A redesigned Apple Watch doesn’t infringe two Masimo Corp. patents, a US trade judge found, a day before an appeals court upheld the US International Trade Commission’s 2023 order barring
Apple’s Redesign 2 Watch doesn’t directly infringe asserted claims of US Patent Nos. 10,912,502 and 10,945,648, nor does it induce their infringement when used with an iPhone in the US, according to Administrative Law Judge Monica Bhattacharyya’s enforcement initial determination issued Wednesday at the US International Trade Commission.
Bhattacharyya’s recommended determination on the modification turned on her finding that the redesigned watch doesn’t infringe and therefore falls outside the scope of the existing exclusion order.
If ratified by the full ITC, her finding could pave the way for Apple to escape the 2023 import ban on Apple Watches with blood-oxygen features found to infringe Masimo’s patents.
On Thursday, meanwhile, a three-judge panel of the US Court of Appeals for the Federal Circuit affirmed the ITC’s 2023 decision in a precedential opinion, finding “no error in the Commission’s domestic industry determination, its validity rulings, or its infringement findings.” The appeals court’s ruling confirmed that the earlier Apple Watch models with blood-oxygen features infringe Masimo’s patents and remain barred from import.
Judge Leonard P. Stark wrote for the Federal Circuit panel that when assessing whether Masimo proved a domestic industry, the ITC “did not rely on a ‘hypothetical’ article as Apple wrongly asserts.” Instead, he said the commission relied on Masimo’s “pertinent patent-practicing article” supported by prototypes, witness testimony, testing data, and “other circumstantial evidence.”
An Apple spokesperson said the company is “pleased with” Bhattacharyya’s findings but disagrees with the Federal Circuit’s decision and is “evaluating all avenues for further review.”
A Masimo spokesperson declined to comment on the developments.
Together, the decisions set up the next phase of the dispute—whether Apple successfully designed around the now-upheld ban. The full commission will decide whether to adopt or modify the judge’s findings on the redesigned watch, determining whether it can continue to be sold in the US.
The litigation between the companies has spanned the ITC, district courts, US Customs and Border Protection, and the Federal Circuit.
The ITC launched the combined enforcement and modification proceeding in November to determine whether Apple’s redesigned watch still falls within the scope of the original ban, which restricted imports of models enabled with the blood-oxygen feature.
The proceeding was instituted the same day a California jury awarded Masimo $634 million upon finding the Apple Watch’s heart-rate alert function infringed a since-expired patent for a power-saving system for light-based pulse- and oxygen-monitoring. The parties are locked in post-trial bids to expand or undo that verdict.
The ITC judge assessed infringement and whether pairing the device with an iPhone in the US would amount to infringement. The expedited review was also meant to resolve perceived tension between CBP’s rulings in January 2025 and August 2025 regarding whether the redesigned Apple Watch could be imported.
Apple told the Federal Circuit in December that the new proceeding underscored flaws in the import ban, arguing the agency applied uneven standards and wrongly credited Masimo with having proven a qualifying domestic industry when issuing the original order.
The cases are In the Matter of Certain Light-Based Physiological Measurement Devices and Components Thereof, USITC, Inv. No. 337-TA-1276, enforcement initial determination issued 3/18/26; and Apple Inc. v. International Trade Commission, Fed. Cir., No. 24-1285, precedential opinion affirming issued 3/19/26.
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