DCT
1:24-cv-00733
Alliance Laundry Systems LLC v. PayRange LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Alliance Laundry Systems LLC (Delaware)
- Defendant: PayRange Inc. (Tennessee)
- Plaintiff’s Counsel: Young Conaway Stargatt & Taylor, LLP; Honigman LLP
- Case Identification: 1:24-cv-00733, D. Del., 06/20/2024
- Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant is subject to personal jurisdiction there and because a substantial part of the events giving rise to the claim, including Defendant’s prior patent enforcement actions on related patents, occurred within the district.
- Core Dispute: Plaintiff seeks a declaratory judgment that its "Speed Queen" and "Huebsch" mobile payment applications do not infringe three of Defendant’s patents related to mobile payment systems for automated machines.
- Technical Context: The technology involves using smartphone applications to facilitate wireless payments for services from unattended, payment-operated machines, such as commercial laundry equipment.
- Key Procedural History: The complaint details extensive prior litigation involving the patents-in-suit and their family members against other parties. Notably, during a dispute with CSC Serviceworks, Defendant PayRange disclaimed numerous claims of U.S. Patent No. 11,481,772 (’772 Patent). Subsequently, the Patent Trial and Appeal Board (PTAB) instituted an inter partes review of the sole remaining asserted claim of the ’772 Patent (claim 11), finding a "reasonable likelihood" that the claim was unpatentable. That proceeding was terminated following a settlement before a final written decision was issued.
Case Timeline
| Date | Event |
|---|---|
| 2013-12-18 | Priority Date for ’772, ’920, and ’423 Patents |
| 2022-10-25 | U.S. Patent No. 11,481,772 Issued |
| 2023-11-22 | PayRange disclaims claims 1-6, 8-10, and 12-20 of the ’772 Patent |
| 2024-04-12 | PTAB institutes inter partes review of claim 11 of the ’772 Patent |
| 2024-04-23 | U.S. Patent No. 11,966,920 Issued |
| 2024-04-30 | U.S. Patent No. 11,972,423 Issued |
| 2024-06-20 | Complaint for Declaratory Judgment Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,481,772 - Method and System for Presenting Representations of Payment Accepting Unit Events
- Patent Identification: U.S. Patent No. 11,481,772, "Method and System for Presenting Representations of Payment Accepting Unit Events," issued October 25, 2022.
The Invention Explained
- Problem Addressed: The patent background describes the conventional, multi-step process for using payment-operated machines (e.g., vending machines), which involves physical interaction for payment (inserting coins, bills, or cards) and selection. The patent identifies mobile payment as a logical extension to increase user convenience. (’772 Patent, col. 1:45-2:18).
- The Patented Solution: The invention provides a method for a mobile device to facilitate a cashless transaction with a nearby payment-accepting machine. The mobile device's application identifies a machine, displays a user interface for payment, establishes a "non-persistent network connection" with an adapter module on the machine, and allows the user to trigger payment and complete the transaction. (’772 Patent, Abstract; col. 2:20-24). This system is designed to retrofit existing machines to accept mobile payments without requiring the machine itself to have a persistent internet connection. (’772 Patent, col. 6:42-53).
- Technical Importance: The described solution aims to enable mobile payments on a wide range of legacy, offline-payment machines by using the user's smartphone as the bridge for communication and authorization. (’772 Patent, col. 6:42-53).
Key Claims at a Glance
- The complaint seeks a declaratory judgment of non-infringement of dependent claim 11, which incorporates all the limitations of independent claim 1. (Compl. ¶¶69-70).
- Independent Claim 1 requires, among other elements:
- A method performed at a mobile device for presenting payment events.
- Identifying a nearby payment-operated machine available to accept payment.
- Displaying a user interface to show the machine and accept user input to select the machine and trigger payment.
- Establishing a "wireless communication path including the mobile device and the available payment accepting unit."
- Enabling user interaction with the interface to complete the transaction after the path is established.
- Exchanging information with the machine and displaying an updated user interface.
- Dependent Claim 11 further specifies that the user interface includes "an affordance that when slid, indicates the initiation of the transaction," and that this affordance is slid in response to a "user input of swipe." (’772 Patent, col. 48:28-34).
U.S. Patent No. 11,966,920 - Method and System for Presenting Representations of Payment Accepting Unit Events
- Patent Identification: U.S. Patent No. 11,966,920, "Method and System for Presenting Representations of Payment Accepting Unit Events," issued April 23, 2024.
The Invention Explained
- Problem Addressed: As a continuation in the same family as the ’772 Patent, this patent addresses the same technical problem of enabling convenient mobile payments on traditionally offline, payment-operated machines. (’920 Patent, col. 1:47-2:22).
- The Patented Solution: The invention is directed to a similar method and system where a mobile device discovers, communicates with, and authorizes payment for a transaction on a nearby machine. The claims of the ’920 Patent describe a user interface that includes a visual representation of the machine, a balance indication, and "an affordance that, in response to a user input, indicates completion of the transaction." (’920 Patent, Abstract; col. 47:32-35).
- Technical Importance: The technical contribution is consistent with that of the ’772 patent family, focusing on retrofitting legacy machines for mobile payment using the user's device as a communication conduit. (’920 Patent, col. 6:48-59).
Key Claims at a Glance
- The complaint asserts non-infringement of independent claims 1 (a method), 13 (a mobile device), and 15 (a non-transitory computer readable storage medium). (Compl. ¶¶80-82).
- Each independent claim requires the essential elements of:
- Identifying a nearby payment-operated machine.
- Displaying a user interface for selecting the machine.
- Establishing a "wireless communication path including the mobile device and the available payment accepting unit."
- Enabling user interaction to complete the transaction via a user interface that includes a visual representation of the machine, a balance, and an affordance indicating completion.
- Exchanging information with the machine and updating the user interface.
- The complaint states that PayRange has asserted dependent claims 2-6, 8, 9, 12-14, and 16-20. (Compl. ¶86).
U.S. Patent No. 11,972,423 - Method and System for Presenting Representations of Payment Accepting Unit Events
- Patent Identification: U.S. Patent No. 11,972,423, "Method and System for Presenting Representations of Payment Accepting Unit Events," issued April 30, 2024. (Compl. ¶18).
- Technology Synopsis: This patent, also a continuation from the ’772 patent family, describes a method and system for enabling a mobile device to conduct transactions with nearby payment-operated machines. The core technology involves the mobile device identifying a machine, displaying a user interface for payment, and establishing a wireless communication path to facilitate the transaction. (’423 Patent, Abstract).
- Asserted Claims: Independent claims 1, 13, and 15. (Compl. ¶94).
- Accused Features: The complaint’s non-infringement argument focuses on the "establishing... a wireless communication path" limitation, alleging the accused "Speed Queen" and "Huebsch" applications do not practice this claimed step. (Compl. ¶¶95-96).
III. The Accused Instrumentality
Product Identification
- The "Speed Queen" and "Huebsch" mobile applications and their associated payment systems. (Compl. ¶52).
Functionality and Market Context
- These applications allow users to pay for and operate commercial laundry machines. (Compl. ¶¶1, 52). The complaint alleges a specific technical architecture for these systems: the mobile applications establish a wireless communication path not with the laundry machine itself, but with "online cloud services." (Compl. ¶74). These cloud services then communicate with a "gateway" device located in the laundromat, which in turn has a separate connection to the laundry machine. (Compl. ¶74, 85, 96). The complaint includes a composite image from application storefronts showing the user interfaces of the accused "Speed Queen" and "Huebsch" applications, which display options to pay and check machine availability. (Compl. ¶52). The complaint further alleges that the user interface for initiating a payment utilizes a "button," not a sliding gesture. (Compl. ¶75).
IV. Analysis of Infringement Allegations
’772 Patent Infringement Allegations
| Claim Element (from Independent Claim 1 and Dependent Claim 11) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| establishing via the one or more radio transceivers a wireless communication path including the mobile device and the available payment accepting unit of the one or more payment accepting units | The accused applications establish a wireless path only between the mobile device and remote cloud services; a separate gateway connects the cloud to the laundry machine. | ¶74 | col. 47:30-34 |
| an affordance that when slid, indicates the initiation of the transaction; wherein the affordance is slid in response to receiving a user input of swipe on the affordance | The accused applications utilize a "button" for payment initiation, not a "sliding" feature or a "swipe" input. | ¶75 | col. 48:28-34 |
- Identified Points of Contention:
- Scope Questions: A primary dispute will be whether the claim term "wireless communication path including the mobile device and the available payment accepting unit" can be construed to cover an architecture intermediated by a remote cloud server and a local gateway.
- Technical Questions: For the "sliding affordance" element, where infringement is alleged under the doctrine of equivalents, a key question is whether a button-press function is substantially different from the claimed sliding function. The complaint argues that asserting equivalence would "wholly eviscerate" the sliding limitation. (Compl. ¶75).
’920 Patent Infringement Allegations
| Claim Element (from Independent Claims 1, 13, and 15) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| establishing via the one or more radio transceivers a wireless communication path including the mobile device and the available payment accepting unit of the one or more payment accepting units | The only wireless path is between the mobile device and online cloud services. A separate, local gateway communicates with the laundry machine. | ¶85 | col. 47:22-26 |
- Identified Points of Contention:
- Scope Questions: The central point of contention for the ’920 Patent is identical to that for the ’772 Patent: what is the scope of a "wireless communication path including" the two named endpoints? Does it permit the specific cloud-based intermediary architecture used by the accused systems?
V. Key Claim Terms for Construction
The Term: "an affordance that when slid, indicates the initiation of the transaction" (’772 Patent, Claim 11).
Context and Importance: This term is critical because the accused products allegedly use a "button," making literal infringement unlikely. The defendant's case for infringement of claim 11 appears to rely on the doctrine of equivalents. Practitioners may focus on this term to determine if the specific action of "sliding" is a patentable element distinct from a generic user input like a button press.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification discusses a "swipe-to-pay" mode generally as a form of user interaction to transfer a prepaid balance. (’772 Patent, col. 7:10-24). One might argue "slid" is merely an exemplary form of a direct manipulation user input for payment.
- Evidence for a Narrower Interpretation: The claim language itself is specific, using both "slid" and "swipe." The patent figures depict a user interface with a directional arrow icon, suggesting a sliding motion is contemplated. (’772 Patent, Fig. 10A, element 152). The specification repeatedly refers to a "swipe mode embodiment," which may support a construction limited to that specific gesture. (’772 Patent, col. 3:16-18).
The Term: "wireless communication path including the mobile device and the available payment accepting unit" (’772 Patent, Claim 1; ’920 Patent, Claim 1).
Context and Importance: This term is the central technical dispute across all three patents-in-suit. Alliance's non-infringement position hinges on its argument that its cloud-intermediated architecture does not meet this limitation.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim uses the word "including," which could be argued to be non-limiting, suggesting the path must involve the two endpoints but does not exclude other components like servers or gateways.
- Evidence for a Narrower Interpretation: The specification consistently describes a "non-persistent network connection" and focuses on short-range communication protocols like Bluetooth (BLE). (’772 Patent, col. 2:20-24; col. 5:58-6:2). Figures in the patent, such as Figure 5 and Figure 7, depict a direct wireless link between an "Adapter Module" on the machine and the "Mobile Device," with the mobile device then using a separate link (e.g., WiFi or Cellular) to reach a remote server. This strongly suggests the claimed "wireless communication path" is the direct, short-range link between the device and the machine, not a path that routes through the internet.
VI. Other Allegations
- Indirect Infringement: The complaint notes that Defendant’s demand letters accused Alliance of direct infringement as well as contributory infringement or inducement. (Compl. ¶5). The complaint does not, however, detail the specific facts alleged by Defendant to support the knowledge and intent elements required for such claims.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of architectural scope: does the claimed "wireless communication path including the mobile device and the available payment accepting unit," which the patent specification illustrates as a direct, short-range Bluetooth connection, read on the accused system’s architecture that routes communications from the mobile device through a remote cloud server and a local gateway before reaching the machine?
- A key infringement question specific to the ’772 patent will be one of vitiation under the doctrine of equivalents: does the specific claim requirement of an "affordance that when slid" in response to a "swipe" represent a central, limiting feature of the invention, such that finding infringement by a "button" interface would improperly eliminate that element from the claim?