DCT
1:18-cv-00660
Coding Tech LLC v. Rexnord Corp
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Coding Technologies, LLC (Texas)
- Defendant: Rexnord Corp (Wisconsin)
- Plaintiff’s Counsel: STAMOULIS & WEINBLATT, LLC
- Case Identification: 1:18-cv-00660, D. Del., 04/30/2018
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant resides in the judicial district.
- Core Dispute: Plaintiff alleges that Defendant’s use of QR codes to direct users to its product webpages via mobile devices infringes a patent related to providing mobile services using code patterns.
- Technical Context: The technology involves using a camera-equipped mobile device to scan a visual code (such as a QR code) to automatically retrieve information from a remote server, bypassing the need for manual data entry like typing a URL.
- Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2003-03-07 | U.S. Patent No. 8,540,159 Priority Date |
| 2013-09-24 | U.S. Patent No. 8,540,159 Issue Date |
| 2017-06-20 | Date of alleged infringing activity documented in packet capture |
| 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"
- Patent Identification: 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 difficulty for users in manually remembering and typing website URLs from advertisements or guidebooks into a mobile device (’159 Patent, col. 1:44-50). It also notes that travelers may have difficulty finding sufficient travel or location information from conventional sources like guidebooks (ʼ159 Patent, col. 1:51-61).
- The Patented Solution: The invention describes a system where a user employs a mobile terminal with a camera to take a photographic image of a code pattern (e.g., a barcode or QR code). The terminal then automatically decodes the pattern, extracts information such as a URL, and communicates with a server to retrieve and display relevant content, thereby streamlining access to online information (’159 Patent, Abstract; Fig. 5).
- Technical Importance: This approach automates the "physical world hyperlink," connecting physical objects or print media to online digital content, a foundational concept for mobile-based augmented reality and marketing. (’159 Patent, col. 2:20-24).
Key Claims at a Glance
- The complaint asserts independent claims 1, 8, 15, and 16.
- Independent Claim 1 (Method):
- obtaining a photographic image of a code pattern by a camera of the user terminal;
- processing the photographic image to extract the code pattern;
- decoding the extracted code pattern into code information;
- transmitting a content information request message to a server based on the code information; and
- receiving content information from the server.
- Independent Claim 8 (Apparatus):
- a camera configured to obtain a photographic image of a code pattern;
- a processor comprising an image processor (to extract the pattern) and a decoder (to create code information); and
- a transceiver configured to transmit a request message to a server and receive content information from the server.
- The complaint also asserts claims 2-4, 9-11, 15, and 16, and reserves the right to assert other dependent claims (Compl. ¶16).
III. The Accused Instrumentality
Product Identification
- The accused instrumentality is a method, allegedly performed by Defendant "at least in internal use and testing," involving the use of a smartphone to scan a QR code associated with Defendant's products (e.g., P4B-207-T Spherical Roller Bearings) to access Defendant's product webpages (Compl. ¶15, ¶19).
Functionality and Market Context
- The accused functionality involves providing QR codes that, when scanned by a user's smartphone, initiate a process of decoding the URL embedded in the code, sending an HTTP request to Defendant's server, and receiving a webpage with product information (Compl. ¶19-24). The complaint provides screenshots illustrating this process, from scanning a QR code to viewing the resulting product page on rexnord.com (Compl. p. 5). This functionality allows customers to quickly access detailed technical specifications and information for industrial products like roller bearings directly from a mobile device.
IV. Analysis of Infringement Allegations
U.S. Patent No. 8,540,159 Infringement Allegations (Claim 1)
| 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; | A smartphone's camera is used to capture an image of a QR code provided by Defendant. A visual provided in the complaint depicts a smartphone camera pointed at a QR code. (Compl. p. 5). | ¶20 | col. 38:7-8 |
| 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 (identified as an iPhone 7's A10 Fusion chip) is alleged to process the captured image to isolate the QR code pattern. | ¶21 | col. 38:9-12 |
| decoding the extracted code pattern by the processor of the user terminal into code information; | The smartphone's processor decodes the QR code pattern into code information, such as the URL for a webpage. The complaint includes a diagram illustrating a "Decode" step. (Compl. p. 7). | ¶22 | col. 38:13-15 |
| transmitting a content information request message to a server based on the code information; | The smartphone transmits an HTTP GET request to Defendant's server using the decoded URL. The complaint presents network packet capture data as evidence of this transmission. (Compl. p. 12). | ¶23 | col. 38:16-18 |
| and receiving content information from the server in response to the content information request message. | The smartphone receives and displays the Rexnord product webpage from the server. A screenshot shows the webpage for "P4B-207-T Spherical Roller Bearings" loaded on the device. (Compl. p. 8). | ¶24 | col. 38:19-21 |
U.S. Patent No. 8,540,159 Infringement Allegations (Claim 8)
| 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 accused user terminal (a smartphone) comprises a camera used to photograph the QR code. | ¶39 | col. 39:9-11 |
| 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 perform the image processing and decoding functions to extract a URL from the QR code. | ¶40-41 | col. 39:12-17 |
| 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's cellular/wireless transceiver (e.g., FDD-LTE) is alleged to transmit the HTTP request and receive the webpage data. The complaint references the technical specifications for an iPhone 7. (Compl. p. 16). | ¶42 | col. 39:18-23 |
Identified Points of Contention
- Attribution Questions: The complaint alleges direct infringement based on Defendant's "internal use and testing" (Compl. ¶19). A primary point of contention may be whether Plaintiff can prove that Rexnord, as a corporate entity, performed all steps of the claimed method. Method claims are typically infringed by the party performing the actions, which in this context is often the end-user, raising questions about whether direct infringement by Rexnord can be established or if the case centers more on the indirect infringement claims.
- Technical Questions: The complaint alleges a multi-stage server interaction, where a request goes to an "intermediate system" which then contacts "Defendant's web server" (Compl. ¶33, ¶52). The defense may question whether this distributed architecture maps onto the more simplified "server" recited in the claims, potentially creating a mismatch between the accused process and the claim language.
V. Key Claim Terms for Construction
The Term: "user terminal" (Claims 1, 8, 15, 16)
Context and Importance: The identity of the "user" is central to the direct infringement theory. Practitioners may focus on this term because if "user" is construed to mean only an individual end-consumer, it could undermine the allegation that Rexnord itself directly infringed by performing "internal testing." This would shift the focus of the case entirely to indirect infringement.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims themselves do not explicitly restrict the "user" to any particular type of entity. The term "user terminal" is a general term for a device operated by an entity to perform the claimed functions.
- Evidence for a Narrower Interpretation: The patent's background repeatedly frames the problem and solution in the context of individual consumers and travelers (e.g., "a person, who reads the advertisement," "Travelers carry a guidebook") (’159 Patent, col. 1:44-51). This context could be used to argue that the claimed "user" is intended to be an individual end-user, not a corporate entity.
The Term: "characteristic information" (Claim 16)
Context and Importance: Claim 16 uses "characteristic information" where other claims use "code pattern" or "code information." Its construction is important to determine the scope of this independent claim and whether it is substantively different from claim 1.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: "Characteristic information" is a broad term and is not explicitly defined. It could be argued to encompass any information extracted from an image that characterizes it, including the data from a QR code.
- Evidence for a Narrower Interpretation: The specification consistently uses the terms "code pattern," "barcode," and "code information" to describe the invention (’159 Patent, Abstract; col. 2:40-52). The use of a different term, "characteristic information," in a single claim without an explicit definition raises the question of whether it was intended to have the same or a different meaning.
VI. Other Allegations
- Indirect Infringement: The complaint alleges contributory and induced infringement, stating Defendant provides a "user terminal designed to capture" code information (Compl. ¶15). The factual basis appears to be Defendant’s creation and provision of the QR codes and the associated web infrastructure, which enables and allegedly encourages end-users to perform the infringing method.
- Willful Infringement: Willfulness is alleged based "upon information and belief" that Defendant knew of the ’159 Patent (Compl. ¶68). The complaint does not plead specific facts to support pre-suit knowledge, such as a notice letter or prior litigation.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of attribution: Can Plaintiff successfully argue that Defendant Rexnord, a corporation, is a "user" that directly infringed the patent through "internal use and testing," or will the case hinge on proving indirect infringement by showing Rexnord induced its customers to infringe?
- A key legal question will be one of claim scope: How will the court construe the term "user terminal"? If the court limits the term to an individual end-consumer based on the patent's specification, it may preclude a finding of direct infringement against the corporate defendant.
- A central evidentiary question will be one of proof: Beyond the technical evidence of packet captures showing the process was performed, what factual evidence can Plaintiff offer to demonstrate that the alleged acts of infringement were specifically conducted by Defendant Rexnord as part of "internal use and testing" rather than by an unaffiliated third party?