Masimo v. Apple (22-1631): Federal Circuit Affirmed-in-Part, Reversed-in-Part on Blood Oximetry Patent
Masimo Corp. challenged Apple's inter partes review victory over US10258265B1, a patent covering multi-stream noninvasive blood constituent measurement. After 517 days, the Federal Circuit issued a split decision — affirming parts of the PTAB ruling while reversing others — leaving the patent's validity posture in a nuanced state.
A split Federal Circuit verdict on Masimo's core oximetry patent
Masimo Corporation filed Federal Circuit appeal No. 22-1631 on 13 April 2022, challenging a Patent Trial and Appeal Board decision concerning US10258265B1 — a patent directed to a multi-stream data collection system for noninvasive measurement of blood constituents. The defendant is Apple, Inc., represented by Fish & Richardson LLP, which had prevailed at the PTAB level on patentability grounds. The appeal was heard in the District of Columbia appellate region.
The case closed on 12 September 2023 after 517 days. The Federal Circuit's decision was mixed: it affirmed the Board's findings in part and reversed them in part. The recorded basis of termination is 'Appeal Dismissed in Part'; the court's verdict text states 'AFFIRMED-IN-PART AND REVERSED-IN-PART.' These characterisations are reported as they appear in the record — the reader should reconcile them. The specific claims or grounds that were affirmed versus reversed are not further detailed in the available record.
A split disposition of this kind suggests the Federal Circuit found at least some of the PTAB's patentability conclusions unsupported, while accepting others. What this means for the ultimate enforceability of US10258265B1 — and whether any surviving claims remain viable against Apple Watch health-monitoring features — is not determinable from the public record alone. No further remand instructions or claim-specific outcomes are disclosed in the available data.
See Complete Case & Patent Analysis →Filing to Appeal Dismissed in Part in 517 days
517 days from filing to Federal Circuit decision — typical Federal Circuit appeal runs 12–18 months
US10258265B1 — Multi-stream noninvasive blood constituent measurement
Any organisation developing wearable devices, smartwatches, or clinical monitors that incorporate noninvasive blood oxygen or multi-constituent measurement — using photoplethysmography, multi-wavelength optical sensing, or related multi-stream data architectures — should assess exposure to US10258265B1. The Federal Circuit's partial reversal means some claims are likely still active, and the scope of surviving claims is not publicly resolved. R&D teams entering this space without an FTO analysis carry material IP risk.
Official order — verbatim text
The Federal Circuit's 'affirmed-in-part and reversed-in-part' disposition on a PTAB patentability decision reflects the court applying de novo review to legal questions and substantial evidence review to factual findings. A reversal on even one ground indicates the Board's prior art analysis or claim construction failed to meet that standard on at least one issue. The specific claims and prior art grounds implicated by each portion of the ruling are not detailed in the available record.
Federal Circuit's split decision: what affirmed-in-part, reversed-in-part means for both parties
What 'affirmed-in-part, reversed-in-part' means at appellate level
A Federal Circuit decision affirming-in-part and reversing-in-part means the court found the PTAB correct on some grounds and in error on others. It is not a wholesale win for either party. The reversal component signals the court identified at least one legal or factual error in the Board's analysis, while the affirmance component validates remaining PTAB findings. The specific claims and grounds split are not disclosed in the available record.
Mixed appellate outcomeMasimo wins reversal on at least some PTAB findings
The reversal component is a partial victory for Masimo: the Federal Circuit determined the PTAB erred on at least one ground, potentially preserving some claims of US10258265B1 from cancellation. However, the affirmed portion means other PTAB invalidity findings stand. The net enforceability of the patent — and which specific claims survive — cannot be determined from the public record alone.
Partial claim survival possibleApple retains some PTAB wins but loses others on appeal
Apple's IPR strategy produced a mixed result at the Federal Circuit. The affirmed portion preserves Apple's PTAB victories on certain patentability grounds, limiting Masimo's ability to enforce those cancelled or invalidated claims. The reversed portion, however, means Apple did not extinguish the entirety of the patent at the PTAB level. Whether further proceedings follow is not indicated in the available record.
Partial IPR win preservedNoninvasive biosensing IP remains contested between med-tech and consumer electronics
A split Federal Circuit ruling in a Masimo v. Apple dispute over noninvasive blood constituent measurement technology signals that the patent boundaries in this space remain actively contested. Companies developing wearable health sensors, photoplethysmography systems, or multi-stream physiological monitoring should treat this outcome as confirmation that oximetry-adjacent IP continues to face rigorous PTAB and appellate scrutiny.
Wearable health-sensor IP riskFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Masimo, Corp. | Company | /Search in Eureka ↗ |
| Defendant | Apple, Inc. | Company | /Search in Eureka ↗ |
| Plaintiff counsel | Jarom D. Kesler | Attorney | Counsel for Masimo, Corp.Search in Eureka ↗ |
| Plaintiff counsel | Jeremiah Helm | Attorney | Counsel for Masimo, Corp.Search in Eureka ↗ |
| Plaintiff counsel | Joseph R. Re | Attorney | Counsel for Masimo, Corp.Search in Eureka ↗ |
| Plaintiff counsel | Stephen C. Jensen | Attorney | Counsel for Masimo, Corp.Search in Eureka ↗ |
| Plaintiff counsel | Stephen W. Larson | Attorney | Counsel for Masimo, Corp.Search in Eureka ↗ |
| Plaintiff law firm | Knobbe Martens Olson & Bear, LLP | Law Firm | Representing Masimo, Corp.Search in Eureka ↗ |
| Defendant counsel | Ashley Bolt | Attorney | Counsel for Apple, Inc.Search in Eureka ↗ |
| Defendant counsel | Christopher Dryer | Attorney | Counsel for Apple, Inc.Search in Eureka ↗ |
| Defendant counsel | Jared Hartzman | Attorney | Counsel for Apple, Inc.Search in Eureka ↗ |
| Defendant counsel | Lauren Ann Degnan | Attorney | Counsel for Apple, Inc.Search in Eureka ↗ |
| Defendant counsel | Walter Karl Renner | Attorney | Counsel for Apple, Inc.Search in Eureka ↗ |
| Defendant law firm | Fish & Richardson LLP | Law Firm | Representing Apple, Inc.Search in Eureka ↗ |
| Presiding judge | Judge N/A | Judge | Court of Appeals for the Federal CircuitSearch in Eureka ↗ |
R&D signals in the noninvasive biosensing patent space
Forward-looking patent intelligence derived from the Masimo v. Apple Federal Circuit dispute over multi-stream noninvasive blood constituent measurement technology.
Masimo's noninvasive monitoring patent activity beyond US10258265B1
Masimo holds a broad portfolio in noninvasive physiological measurement extending well beyond the single asserted patent. Tracking Masimo's continuation filings, CIP applications, and new grants in multi-stream sensing and pulse oximetry reveals the enforcement perimeter Apple — and any wearable health-device entrant — must navigate. Active prosecution in this family suggests continued portfolio expansion.
Masimo portfolio breadthFiling trends in multi-stream noninvasive blood constituent sensing
Patent filing activity in multi-stream photoplethysmography, multi-wavelength optical sensing, and noninvasive blood constituent measurement has intensified as consumer wearable health features proliferate. Understanding which organisations — beyond Masimo and Apple — are actively filing in this space helps R&D teams anticipate cross-fire IP risk and identify where the technology frontier is moving.
Filing trend: risingApple's health-sensor patent strategy in the post-IPR landscape
Apple has pursued an aggressive IPR strategy against Masimo's oximetry patents while simultaneously building its own health-sensor IP in the Apple Watch ecosystem. Mapping Apple's own patent grants in blood oxygen sensing, optical sensor arrays, and signal processing reveals both its defensive posture and potential offensive portfolio that could be cross-licensed or asserted in future disputes.
Apple biosensor IPDesign-around opportunities in noninvasive multi-constituent sensing
The contested claim landscape around multi-stream noninvasive measurement creates white-space opportunities for organisations that can differentiate on sensor architecture, signal processing algorithm, or data fusion methodology. Identifying claim gaps — particularly in areas where the Federal Circuit reversed the PTAB — may reveal patentable territory adjacent to US10258265B1 that is not yet densely populated.
Design-around potentialSimilar Federal Circuit appeals on wearable health-sensor and oximetry patents
Explore Federal Circuit appeals involving noninvasive physiological monitoring patents, PTAB IPR decisions in the wearable health-sensor space, and Masimo or Apple IP disputes.
What this case signals for the wearable health-sensor IP landscape
The Masimo–Apple Federal Circuit split reinforces that noninvasive biosensing patents face high-stakes, claim-by-claim battles at both PTAB and appellate levels.
Partial reversals signal PTAB over-reach risk in complex biosensing IPRs
When the Federal Circuit reverses even part of a PTAB invalidity decision, it signals that the Board's obviousness or anticipation analysis did not fully withstand appellate scrutiny. Patent holders in the noninvasive monitoring space should document secondary considerations and claim differentiation with Federal Circuit standards in mind from the outset.
Apple's IPR strategy in wearable health tech is active and sophisticated
Apple's engagement of Fish & Richardson and a five-attorney defence team reflects a deliberate, resourced approach to challenging third-party health-sensor patents via IPR. Companies holding oximetry or photoplethysmography patents that are commercially relevant to Apple Watch should anticipate IPR challenges and prepare prosecution histories accordingly.
Masimo v Apple — key questions answered
The Federal Circuit issued an affirmed-in-part and reversed-in-part decision, closing the case on 12 September 2023. The court upheld some of the PTAB's patentability findings and reversed others. The specific claims and grounds affected by each portion are not detailed in the publicly available record.
The patent at issue is US10258265B1, filed under application number US16/212440. It is directed to a multi-stream data collection system for noninvasive measurement of blood constituents — technology central to pulse oximetry and wearable health sensing.
It means the Federal Circuit found the PTAB correct on some invalidity grounds and in error on others. Some claims of US10258265B1 may have been restored from cancellation by the reversal, while others remain invalidated by the affirmed portion. The precise claim-by-claim outcome is not disclosed in the available case record.
The recorded basis of termination is 'Appeal Dismissed in Part.' The court's verdict text states 'AFFIRMED-IN-PART AND REVERSED-IN-PART.' Both characterisations are reported as they appear in the case record; the available data does not explain the relationship between them, and readers should consult the docket directly to reconcile the two.
Yes. The partial reversal of the PTAB decision suggests at least some claims of US10258265B1 survived the IPR and Federal Circuit process. Any organisation developing noninvasive blood constituent measurement products — particularly wearable devices using optical or multi-stream sensing — should conduct a freedom-to-operate analysis against the surviving claims before commercialisation.
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