cases, where parties brief convenience factors and district-specific connections at length. InMode’s decision to file in California rather than Massachusetts — BTL’s home district — suggests a forum selection strategy that ultimately did not prevail. What drove the court’s transfer analysis, including any findings on witness location or prior art sources, remains available in the public docket but is not reflected in the summary record.
Filing to Case Transferred in 404 days
404 days in California Central District before transfer to Massachusetts
Case transferred to Massachusetts: what this means for both parties
A transfer is not a dismissal — litigation continues in a new court
When a district court grants a motion to transfer under 28 U.S.C. § 1404(a) or § 1406, the case is not dismissed. The entire action — claims, counterclaims, and the asserted patent — moves to the transferee court. The District of Massachusetts will pick up the docket from where California left off. No merits ruling has been made; InMode’s infringement allegations remain live.
Merits still pendingInMode must re-engage in BTL’s home district
InMode’s forum choice — California — was overridden. Litigating in Massachusetts, where BTL is headquartered, typically shifts practical advantages toward the defendant: local witnesses, potentially more familiar local counsel, and a district with its own patent litigation posture. InMode’s legal team, led by K&L Gates and Venable LLP, will need to adapt strategy and potentially local counsel arrangements for the new venue.
Forum strategy resetBTL secures home-court advantage — but faces the same patent claims
Winning a transfer motion is a meaningful procedural win for BTL: litigation in Massachusetts is less disruptive operationally, and the District of Massachusetts has an established patent docket. However, BTL still faces InMode’s assertion of US8961511B2 across multiple product lines. The transfer ruling is silent on invalidity, non-infringement, or claim scope — all of which remain fully at issue.
Procedural win onlyMulti-platform IP risk remains unresolved across BTL’s wellness portfolio
With six named product platforms at stake — including UltraFemme 360 and the Exion Platform — the commercial exposure for BTL is significant if infringement is ultimately found. The transfer does not trigger any injunctive relief or royalty obligation. Companies competing in energy-based intimate wellness and body contouring should monitor the Massachusetts docket for claim construction rulings that could define the patent’s scope across the sector.
Watch Massachusetts docketFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | InMode, Ltd. | Company | Medical aesthetics technology company — holder of US8961511B2Search in Eureka ↗ |
| Defendant | BTL Industries, Inc. | Company | BTL Industries, Inc. — maker of UltraFemme 360 and related energy-based wellness platformsSearch in Eureka ↗ |
| Plaintiff counsel | Caitlin Comstock Blanche | Attorney | Counsel for InMode, Ltd.Search in Eureka ↗ |
| Plaintiff counsel | Caroline M. Vermillion | Attorney | Counsel for InMode, Ltd.Search in Eureka ↗ |
| Plaintiff counsel | Christina N. Goodrich | Attorney | Counsel for InMode, Ltd.Search in Eureka ↗ |
| Plaintiff counsel | Frank C. Cimino , Jr | Attorney | Counsel for InMode, Ltd.Search in Eureka ↗ |
| Plaintiff counsel | Jeffrey R. Gargano | Attorney | Counsel for InMode, Ltd.Search in Eureka ↗ |
| Plaintiff counsel | Kelsi Quarles | Attorney | Counsel for InMode, Ltd.Search in Eureka ↗ |
| Plaintiff counsel | Parker G. Zimmerman | Attorney | Counsel for InMode, Ltd.Search in Eureka ↗ |
| Plaintiff counsel | Peter E. Soskin | Attorney | Counsel for InMode, Ltd.Search in Eureka ↗ |
| Plaintiff counsel | William Andrew Hector | Attorney | Counsel for InMode, Ltd.Search in Eureka ↗ |
| Plaintiff law firm | K&L Gates LLP | Law Firm | Representing InMode, Ltd.Search in Eureka ↗ |
| Plaintiff law firm | Meyers Nave | Law Firm | Representing InMode, Ltd.Search in Eureka ↗ |
| Plaintiff law firm | Venable LLP | Law Firm | Representing InMode, Ltd.Search in Eureka ↗ |
| Defendant counsel | Chandrika Vira | Attorney | Counsel for BTL Industries, Inc.Search in Eureka ↗ |
| Defendant counsel | J. C. Rozendaal | Attorney | Counsel for BTL Industries, Inc.Search in Eureka ↗ |
| Defendant counsel | Josephine Kim | Attorney | Counsel for BTL Industries, Inc.Search in Eureka ↗ |
| Defendant counsel | Randy R. Haj | Attorney | Counsel for BTL Industries, Inc.Search in Eureka ↗ |
| Defendant law firm | Payne & Fears LLP | Law Firm | Representing BTL Industries, Inc.Search in Eureka ↗ |
| Defendant law firm | Sterne, Kessler, Goldstein & Fox PLLC | Law Firm | Representing BTL Industries, Inc.Search in Eureka ↗ |
| Presiding judge | Judge N/A | Judge | California Central District CourtSearch in Eureka ↗ |
Official order — verbatim text
The court’s transfer order is purely procedural — it resolves venue, not liability. The phrase ‘GRANTED, and this case is TRANSFERRED’ confirms no infringement finding, no invalidity ruling, and no damages assessment were made. Under 28 U.S.C. § 1404(a), the court likely weighed factors including witness location, operational nexus, and the interests of justice. BTL’s Massachusetts headquarters was almost certainly central to the analysis. All substantive patent claims against BTL’s platforms remain pending before the District of Massachusetts.
US8961511B2 — energy-based tissue treatment for intimate wellness devices
US8961511B2, filed under application number US11/704067, protects technology in the energy-based tissue treatment space — specifically the application of radio-frequency or similar energy modalities for intimate wellness and body contouring procedures. The patent is central to InMode’s product differentiation strategy in a sector where clinical efficacy and device design overlap significantly. Its grant status and the breadth of products named in the complaint suggest InMode views it as a foundational enforcement asset.
The six BTL product platforms named in this case — spanning UltraFemme 360, EmFemme 360, and the Exion Platform among others — reflect how widely InMode believes this patent’s claims extend across competing energy-based device architectures. For any company developing or commercialising RF-based intimate wellness or body contouring technology, US8961511B2 represents a live enforcement risk. The Massachusetts proceedings will likely produce claim construction rulings that clarify scope and set benchmarks for the broader competitive landscape.
Should you run an FTO against US8961511B2?
Any R&D team or product manager working on RF-based vaginal rejuvenation, intimate wellness, or energy-based body contouring devices should treat US8961511B2 as a priority FTO target. InMode has demonstrated willingness to assert this patent across a wide range of competing platforms — including devices that may appear architecturally distinct. If your product uses radio-frequency or thermal energy for tissue treatment, a clearance analysis against this patent and its family is not optional.
PatSnap Eureka’s FTO Search Agent can map US8961511B2’s claim language against your product specifications, identify the full patent family including any continuations filed after the original grant, and flag cited prior art that could inform an invalidity strategy. Eureka also tracks the Massachusetts docket in real time, so your legal and R&D teams receive claim construction updates the moment they are issued — before they reshape your freedom to operate.
Run a freedom-to-operate analysis on US8961511B2 to assess your product’s exposure
Run FTO in Eureka →Similar RF medical device patent cases in federal district courts
Explore patent infringement cases involving energy-based medical devices and RF tissue treatment technology litigated in California and Massachusetts federal courts.
What this case signals for the medical aesthetics IP landscape
InMode’s aggressive multi-product assertion and BTL’s successful venue challenge offer lessons for competitors and IP teams in energy-based medical devices.
Forum selection in medical device patent cases requires rigorous pre-suit analysis
InMode filed in California despite BTL’s Massachusetts headquarters — a strategy that failed after 404 days. Patent plaintiffs in hardware-intensive medical device cases should model transfer risk early, particularly where the defendant’s key witnesses and operations are concentrated in a different district.
Six-product assertion signals broad claim scope — or deliberate pressure tactics
Naming the UltraFemme 360, EmFemme 360, Exilis Ultra 360, Exion Platform, and related products suggests InMode believes US8961511B2 covers a wide range of RF and energy-based tissue treatment implementations. Competitors with similar device architectures should treat this as a signal to audit their own product-to-claim mapping against this patent.
InMode v BTL — key questions answered
InMode, Ltd. filed a patent infringement action against BTL Industries, Inc. in California’s Central District on October 11, 2023, asserting US8961511B2 against six BTL product platforms. After 404 days, the court granted BTL’s motion to transfer the case to the District of Massachusetts. No merits ruling was issued in California.
InMode’s complaint names six BTL product platforms: UltraFemme 360, EmFemme 360, EmFemme Platform, Exilis Ultra 360 Platform, Exion Platform, and UltraFemme 360 Platform. All are energy-based devices used in intimate wellness and body contouring applications.
The court granted BTL’s transfer motion, consistent with BTL Industries being headquartered in Massachusetts. Transfer under 28 U.S.C. § 1404(a) typically turns on factors including witness location, convenience of the parties, and the interests of justice. The detailed reasoning is in the California court’s order on the public docket.
A transfer does not dismiss or resolve InMode’s claims. The infringement allegations under US8961511B2 travel with the case to the District of Massachusetts, where they will be litigated from the procedural point where California left off. BTL still faces full exposure on infringement, and InMode retains the ability to seek damages and injunctive relief.
US8961511B2 covers energy-based tissue treatment technology, including RF-based applications for vaginal rejuvenation and body contouring. InMode’s assertion against six competing platforms signals the patent may cover broad implementation architectures in the intimate wellness device space. Companies developing similar energy-based devices should conduct FTO analysis against this patent and its family.
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