DCT
1:25-cv-01531
Life360 Inc v. Gocodes Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Life360, Inc. and Tile, Inc. (Delaware)
- Defendant: GoCodes, Inc. (Minnesota)
- Plaintiff’s Counsel: Faegre Drinker Biddle & Reath LLP; The Webb Law Firm
- Case Identification: 1:25-cv-01531, D. Del., 12/18/2025
- Venue Allegations: Plaintiffs allege venue is proper in the District of Delaware because both plaintiffs are incorporated in Delaware and Defendant GoCodes previously elected to file a patent infringement suit against them in the same district.
- Core Dispute: Plaintiffs seek a declaratory judgment that Defendant’s patent related to a system for recovering lost property using scannable tags is invalid under 35 U.S.C. §§ 101, 102, and 103.
- Technical Context: The technology involves using unique, machine-readable codes (e.g., QR codes) on physical tags to link a lost item to a specific webpage where a finder can securely contact the owner according to pre-set privacy preferences.
- Key Procedural History: This declaratory judgment action follows a prior lawsuit filed by GoCodes against Life360 and Tile for infringement of the same patent. GoCodes voluntarily dismissed its suit without prejudice and without providing a covenant not to sue, which Plaintiffs allege creates an ongoing threat of future litigation necessitating this action to resolve the patent's validity.
Case Timeline
| Date | Event |
|---|---|
| 2009 | Plaintiff Life360 allegedly offered a lost and found recovery service |
| 2010 | Plaintiff Life360 allegedly acquired Foundog, a lost item recovery service |
| 2011-04-19 | U.S. Patent No. 8,973,813 Priority Date |
| 2015-03-10 | U.S. Patent No. 8,973,813 Issue Date |
| 2024-07-01 | GoCodes' counsel allegedly sent a notice letter to Life360's CEO |
| 2025-06-03 | GoCodes filed infringement suit against Life360 and Tile |
| 2025-07-23 | GoCodes voluntarily dismissed its infringement suit |
| 2025-12-18 | Life360 and Tile filed Complaint for Declaratory Judgment |
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 (’813 Patent).
The Invention Explained
- Problem Addressed: The patent’s background section notes the increasing frequency of misplaced or stolen smart phones and other mobile devices and suggests it would be advantageous to use the power of these devices to facilitate their own return (’813 Patent, col. 1:29-34). The patent also describes the prior art use of barcodes for tracking items in transit or for inventory, and the newer use of QR codes that can direct a user’s device to a website (’813 Patent, col. 1:35-57).
- The Patented Solution: The invention is a system where a unique barcode (e.g., a QR code) is attached to a portable asset. If the asset is lost, a finder can scan the code with a camera-equipped device, which automatically directs them to a unique webpage associated with that specific asset. The owner can pre-configure this webpage with "privacy preferences" that control what contact information is displayed and how communication with the finder is handled, allowing for potentially anonymous interaction (’813 Patent, Abstract; col. 2:5-10). Figure 1 illustrates the overall system, showing an owner (102), a finder (104), and a centralized vendor (100) that hosts the system (’813 Patent, Fig. 1).
- Technical Importance: The claimed solution seeks to provide a mechanism for secure, anonymous communication between the owners and finders of lost assets, leveraging the widespread availability of camera-equipped smart devices (’813 Patent, col. 1:21-25).
Key Claims at a Glance
- The complaint focuses its invalidity arguments on independent claim 19, which was asserted against Plaintiffs in the prior litigation (Compl. ¶¶ 9, 20-21).
- Independent Claim 19 requires:
- A host processor with a memory module hosting a database of user accounts.
- Each user account includes at least one "return profile" associated with a portable asset.
- Each return profile includes "privacy preferences" elected by the user, which are used to create a unique property page.
- A "visual tag" with a symbol containing a machine-readable internet link to the unique property page.
- The visual tag is "resiliently attached" to the asset and is accessible for capture by a camera device.
- The camera device "directly accesses and displays the unique property page."
- The complaint notes that the prior suit also asserted dependent claims 20 and 22-26 (Compl. ¶9).
III. The Accused Instrumentality
Product Identification
The instrumentalities previously accused of infringement by GoCodes, and which form the basis for this declaratory judgment action, are Life360 and Tile’s "products and services," including "Lost and Found Labels" (Compl. ¶10).
Functionality and Market Context
- The complaint references a Life360 webpage titled "Introducing Lost and Found Labels" (Compl. ¶10). This suggests the products are physical labels or tags, likely with QR codes, that users can attach to their belongings. When a finder scans the code on a label, the system is designed to facilitate the return of the item to the owner.
- The complaint does not provide further technical detail on the operation of the Life360/Tile products.
IV. Analysis of Invalidity Allegations
The complaint alleges the ’813 Patent is invalid as anticipated (§ 102) or obvious (§ 103) in view of prior art systems, including ReboundTag and PetHub (Compl. ¶¶ 54-63, 66). Plaintiffs map the functionality of these prior art systems to the limitations of claim 19.
’813 Patent Invalidity Allegations (Based on Prior Art)
| Claim Element (from Independent Claim 19) | Alleged Prior Art Functionality (ReboundTag & PetHub) | 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 | The ReboundTag and PetHub systems allegedly included databases of registered user accounts, with each account including a return profile for the user that was associated with their tags. | ¶¶55, 60, 67 | col. 9:32-38 |
| 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 with the individual portable asset | The ReboundTag "Members Area" allegedly allowed users to manage their details, including optional privacy preferences. The PetHub system allegedly allowed users to manage personal data inputs for their return profile, which constituted privacy preferences. This information was used to create a unique property page. | ¶¶55, 60, 68 | col. 10:1-5 |
| a visual tag including a symbol containing embedded information, the embedded information including a machine readable internet link to the unique property page | ReboundTag allegedly provided tags with a barcode and unique ID. PetHub allegedly provided pet tags with QR codes containing an embedded URL that linked to an owner information page. | ¶¶56, 61, 69 | col. 10:5-9 |
| the symbol being accessible to capture by a camera device while the visual tag is resiliently attached to the individual portable asset, and wherein the camera device directly accesses and displays the unique property page | PetHub’s QR codes were allegedly scannable by a camera. The complaint alleges that the capability of being captured by a camera to display the page was either present or an obvious design variation for both systems. | ¶¶57, 62, 70 | col. 10:9-14 |
- Identified Points of Contention:
- Scope Questions: A central question will be whether the features of the prior art systems, such as ReboundTag’s "Members Area" or PetHub’s pet profile page, meet the claim limitations of a "return profile" and "privacy preferences" as construed in the context of the ’813 Patent.
- Technical Questions: The analysis may turn on whether the prior art tags, particularly ReboundTag’s barcode and unique ID, constitute a "machine readable internet link" that a camera device can use to "directly access" a webpage, as required by the claim, or if they required an intermediate manual step (e.g., typing an ID into a website) not contemplated by the patent.
V. Key Claim Terms for Construction
The Term: "return profile"
Context and Importance: This term is central to the invention's claimed novelty over simple tracking tags. The complaint alleges that prior art user account pages in systems like ReboundTag constitute a "return profile" (Compl. ¶55). The scope of this term will be critical for determining whether the prior art anticipates or renders the claim obvious.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims state the profile "includes privacy preferences" but do not require specific types of information, which may support a broader reading to include any user-configurable account page related to an asset (’813 Patent, col. 10:1-2).
- Evidence for a Narrower Interpretation: The specification describes the property registration page (212) as including specific fields like property name, type, and serial number, which could be argued to define the required contents of a "return profile" (’813 Patent, col. 4:41-51).
The Term: "privacy preferences"
Context and Importance: The customizability of privacy is presented as a key feature. The complaint argues that prior art features like managing personal data inputs or having a "Members Area" meet this limitation (Compl. ¶¶ 55, 60). The definition will determine whether generic user account settings qualify.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language "privacy preferences elected by a user" is general and could be read to cover any user choice regarding the display of personal information (’813 Patent, col. 10:1-2).
- Evidence for a Narrower Interpretation: The specification provides specific examples, such as choosing between providing direct contact information versus anonymous communication through the vendor, or setting different privacy levels for different assets. This could support a narrower construction requiring specific, selectable privacy modes beyond simple data entry (’813 Patent, col. 5:30-61).
VI. Other Allegations
The complaint does not make its own allegations of indirect or willful infringement. It references the allegations from GoCodes’ previously filed, now-dismissed complaint to establish the existence of a legal controversy.
- Indirect Infringement: The complaint notes that GoCodes previously alleged inducement based on Life360's instructions to customers on how to use its products, citing a company webpage (Compl. ¶10).
- Willful Infringement: The complaint states that GoCodes previously alleged willful infringement based on knowledge of the ’813 Patent from at least July 1, 2024, when GoCodes’ counsel allegedly sent a notice letter with infringement claim charts to Life360’s CEO (Compl. ¶11).
VII. Analyst’s Conclusion: Key Questions for the Case
This declaratory judgment action appears to center on the validity of claims directed to a now-commonplace commercial practice. The outcome will likely depend on the court’s resolution of two primary questions:
- A core issue will be one of patent eligibility under § 101: are the claims directed to the abstract idea of managing asset recovery using a database and tags, and if so, do the claimed elements—such as a "host processor," a "database," and a "visual tag" with a link—add a sufficient "inventive concept" beyond generic computer implementation?
- A key evidentiary question will be one of anticipation and obviousness under §§ 102/103: do the functionalities of the cited prior art systems, such as ReboundTag and PetHub, teach every element of claim 19, or was combining their features to arrive at the claimed system an obvious step to a person of ordinary skill in the art before the patent’s 2011 priority date?