DCT
1:25-cv-00685
Gocodes Inc v. Life360 Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: GoCodes, Inc. (Minnesota)
- Defendant: Life360, Inc. and Tile, Inc. (Delaware)
- Plaintiff’s Counsel: Phillips, McLaughlin & Hall, P.A.; Husch Blackwell LLP; The Simon Law Firm, P.C.
- Case Identification: 1:25-cv-00685, D. Del., 06/03/2025
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendants are incorporated in Delaware, have committed acts of infringement in the district, are deemed to reside there, and have regular and established places of business in the district.
- Core Dispute: Plaintiff alleges that Defendants’ QR code-enabled personal item trackers and labels infringe a patent related to systems for facilitating the return of lost property using scannable visual tags linked to unique web pages.
- Technical Context: The technology involves using machine-readable codes (like QR codes) on physical tags to link a lost item to a cloud-based service that manages owner-specified contact information and privacy settings to facilitate the item's return.
- Key Procedural History: Plaintiff alleges it sent a notice letter with claim charts to Defendants on July 1, 2024, putting them on actual notice of the alleged infringement. The complaint notes that Defendant Life360 acquired Defendant Tile in November 2021.
Case Timeline
| Date | Event |
|---|---|
| 2011-04-19 | '813 Patent Priority Date |
| 2015-03-10 | '813 Patent Issue Date |
| 2015-06-30 | '813 Patent Certificate of Correction Issued |
| 2021-11-22 | Life360 announces acquisition of Tile |
| 2024-07-01 | Plaintiff sends notice letter to Defendants |
| 2025-06-03 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,973,813 - "System for Facilitating Return of Lost Property"
- Patent Identification: U.S. Patent No. 8,973,813, "System for Facilitating Return of Lost Property", issued March 10, 2015.
The Invention Explained
- Problem Addressed: The patent identifies the increasing frequency of consumers misplacing or losing valuable portable assets like smartphones and other mobile devices, creating a need for a better way to facilitate their return to the rightful owner (U.S. Patent No. 8,973,813, col. 1:26-34).
- The Patented Solution: The invention describes a system where a unique visual code, such as a QR code, is affixed to a portable asset via a tag. If the item is lost, a finder can scan the code with a camera-equipped device (e.g., a smartphone) to be automatically directed to a unique web page. This page is controlled by the owner through a central vendor's system, allowing the owner to set "privacy preferences" that dictate what contact information or messages are displayed to the finder, thereby facilitating the item's return while managing the owner's privacy (U.S. Patent No. 8,973,813, Abstract; col. 2:3-10; col. 5:29-54).
- Technical Importance: The described system leverages the widespread adoption of smartphones with cameras and internet access to create a more dynamic and secure lost-and-found process than static ID tags, giving property owners control over the information revealed to a stranger who finds their property (U.S. Patent No. 8,973,813, col. 1:47-55).
Key Claims at a Glance
- The complaint asserts independent claim 19 and dependent claims 20 and 22-26 (Compl. ¶16).
- Independent Claim 19 recites a "portable asset recovery system" with two main components:
- A "host processor" with a memory module that hosts a "database of individual user accounts", where each account has at least one "return profile" for a portable asset. This profile includes "privacy preferences" used to create a "unique property page" for the asset.
- A "visual tag" with a symbol containing "embedded information", including a "machine readable internet link" to the unique property page. The tag must be "resiliently attached" to the asset and "accessible to capture by a camera device", which then "directly accesses and displays" the page.
- The complaint reserves the right to assert additional claims (Compl. ¶33).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are Defendants' "Tile Pro, the Tile Mate, the Tile Slim, the Tile Sticker, and the Tile Lost and Found Labels," specifically those lineups from 2022 and 2024 that feature a QR code (Compl. ¶1, ¶17, ¶26).
Functionality and Market Context
- The accused products are physical tracking devices and labels designed to be attached to personal items like keys and bags (Compl. ¶18). When a user sets up a device, they are prompted to create a user account and a "return profile" by entering contact information and an optional message for a finder (Compl. ¶22, ¶24). Certain Tile products feature a QR code printed on the device (Compl. ¶26). If a third party finds the lost item, they can scan the QR code with a smartphone camera, which directs them to a web page displaying the owner's pre-selected contact information, facilitating the item's return (Compl. ¶27, ¶30). The complaint includes a screenshot from Defendants' website showing how a phone scans a QR code on a Tile label affixed to a water bottle. (Compl. p. 8).
IV. Analysis of Infringement Allegations
'813 Patent Infringement Allegations
| Claim Element (from Independent Claim 19) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a host processor including a memory module hosting a database of individual user accounts, each individual user account including at least one return profile associated with an individual portable asset... | Defendants' servers act as the host processor and database, supporting the creation of individual user accounts linked to specific Tile devices. The complaint provides a screenshot of the Tile app's "Account" screen to support this. (Compl. p. 4). | ¶21 | col. 4:6-12 |
| ...wherein each return profile includes privacy preferences elected by a user, the return profile and privacy preferences being used to create a unique property page that is uniquely associated... | Defendants instruct users to create a return profile by entering contact information (phone number, email) and a custom message. These selections are alleged to be the "privacy preferences" that generate the unique page a finder sees. A screenshot shows the "Add Contact Info" interface. (Compl. p. 6). | ¶22, ¶24 | col. 5:29-38 |
| a visual tag including a symbol containing embedded information, the embedded information including a machine readable internet link to the unique property page... | The QR code printed on the back of the accused Tile devices is alleged to be the "visual tag." This QR code is alleged to contain an internet link to the unique property page for that specific Tile device. The complaint shows images of the Tile Pro and Mate with QR codes labeled "SCAN ME IF FOUND." (Compl. p. 7). | ¶25, ¶26, ¶27 | col. 5:56-59 |
| ...the symbol being accessible to capture by a camera device while the visual tag is resiliently attached to the individual portable asset... | The QR code is printed directly on the devices or on "water-resistant stickers," which the complaint alleges constitutes resilient attachment. The code is accessible to a cellphone camera. | ¶28, ¶29 | col. 4:64-65 |
| ...and wherein the camera device directly accesses and displays the unique property page. | Scanning the QR code on an accused device with a camera is alleged to automatically direct the user to the unique property page containing the owner's contact details. | ¶30 | col. 2:6-10 |
- Identified Points of Contention:
- Scope Questions: A central question may be whether Defendants' combination of a physical device (the Tile tracker) and a separate cloud service (the server/database) meets the claim limitation of "a portable asset recovery system, comprising..." This raises the question of whether the "host processor" and "visual tag" must be understood as components of a single, integrated system provided by one party.
- Technical Questions: The analysis may focus on whether the user's act of entering contact information in the Tile app (Compl. p. 6) constitutes the creation of a "return profile" with "privacy preferences" as taught by the patent. The court may need to determine if providing contact information is equivalent to electing from a set of privacy options as described in the patent's specification (U.S. Patent No. 8,973,813, col. 5:29-54).
V. Key Claim Terms for Construction
The Term: "return profile"
Context and Importance: This term is critical because infringement hinges on whether the information users enter into the Tile system (e.g., phone number, email, message) constitutes a "return profile" as claimed. Practitioners may focus on this term because its definition will determine if Tile's functionality of saving contact information maps onto this specific claim element.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims state the profile "includes privacy preferences elected by a user" (U.S. Patent No. 8,973,813, col. 10:1-2), which could be argued to broadly cover any user choice about what information to display, including simply choosing to enter a phone number.
- Evidence for a Narrower Interpretation: The specification describes a "contract details and privacy preference page" where an owner can choose between public and anonymous communication methods, or even select third-party delivery services to maintain anonymity (U.S. Patent No. 8,973,813, col. 5:29-54). This could support a narrower construction requiring more structured privacy "options" than simply filling in a contact field.
The Term: "resiliently attached"
Context and Importance: The validity of the infringement allegation depends on whether printing a QR code on a device or providing a sticker meets the "resiliently attached" requirement. The defense may argue that the attachment is not sufficiently durable or permanent to qualify as "resilient."
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not appear to provide a specific definition of "resiliently." The specification mentions attachment via a "sticker, key ring or other suitable attachment method" (U.S. Patent No. 8,973,813, col. 5:8-9), suggesting flexibility. This may support an argument that any attachment intended to last for the normal use of the product is sufficient.
- Evidence for a Narrower Interpretation: The term "resiliently" itself implies durability against wear and environmental factors. A party could argue that an ordinary sticker is not inherently resilient and that the patent contemplates a more robust, permanent form of attachment integral to the tag's function over the asset's life.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Defendants "actively encouraged or instructed" customers on how to use the accused products in an infringing manner through materials on their website, such as pages titled "Introducing Lost and Found Labels" (Compl. ¶37).
- Willful Infringement: The complaint alleges willful infringement based on Defendants' alleged knowledge of the '813 Patent since at least July 1, 2024, the date Plaintiff sent a notice letter and infringement claim charts to the CEO of Defendant Life360 (Compl. ¶15, ¶38).
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this dispute may turn on the following central questions:
- A core issue will be one of definitional scope: Does Tile's feature allowing a user to enter contact information and a message constitute a "return profile" that includes "privacy preferences" as those terms are used in the '813 Patent, or does the patent require a more complex set of user-selectable privacy controls?
- A second key question will relate to system architecture: Can Plaintiff successfully argue that Defendants' combination of a physical QR-coded device and a separate back-end server constitutes the single "portable asset recovery system" recited in claim 19, which comprises both the "host processor" and the "visual tag"?
- Finally, an evidentiary question will be one of technical interpretation: Does the "imprinted" QR code or "water-resistant sticker" on the accused Tile products satisfy the "resiliently attached" limitation of the claim, or will a more stringent standard of durability be required at trial?