PayRange LLC v. Airwallet ApS

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: PayRange LLC (Tennessee)
  • Defendant: Airwallet ApS (Denmark) and Airwallet Inc. (Delaware)
  • Plaintiff’s Counsel: Potter Anderson & Corroon LLP
• Case Identification: 1:26-cv-00126, D. Del., 02/03/2026
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant Airwallet Inc. is a Delaware corporation, and Defendant Airwallet ApS is a foreign entity that may be sued in any judicial district.
• Core Dispute: Plaintiff alleges that Defendant’s mobile payment hardware and software systems for unattended retail machines infringe patents related to retrofitting coin-operated machines for electronic payments and the user interface for such systems.
• Technical Context: The technology enables users to pay for services at traditionally coin-operated machines, such as laundry or vending machines, using a mobile phone application that communicates with a retrofitted hardware module.
• Key Procedural History: The complaint details an extensive history of prior enforcement and validation of the patent portfolio, including successful litigation and subsequent licensing deals with competitors KioSoft, CSC, WASH, CCI, and Nayax. It also notes that the patents-in-suit have survived multiple validity challenges at the Patent Trial and Appeal Board (PTAB), with claims being confirmed or challenges denied institution. The '772 Patent was subject to a statutory disclaimer filed November 22, 2023, disclaiming several claims not asserted in this action. The complaint also outlines a lengthy pre-suit negotiation history between PayRange and Airwallet.

Case Timeline

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

U.S. Patent No. 10,891,608 - “Method and System for an Offline-Payment Operated Machine to Accept Electronic Payments”

The Invention Explained

• Problem Addressed: The patent addresses the difficulty and cost of upgrading the vast number of existing coin-operated machines (e.g., vending, laundry) to accept modern electronic payments, particularly in locations without a persistent internet connection ’608 Patent, col. 1:29-53 ’608 Patent, col. 6:30-50
• The Patented Solution: The invention is a retrofittable "payment module" that installs into a legacy machine ’608 Patent, col. 6:5-24 The module communicates wirelessly (e.g., via Bluetooth) with a user's mobile device. When a user initiates a payment from their phone, the module receives the wireless request and generates a sequence of electrical pulses that "emulate" the signal a coin-acceptor would produce, thereby activating the machine without requiring it to have its own internet connection ’608 Patent, abstract ’608 Patent, col. 10:41-54
• Technical Importance: This technology provided a practical, low-cost method to bring mobile payment capabilities to a large installed base of offline, analog-controlled machines, expanding the reach of electronic commerce ’608 Patent, col. 7:66-8:3 Compl. ¶41

Key Claims at a Glance

• The complaint asserts independent claim 1 and dependent claims 5-7, 11, and 12 Compl. ¶45
• Independent Claim 1 of the ’608 Patent recites the essential elements of a payment module comprising:
  • Processors, memory, a short-range wireless transceiver, and a first interface module configured to output electrical pulses that emulate an analog signal from a coin receiving switch.
  • The memory stores instructions for:
  • Storing a number of electrical pulses required to initiate a machine operation.
  • Receiving a wireless request from a mobile device to initiate a cashless operation.
  • In response to the request: determining a first number of pulses to output, causing the machine to initiate operation by issuing those pulses, and sending operation information back to the mobile device.

U.S. Patent No. 11,481,772 - “Method and System for Presenting Representations of Payment Accepting Unit Events”

The Invention Explained

• Problem Addressed: Traditional user interfaces for payment-accepting units are located on the machines themselves and are often limited in the information they can display ’772 Patent, col. 1:46-54 Compl. ¶57 When using a mobile app, users need clear, centralized feedback on their own device about transaction status (e.g., success, failure, or abortion).
• The Patented Solution: The patent describes a method where a user's mobile device, after requesting a transaction with a payment-accepting unit, obtains a notification from the unit indicating an event (e.g., transaction complete, aborted). The mobile device then provides a "representation" of this notification to the user, such as a message on the display or a vibration alert, centralizing the user experience on the personal device ’772 Patent, abstract ’772 Patent, col. 2:25-33
• Technical Importance: This invention improves the user experience of mobile payment systems for unattended machines by providing immediate and clear feedback directly on the user's mobile device, which is more versatile than the limited displays on the machines themselves Compl. ¶57

Key Claims at a Glance

• The complaint asserts claim 11 Compl. ¶59 A statutory disclaimer has disclaimed claims 1-6, 8-10, and 12-20, leaving claim 7 as the independent claim from which claim 11 depends Compl. ¶37 ’772 Patent, Disclaimer
• Independent Claim 7 of the ’772 Patent recites the essential elements of a method for presenting payment events on a mobile device, comprising:
  • Identifying one or more payment accepting units in proximity.
  • Displaying a user interface on the mobile device showing the units and accepting user input to select a unit and trigger a payment.
  • Establishing a wireless communication path with the selected unit.
  • Enabling user interaction to complete the transaction.
  • Exchanging information with the unit.
  • Displaying an updated user interface after the information exchange.
• Asserted dependent claim 11 adds the limitation of the user interface including "an affordance that when slid, indicates the initiation of the transaction."

III. The Accused Instrumentality

Product Identification

• The accused products are the "Airwallet mobile payment system," which includes the "Airwallet App, Airwallet PRO hardware, and associated backend servers and cloud services" Compl. ¶2

Functionality and Market Context

• The complaint alleges that the Airwallet system provides mobile payment solutions for unattended retail machines, such as those in the laundry and vending industries Compl. ¶¶1-3 The system is described as comprising hardware (Airwallet PRO) that is installed in machines and software (Airwallet App) that runs on a user's mobile device to enable mobile transactions Compl. ¶2 The complaint positions Airwallet as a competitor that copied PayRange's technology and is one of a "few outliers" that has refused to take a license to PayRange's patent portfolio Compl. ¶¶3, 11

IV. Analysis of Infringement Allegations

The complaint references, but does not include, claim chart exhibits detailing its infringement theories Compl. ¶¶47, 61 The following summarizes the narrative infringement allegations from the complaint.

No probative visual evidence provided in complaint.

’608 Patent Infringement Allegations

The complaint alleges that the Airwallet system infringes claims 1, 5-7, 11, and 12 of the ’608 Patent Compl. ¶45 The infringement theory suggests that the Airwallet PRO hardware functions as the claimed "payment module" when installed in an offline payment-operated machine. This hardware allegedly receives a wireless payment request from a user's mobile device running the Airwallet App. In response, the Airwallet PRO hardware is alleged to determine and issue a specific number of electrical pulses to the machine's control unit, thereby emulating the signal of a traditional coin mechanism and causing the machine to initiate a cashless operation. This narrative mirrors the patent's description of its "unconventional approach" Compl. ¶¶40-44

’772 Patent Infringement Allegations

The complaint alleges that the Airwallet system infringes claim 11 of the ’772 Patent Compl. ¶59 The infringement theory centers on the user interface of the Airwallet App. The complaint alleges that the app displays available payment-accepting units to the user and provides an interface for initiating a transaction. This interface is alleged to include "an affordance that when slid, indicates the initiation of the transaction," directly mapping to the language of asserted claim 11 Compl. ¶58 This functionality is described as an "unconventional solution" that improves upon prior art user interfaces, which were typically displayed on the payment-accepting units themselves Compl. ¶57

Identified Points of Contention

• Technical Questions (’608 Patent): A central technical question may be whether the Airwallet PRO hardware actually performs the specific function of "storing... a number of the electrical pulses" and "determining a first number of electrical pulses to output" to "emulate an analog signal," as required by claim 1. The complaint highlights the PTAB’s focus on this as an unconventional element Compl. ¶¶42-43, suggesting that the dispute could turn on evidence of the precise internal operation of the accused hardware.
• Scope Questions (’772 Patent): The infringement analysis for the ’772 Patent raises the question of whether the user action required by the Airwallet App to trigger a payment falls within the scope of the claim term "an affordance that when slid." The complaint notes the PTAB distinguished prior art based on this specific limitation Compl. ¶58, indicating its construction will be a focal point.

V. Key Claim Terms for Construction

• The Term: "emulating an analog signal generated by the coin receiving switch" ’608 Patent, claim 1

• Context and Importance: This term describes the core mechanism by which the invention retrofits legacy machines. The complaint highlights that the patent examiner and the PTAB found this "analog signal emulation" to be a key inventive concept that is "necessarily rooted in computer technology" and not routine or conventional Compl. ¶¶41, 43-44 Practitioners may focus on this term because its construction will determine whether Airwallet’s method of activating a machine is technically equivalent to the patented method.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification describes the concept in functional terms, stating the module "simulates establishing payment" and that the invention involves "practically applying analog signal emulation" ’608 Patent, col. 6:25-29 ’608 Patent, col. 10:41-43 This language may support an interpretation covering any signal that achieves the functional result of initiating credit.
  • Evidence for a Narrower Interpretation: The specification also provides detailed examples, including a figure showing specific pulse shapes, counts, and intervals ’608 Patent, Fig. 28B ’608 Patent, col. 39:50-40:2 This could support a narrower construction requiring a more direct replication of the pulse characteristics of a specific coin mechanism.

• The Term: "an affordance that when slid, indicates the initiation of the transaction" ’772 Patent, claim 11

• Context and Importance: This term is the central limitation of the single asserted claim of the ’772 Patent. The complaint alleges the PTAB confirmed the validity of this claim over prior art that lacked this specific element Compl. ¶58 The dispute may hinge on whether the "swipe" or other gesture in the Airwallet App constitutes a "slid" affordance.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The detailed description refers to a "manual (swipe to pay) mode" where a user "quickly brushes his/her finger" on the mobile device screen ’772 Patent, col. 7:1-9 This use of "swipe" and "brush" may support construing "slid" to encompass a general class of directional touch gestures.
  • Evidence for a Narrower Interpretation: The claim uses the specific word "slid." An argument could be made that this implies moving a specific UI element (the "affordance," e.g., a virtual slider) from one point to another, as opposed to a freeform "swipe" gesture anywhere on a screen. The patent's figures show a graphical representation of a dollar bill moving, which might be argued to be the "affordance" that is "slid" ’772 Patent, Figs. 10B, 26B

VI. Other Allegations

• Indirect Infringement: The complaint alleges active inducement of infringement for both patents. This is based on allegations that Airwallet provides "installation and configuration instructions," "user guides," and "marketing and sales materials" that encourage and direct customers to use the accused products in an infringing manner Compl. ¶48 Compl. ¶62 The complaint also alleges contributory infringement of the ’608 Patent, asserting the accused products are a material part of the invention especially made for infringing use Compl. ¶49
• Willful Infringement: Willfulness is alleged for both patents based on pre-suit knowledge Compl. ¶¶46, 60 The complaint details a lengthy history of correspondence, starting with a notice letter on June 28, 2024, which included infringement allegations and claim charts Compl. ¶¶12, 18 The allegations of willfulness are further supported by claims that Airwallet continued its conduct despite being aware of PayRange’s successful licensing program and PTAB victories involving the same patents Compl. ¶¶3-11

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

• A core issue will be one of technical operation: Does the Airwallet PRO hardware function by storing and issuing a determined number of electrical pulses to "emulate" a coin signal, as required by the ’608 Patent, or does it utilize a technically distinct, non-infringing method to activate legacy machines?
• A second core issue will be one of definitional scope: Can the claim term "an affordance that when slid," which was pivotal in distinguishing the ’772 Patent from prior art, be construed broadly enough to read on the specific user gesture for initiating payment in the accused Airwallet App?
• A significant question for remedies will be one of willfulness: Given the extensive pre-suit notice, discussions, and the context of the patents' successful validation and licensing history alleged in the complaint, did the defendant have an objectively reasonable basis for its continued alleged infringement, or was its conduct egregious enough to warrant enhanced damages and attorney's fees?