In June 2022, SmartWatch Mobileconcepts LLC (SWM) voluntarily dismissed, without prejudice, a Western District of Texas case that it had filed roughly three weeks earlier against Philips (Philips North America) over a single patent generally related to allowing access to a “secured electronic system” after authenticating a user through biometric information obtained from a wearable device. Now, in a new Western District of Texas complaint against the same defendant (6:23-cv-00775), SWM again targets provision of the Lifeline medical alert wearable with that same patent, this time pleading that Philips has had prefiling knowledge of that patent, reaching back to the June 2022 complaint.