DCT
1:20-cv-00307
Coding Tech LLC v. Eventbrite Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Coding Technologies, LLC (Texas)
- Defendant: Eventbrite, Inc. (Delaware)
- Plaintiff’s Counsel: Chong Law Firm
- Case Identification: 1:20-cv-00307, D. Del., 03/01/2020
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because the Defendant is a Delaware corporation and is therefore deemed to be a resident of the district.
- Core Dispute: Plaintiff alleges that Defendant’s event ticketing platform, which utilizes QR codes on tickets for mobile device interaction, infringes a patent related to methods for using a mobile device to scan a code pattern and retrieve online content from a server.
- Technical Context: The technology involves using a camera-equipped mobile device to scan a visual code, thereby bridging physical media with online information without requiring manual data entry.
- Key Procedural History: The asserted patent is part of a family with a long prosecution history, originating from a 2004 PCT application which itself claimed priority to 2003 Korean applications. This history may be relevant for issues of claim construction and potential prosecution history estoppel. No prior litigation or post-grant proceedings are mentioned in the complaint.
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 |
| 2020-03-01 | 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 low likelihood of a user manually remembering and typing a website URL found on physical media (like a newspaper or magazine) into a mobile device to access related content (’159 Patent, col. 1:43-50).
- The Patented Solution: The invention provides a method where a user employs a camera-equipped mobile terminal to take a photograph of a "code-pattern" (e.g., a barcode or QR code). The terminal then automatically processes the image, decodes the pattern into information like a URL, transmits a request to a server based on that information, and receives corresponding content, thereby streamlining the process of linking physical objects to online services (’159 Patent, Abstract; Fig. 5).
- Technical Importance: The technology provides a more convenient and direct method for users to access various services and content from mobile terminals, effectively bridging the gap between physical advertisements and interactive digital content (’159 Patent, col. 1:31-34).
Key Claims at a Glance
- The complaint asserts infringement of "one or more claims, including at least Claim 1" (Compl. ¶13).
- Independent Claim 1 of the ’159 Patent contains the following essential elements:
- 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.
III. The Accused Instrumentality
Product Identification
- The accused instrumentality is Defendant Eventbrite, Inc.’s ticketing platform and services, specifically the function that incorporates QR codes onto event tickets (Compl. ¶¶13-14).
Functionality and Market Context
- The complaint alleges that Eventbrite provides promotional media (e.g., event tickets) containing a QR code. A user with a smartphone or similar user terminal can scan this code. The terminal’s processor then obtains a URL from the code, sends an http request to an Eventbrite server, and receives a webpage with promotional or event-related information (Compl. ¶¶14, 18-19). The complaint provides visual evidence illustrating this process, from an exemplary ticket with a QR code to the final webpage displayed on the user's device (Compl. ¶14). This series of screenshots depicts the alleged end-to-end infringing process. (Compl. ¶14, p. 3).
IV. Analysis of Infringement Allegations
U.S. Patent No. 8,540,159 Infringement Allegations
| 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 user obtains an image of the QR code on an Eventbrite ticket using the camera of a smartphone. A provided screenshot shows a smartphone camera view framing a QR code for scanning. (Compl. ¶15, p. 4). | ¶15 | col. 10:9-19 |
| processing, by a processor of the user terminal, the photographic image of the code pattern to extract the code pattern from the photographic image; | A processor of the user terminal processes the photographic image to extract the QR code pattern from the image. The complaint provides a screenshot showing the QR code isolated within the camera's view. (Compl. ¶16, p. 4). | ¶16 | col. 10:20-24 |
| decoding the extracted code pattern by the processor of the user terminal into code information; | The smartphone processor decodes the extracted QR code pattern into code information, specifically the URL of a webpage associated with the defendant. A screenshot shows the decoded URL as a hyperlink. (Compl. ¶17, p. 5). | ¶17 | col. 10:20-24 |
| transmitting a content information request message to a server based on the code information; | The user terminal sends a content information request (e.g., an http request) to the defendant’s server based on the decoded URL. A screenshot shows the phone's browser navigating to the decoded URL. (Compl. ¶18, p. 6). | ¶18 | col. 10:52-55 |
| and receiving content information from the server in response to the content information request message. | The user terminal receives a webpage from the defendant’s server in response to the request. A screenshot illustrates the loaded webpage with promotional content on the smartphone's screen. (Compl. ¶19, p. 6). | ¶19 | col. 2:48-51 |
- Identified Points of Contention:
- Scope Questions: Claim 1 recites two distinct steps: "processing...to extract the code pattern" and then "decoding the extracted code pattern." A primary point of contention may be whether the accused functionality, such as a standard QR reader application, performs these as two separate, sequential steps as required by the claim language, or as a single, integrated function. The defense may argue the latter, suggesting a mismatch with the claim's scope.
- Technical Questions: The complaint alleges that the user's terminal performs the method steps. This raises the question of Eventbrite's liability. The case will require evidence demonstrating whether Eventbrite's role in providing the QR code and the destination server constitutes direct infringement under a "use" theory, or whether liability is based on an indirect infringement theory (e.g., inducement).
V. Key Claim Terms for Construction
- The Term: "processing...to extract the code pattern from the photographic image"
- Context and Importance: This term, and its relationship to the subsequent "decoding" step, appears central to the infringement analysis. The court's construction will determine whether performing a single, integrated scan-and-decode operation meets the claim limitations. Practitioners may focus on this term because the patent's validity and infringement positions could depend on whether these are construed as one step or two.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent’s abstract describes the method as "decoding the photographed code pattern image so as to obtain code information," which may suggest a single, unified action (’159 Patent, Abstract). The specification's description of the "decoder 13" also appears to describe a single function of analyzing the image data to "extract code information" (’159 Patent, col. 10:20-24).
- Evidence for a Narrower Interpretation: The plain language of Claim 1 itself, which presents "processing" and "decoding" in two separate clauses, provides the strongest evidence for an interpretation requiring two distinct actions (’159 Patent, col. 38:40-46). A party could argue that this linguistic separation was intentional and must be given effect.
VI. Other Allegations
- Indirect Infringement: The complaint does not include separate counts for indirect infringement. However, the factual allegations describe a method performed by a "user terminal" (Compl. ¶¶15-19) in response to a QR code provided by the Defendant (Compl. ¶14). This structure suggests a potential, unstated theory of induced infringement, where Eventbrite is alleged to have infringed by providing the means (the QR code) and intending for its users to perform the patented method.
- Willful Infringement: The complaint does not include allegations of willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction: does the language of Claim 1 require two distinct and sequential steps—first "processing...to extract the code pattern" and then "decoding" it—or can the claim be read to cover a single, integrated operation performed by a standard QR code reader?
- A key legal question will be the theory of liability: as the end-user's device is alleged to perform the patented method, the case will turn on whether Plaintiff can prove that Eventbrite's actions of generating the QR code and operating the target server constitute direct infringement, or whether the claim is for indirect infringement by inducing end-users to infringe.