DCT

1:25-cv-01564

Grecia v. Roc Nation LLC

Log In
Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-01564, D. Del., 01/05/2026
  • Venue Allegations: Venue is asserted in the District of Delaware based on the Defendants being Delaware-registered business entities.
  • Core Dispute: Plaintiff alleges that Defendant Roc Nation, LLC indirectly infringed two design patents by misrepresenting its authority to license or commercialize the patented graphical user interface designs to third parties, including the other named defendants.
  • Technical Context: The patents-in-suit relate to ornamental designs for graphical user interfaces (GUIs) on display screens, specifically those incorporating QR codes for authentication or financial transactions.
  • Key Procedural History: The complaint alleges a prior commercial relationship and course of dealing between the parties, which it contends gives rise to equitable estoppel, potentially barring Defendants from challenging the patents' validity or enforceability. It also references a prior "Zelle-related patent action" as context for an allegation of "False Agency" against Roc Nation.

Case Timeline

Date Event
2015-07-27 U.S. Design Patent No. D769,296 – Priority Date
2016-10-18 U.S. Design Patent No. D769,296 – Issue Date
2017-08-18 U.S. Design Patent No. D857,054 – Priority Date
2019-08-20 U.S. Design Patent No. D857,054 – Issue Date
2023-01-17 Date of Electronic Filing Notice cited in complaint as evidence of alleged "False Agency"
2026-01-05 Complaint Filing Date

II. Technology and Patent(s)-in-Suit Analysis

U.S. Design Patent No. D769,296 - *Display Screen or Portion Thereof with Graphical User Interface*

The Invention Explained

  • Problem Addressed: Design patents protect the ornamental appearance of an article, not its function. As such, the patent does not articulate a technical problem to be solved.
  • The Patented Solution: The patent claims the specific ornamental design for a graphical user interface. The sole figure illustrates a rectangular interface with the stylized word "KodeKey" at the top, followed by a "Device Number," a "Device PIN," a central QR code, and a button labeled "RESET DEVICE PIN" at the bottom (D’296 Patent, FIG. 1; Description). The broken lines in the drawing, including the outermost border and the word "KodeKey," are disclaimed and do not form part of the patented design (D’296 Patent, Description).
  • Technical Importance: The claimed design provides a specific visual layout for presenting QR code-based authentication or access credentials on a digital display screen.

Key Claims at a Glance

  • A design patent contains a single claim. The asserted claim is: "The ornamental design for a display screen or portion thereof with graphical user interface, substantially as shown and described." (D’296 Patent, Claim).
  • The essential visual elements of the claimed design include the relative placement and appearance of:
    • The label "Device Number:" followed by a string of numbers.
    • The label "Device PIN:" followed by a shorter string of numbers.
    • A square QR code positioned below the PIN.
    • A rectangular button with the text "RESET DEVICE PIN" positioned below the QR code.

U.S. Design Patent No. D857,054 - *Display Screen or Portion Thereof with Graphical User Interface*

The Invention Explained

  • Problem Addressed: As a design patent, the ’054 Patent protects an ornamental design and does not describe a technical problem.
  • The Patented Solution: The patent claims the ornamental design for a GUI intended for receiving payments. The sole figure shows a rectangular interface with the stylized logo "Digital Debit" and the text "Receive Mode" at the top, a monetary value ("$0.00") below, and then a large QR code with a circular logo in its center (D’054 Patent, FIG. 1). Below the QR code are two icons labeled "mPOS" and "Settings" (D’054 Patent, FIG. 1; Description). The outermost border of the display screen is shown in broken lines and is not part of the claimed design (D’054 Patent, Description).
  • Technical Importance: The design provides a distinct visual arrangement for a mobile point-of-sale or peer-to-peer payment interface that utilizes a QR code.

Key Claims at a Glance

  • The single asserted claim is: "The ornamental design for a display screen or portion thereof with a graphical user interface, as shown and described." (D’054 Patent, Claim).
  • The essential visual elements of the claimed design include the combination and arrangement of:
    • A logo and title area at the top.
    • A prominent monetary value display.
    • A large, central QR code featuring an embedded central logo.
    • Textual instructions positioned between the monetary value and the QR code.
    • Two distinct icons at the bottom of the interface.

III. The Accused Instrumentality

Product Identification

The complaint does not identify a specific product, service, or device that directly infringes the asserted design patents by embodying their ornamental appearance (Compl. ¶¶16-24).

Functionality and Market Context

The complaint’s theory of infringement is not centered on a tangible product. Instead, the accused instrumentality is Defendant Roc Nation’s alleged conduct: the "unauthorized sale, licensing, commercialization, and transfer of rights" in the asserted patents (Compl. ¶1). The complaint alleges that Roc Nation facilitated, authorized, and enabled third parties, including Early Warning Services and PayPal, to use the patented designs without the plaintiff's permission (Compl. ¶17). The core of the accusation is that Roc Nation falsely represented that it had the authority to license these designs (Compl. ¶18).

IV. Analysis of Infringement Allegations

The complaint does not contain allegations of direct infringement against a specific product or provide a comparison of an accused product to the patented designs. The infringement counts are for contributory and induced infringement, predicated on the allegation that Roc Nation's business dealings caused third parties to directly infringe (Compl. ¶¶16-24). As no accused product design is identified or depicted, a claim chart summary comparing the patented design to an infringing functionality cannot be constructed.

  • Identified Points of Contention:
    • Legal Question: The central dispute appears to be a legal one: whether allegations of misrepresenting licensing authority for a design patent, without identifying a specific resulting article of manufacture that embodies the patented design, can sustain a claim for indirect patent infringement under 35 U.S.C. § 271(b) or (c).
    • Factual Question: A primary factual question will be what evidence supports the allegation that Roc Nation's actions caused a direct infringement by a third party. The complaint does not specify what infringing "user interface design(s)" Early Warning Services or PayPal allegedly used as a result of Roc Nation's conduct (Compl. ¶17).

V. Key Claim Terms for Construction

In design patent litigation, the claim is defined by the drawings as a whole, and claim construction is typically not focused on textual terms. The legal standard for infringement is the "ordinary observer" test, which asks whether an ordinary observer, familiar with the prior art, would be deceived into believing the accused design is the same as the patented design. The complaint does not raise any issues that would necessitate the construction of a specific term. The dispute as pleaded centers on conduct related to the patents, not the visual scope of their claims.

VI. Other Allegations

  • Indirect Infringement: This is the foundation of the complaint.
    • Contributory Infringement: The complaint alleges that Roc Nation knowingly contributed to infringement by "facilitating, authorizing, and enabling third parties... to use the patented user interface design(s)" and by "falsely representing that it possessed authority to license or commercialize" them (Compl. ¶¶17-18).
    • Induced Infringement: The complaint alleges Roc Nation actively induced infringement by "intentionally encouraging and causing third parties to use the patented user interface design(s)" through "misrepresentations of authority, promotion of unauthorized use, and intentional interference" (Compl. ¶22). As evidence of this alleged misrepresentation, the complaint includes a screenshot of an electronic court filing notice from a separate case, which it characterizes as evidence of Roc Nation's "False Agency" (Compl. p. 4).
  • Willful Infringement: The complaint alleges that Defendant Roc Nation "knew or was willfully blind to the fact that the acts it facilitated constituted infringement" and "acted with knowledge of the Asserted Patents and with specific intent that infringement occur" (Compl. ¶¶19, 23). Plaintiff seeks enhanced damages based on this alleged willful conduct (Compl. p. 6).

VII. Analyst’s Conclusion: Key Questions for the Case

  • A core issue will be one of legal sufficiency: Does the complaint, which focuses on alleged misrepresentations of licensing authority rather than the sale or use of a visually similar product, state a viable claim for indirect design patent infringement under § 271? The court may need to determine if this theory of liability is cognizable without a well-pleaded allegation of a specific, underlying direct infringement.
  • A key evidentiary question will be one of causation and proof: Assuming the legal theory is viable, can the Plaintiff produce evidence to demonstrate not only that Roc Nation made false representations about its authority, but also that these specific actions directly caused a third party (e.g., PayPal or Early Warning Services) to make, use, or sell a product embodying a design substantially the same as those claimed in the ’296 and ’054 patents?