DCT
1:18-cv-00658
Coding Tech LLC v. Control4 Corp
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Coding Technologies, LLC (Texas)
- Defendant: Control4 Corp (Delaware)
- Plaintiff’s Counsel: Stamoulis & Weinblatt, LLC; Watson LLP
- Case Identification: 1:18-cv-00658, D. Del., 04/30/2018
- Venue Allegations: Venue is alleged to be proper because the Defendant is a citizen of the State of Delaware and resides in the judicial district.
- Core Dispute: Plaintiff alleges that Defendant's method of providing content to users via QR codes, as practiced during internal use and testing, infringes a patent related to using a mobile device to scan a code pattern to retrieve online content.
- Technical Context: The technology involves using a camera-equipped mobile terminal to capture and decode a visual code pattern, thereby automatically accessing linked online content without requiring a user to manually input information like a URL.
- Key Procedural History: The asserted patent is part of a family with a long prosecution history, claiming priority back to multiple Korean applications filed in 2003 and a PCT application filed in 2004. No other procedural events are mentioned in the complaint.
Case Timeline
| Date | Event |
|---|---|
| 2003-03-07 | ’159 Patent - Earliest Priority Date |
| 2013-09-24 | ’159 Patent - Issue Date |
| 2017-06-27 | Alleged Infringing Act (Scan Date) |
| 2018-04-30 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,540,159 - "Method for Providing Mobile Service Using Code-Pattern," Issued September 24, 2013
The Invention Explained
- Problem Addressed: The patent identifies the inconvenience and inefficiency of users needing to manually remember and type Uniform Resource Locators (URLs) from advertisements into a mobile device to access websites (’159 Patent, col. 1:45-50; Compl. ¶10).
- The Patented Solution: The invention provides a system where a user employs a mobile terminal's camera to photograph a "code pattern" (such as a QR code or barcode). The terminal's processor then automatically decodes the pattern, extracts information (e.g., a URL), and uses it to request and receive content from a server, bridging the gap between a physical object and online information (’159 Patent, Abstract; col. 8:41-51).
- Technical Importance: This approach significantly simplified the process for users to access web content linked from physical media, a key development for mobile marketing and information retrieval as camera-equipped smartphones became ubiquitous (Compl. ¶10, ¶12).
Key Claims at a Glance
- The complaint asserts independent claims 1 (method), 8 (user terminal), 15 (non-transitory medium), and 16 (method), along with dependent claims 2, 3, 9, and 10 (Compl. ¶16).
- Independent Claim 1 (Method):
- obtaining a photographic image of a code pattern by a camera of the user terminal;
- processing, by a processor of the user terminal, the photographic image of the code pattern to extract the code pattern from the photographic image;
- decoding the extracted code pattern by the processor of the user terminal into code information;
- transmitting a content information request message to a server based on the code information; and
- receiving content information from the server in response to the content information request message.
- Independent Claim 8 (Apparatus):
- a camera configured to obtain a photographic image of a code pattern;
- a processor comprising: an image processor configured to process the photographic image of the code pattern to extract the code pattern from the photographic image; and a decoder configured to decode the extracted code pattern into code information; and
- a transceiver configured to (i) transmit a content information request message to a server based on the code information; and (ii) receive content information from the server in response to the content information request message.
- The complaint reserves the right to assert additional claims (Compl. ¶16).
III. The Accused Instrumentality
Product Identification
The complaint accuses Control4 of practicing an infringing method of providing content through "internal use and testing" (Compl. ¶19). This method involves using a "user terminal (e.g., a smartphone)" to scan a QR code that links to a Control4 webpage (Compl. ¶19).
Functionality and Market Context
The accused functionality is the end-to-end process of using a smartphone to scan a QR code provided by Control4, which directs the user's device to the URL "http://ctrl4.co/alexa" (Compl. ¶22). This URL leads to a Control4 webpage providing information on its smart home products' integration with Amazon's Alexa service (Compl. ¶20, ¶24). The complaint provides a screenshot of an iPhone 7 camera viewfinder pointed at the QR code, illustrating the accused scanning step (Compl. p. 6).
IV. Analysis of Infringement Allegations
'159 Patent Infringement Allegations (Claim 1 - Method)
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| obtaining a photographic image of a code pattern by a camera of the user terminal; | Defendant, in testing, obtains a photographic image of a QR code using a smartphone's camera. The complaint includes a screenshot of this action. | ¶20 | col. 37:37-39 |
| processing, by a processor of the user terminal, the photographic image of the code pattern to extract the code pattern from the photographic image; | The smartphone's processor (e.g., an iPhone's A10 Fusion chip) processes the captured image to extract the QR code pattern. | ¶21 | col. 37:40-43 |
| decoding the extracted code pattern by the processor of the user terminal into code information; | The processor decodes the QR code pattern into code information, specifically the URL "http://ctrl4.co/alexa". A screenshot shows this decoded URL. | ¶22 | col. 37:44-46 |
| transmitting a content information request message to a server based on the code information; | The smartphone transmits an HTTP request to Defendant's server based on the decoded URL. The complaint illustrates this with a diagram showing the "Scan -> Decode -> Action" flow. | ¶23 | col. 37:47-49 |
| receiving content information from the server in response to the content information request message. | The smartphone receives the webpage associated with the URL from Defendant's server. A screenshot of the resulting Control4 webpage is provided as evidence. | ¶24 | col. 37:50-52 |
'159 Patent Infringement Allegations (Claim 8 - User Terminal)
| Claim Element (from Independent Claim 8) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a camera configured to obtain a photographic image of a code pattern; | The user terminal (e.g., smartphone) used in testing comprises a camera configured to obtain a photographic image of the QR code. | ¶34 | col. 39:10-12 |
| a processor comprising: an image processor configured to process the photographic image ... to extract the code pattern ...; and a decoder configured to decode the extracted code pattern into code information; | The smartphone's processor is alleged to comprise an image processor that extracts the QR code pattern from the image and a decoder that decodes it into a URL. | ¶35, ¶36 | col. 39:13-19 |
| and a transceiver configured to (i) transmit a content information request message to a server ...; and (ii) receive content information from the server ... | The smartphone comprises a transceiver (e.g., FDD-LTE/TDD-LTE/CDMA/EDGE) configured to transmit the HTTP request and receive the webpage content. A screenshot of an iPhone's cellular specifications is provided. | ¶37 | col. 39:20-25 |
- Identified Points of Contention:
- Scope Questions: The complaint's allegations are based on "at least in internal use and testing" (Compl. ¶19). A potential issue for the court is whether this limited activity is sufficient to establish infringement and warrant the requested relief, or if it is primarily a basis to seek an injunction against future commercial activities.
- Technical Questions: The complaint maps the accused functionality of a standard smartphone to the claim elements. For apparatus claim 8, a question may arise as to whether a general-purpose processor running integrated QR-scanning software contains a distinct "image processor" and "decoder" as contemplated by the patent, or if these are merely functional descriptions of a single, undifferentiated software process. The complaint does not provide evidence distinguishing these two functions within the accused smartphone's processor (Compl. ¶35, ¶36).
V. Key Claim Terms for Construction
The Term: "code pattern"
Context and Importance: This term appears in all asserted independent claims and defines the scannable object. Its construction will determine whether the patent covers a broad range of 2D codes, such as the accused QR code, or is limited to more specific embodiments disclosed in the patent.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent's title and initial description refer generally to a "code-pattern" ('159 Patent, Title; col. 1:20-22). The claims themselves use this general term without express limitation to a specific type.
- Evidence for a Narrower Interpretation: The specification frequently uses "barcode" as a synonym or example of a "code pattern" (e.g., "the mobile terminal reads the code pattern (barcode)," col. 2:20-22). It also provides specific examples, stating the "barcode 60 includes a one-dimensional barcode, and a PDF-417 code, a QR code and a data matrix, which are two-dimensional barcodes" ('159 Patent, col. 11:1-5). A party could argue the term's scope should be viewed in light of these specific examples.
The Term: "characteristic information"
Context and Importance: This term appears in independent claim 16, which is an alternative method claim. Instead of "decoding the extracted code pattern... into code information," claim 16 requires "processing... the photographic image to extract characteristic information." The relationship between "code information" and "characteristic information" will be critical to determining the scope of claim 16 relative to claim 1.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that "characteristic information" is a broader term than "code information," potentially covering any identifiable feature extracted from an image, not just information from a formally structured code. The patent does not appear to explicitly define the term.
- Evidence for a Narrower Interpretation: A party could argue that, in the context of the patent as a whole, "characteristic information" must be information that functions like the "code information" in other claims—that is, information capable of identifying and leading to specific server content. The complaint appears to treat them as equivalent, alleging the extraction of a URL as the "characteristic information" (Compl. ¶56, ¶57).
VI. Other Allegations
- Indirect Infringement: The complaint includes boilerplate allegations of contributory and induced infringement (Compl. ¶15). However, the pleading does not contain specific factual allegations detailing how Defendant instructs or provides means for others to infringe, focusing instead on direct infringement through internal testing.
- Willful Infringement: The complaint alleges willful infringement based on Defendant’s purported knowledge of the ’159 Patent (Compl. ¶58). This is presented "upon information and belief" and does not include specific facts to substantiate pre-suit knowledge of the patent or its infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of infringing act and remedy: Will the complaint's allegations of "internal use and testing" be sufficient to prove infringement and support a claim for damages, or is the primary dispute centered on enjoining future commercial use of the accused method?
- A key evidentiary question will be one of structural definition: For the apparatus claims, does a general-purpose smartphone processor running integrated QR-scanning software satisfy the limitation of a "processor comprising" a distinct "image processor" and a "decoder," or does the patent require greater structural or functional separation between these components?
- A central question of claim construction will be the scope of key terms across different claims: can "code pattern" (Claim 1), "characteristic information" (Claim 16), and the accused QR code all be treated as coextensive, as the plaintiff's infringement theory suggests?