DCT
6:18-cv-01184
Coding Tech LLC v. Delta Faucet Co
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Coding Technologies, LLC (Texas)
- Defendant: Delta Faucet Co (Michigan)
- Plaintiff’s Counsel: Watson LLP
- Case Identification: 6:18-cv-01184, M.D. Fla., 07/23/2018
- Venue Allegations: Venue is alleged to be proper in the Middle District of Florida because the Defendant maintains a regular and established place of business (a product showroom) and sells the accused infringing products within the district.
- Core Dispute: Plaintiff alleges that Defendant’s use of QR codes on its products and marketing materials to direct customers to online content infringes a patent related to methods and systems for retrieving information from a server by scanning a code pattern with a mobile device.
- Technical Context: The technology concerns the now-ubiquitous practice of using smartphones to scan QR codes, which serve as a bridge between physical objects and online digital content, a common tool in marketing and customer support.
- Key Procedural History: The complaint does not mention any prior litigation, licensing history, or post-grant proceedings involving the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2003-03-07 | ’159 Patent Priority Date |
| 2013-09-24 | ’159 Patent Issue Date |
| 2018-07-23 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. 8,540,159, "Method for Providing Mobile Service Using Code-Pattern," issued September 24, 2013.
The Invention Explained
- Problem Addressed: The patent identifies the inconvenience and difficulty for users of mobile terminals who must manually remember and type website URLs found in physical advertisements, such as newspapers or magazines, to access further information (’159 Patent, col. 1:44-52).
- The Patented Solution: The invention proposes a method and system where a user employs a camera-equipped mobile terminal to capture a photographic image of a "code pattern" (e.g., a barcode or QR code). The terminal then decodes this pattern to extract information, such as a URL, and automatically sends a request to a server to retrieve and display the corresponding content, thereby streamlining access to online information from a physical source (’159 Patent, Abstract; FIG. 5).
- Technical Importance: This technology provided a more seamless method for linking physical-world objects and advertisements to the growing ecosystem of online content and services, a key development as mobile internet access became more prevalent (’159 Patent, col. 1:20-27).
Key Claims at a Glance
- The complaint asserts independent claims 1, 8, 15, and 16.
- Independent Claim 1 (Method):
- obtaining a photographic image of a code pattern by a camera of the user terminal;
- processing, by a processor of the user terminal, the photographic image of the code pattern to extract the code pattern from the photographic image;
- decoding the extracted code pattern by the processor of the user terminal into code information;
- transmitting a content information request message to a server based on the code information; and
- receiving content information from the server in response to the content information request message.
- Independent Claim 8 (Apparatus):
- a camera configured to obtain a photographic image of a code pattern;
- a processor comprising: an image processor configured to process the photographic image to extract the code pattern, and a decoder configured to decode the extracted code pattern into code information; and
- a transceiver configured to transmit a content information request message to a server and receive content information from the server.
- The complaint also asserts dependent claims 2, 3, 9, and 10, and reserves the right to assert additional claims (’159 Patent, col. 38:50-59, col. 39:9-14; Compl. ¶16).
III. The Accused Instrumentality
- Product Identification: The accused instrumentality is the method by which Delta Faucet Company provides content to users via QR codes placed on products or in materials, which are then scanned by a user's terminal (e.g., a smartphone) (Compl. ¶¶15, 19).
- Functionality and Market Context: The complaint alleges that Defendant provides a QR code with an instruction such as "For helpful videos, scan this QR code" (Compl. ¶19). A user with a smartphone scans this code, which contains a URL. The smartphone's software decodes the URL and initiates an HTTP request to Defendant's server, which in turn delivers content, such as a webpage with product videos, back to the user's smartphone (Compl. ¶¶20-24). The complaint provides an image of a QR code on what appears to be product packaging, suggesting its use in a marketing and customer support context (Compl. ¶19). A corresponding screenshot shows the resulting Delta Faucet mobile webpage, featuring "H2Okinetic® Showers" (Compl. p. 5).
IV. Analysis of Infringement Allegations
8,540,159 Patent Infringement Allegations (Claim 1)
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| obtaining a photographic image of a code pattern by a camera of the user terminal; | A user obtains a photographic image of the QR code using a smartphone's camera. The complaint provides a visual demonstrating this action. | ¶20 | col. 38:36-38 |
| processing, by a processor of the user terminal, the photographic image of the code pattern to extract the code pattern from the photographic image; | The smartphone's processor processes the image to view and extract the QR code pattern. | ¶21 | col. 38:39-42 |
| decoding the extracted code pattern by the processor of the user terminal into code information; | The smartphone's processor decodes the QR code into "code information (e.g., URL of web page associated with the defendant)." A multi-step diagram illustrates this process. | ¶22 | col. 38:43-45 |
| transmitting a content information request message to a server based on the code information; | An HTTP request message for the webpage is transmitted to the Defendant's server based on the decoded URL. | ¶23 | col. 38:46-48 |
| and receiving content information from the server in response to the content information request message. | The smartphone receives webpage content from the Defendant's server in response to the request. | ¶24 | col. 38:48-50 |
8,540,159 Patent Infringement Allegations (Claim 8)
| Claim Element (from Independent Claim 8) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A user terminal for providing content with the use of a code pattern, the user terminal comprising: a camera configured to obtain a photographic image of a code pattern; | Defendant is alleged to use a smartphone with a camera to obtain an image of a QR code. | ¶34 | col. 39:10-11 |
| a processor comprising: an image processor configured to process the photographic image of the code pattern to extract the code pattern...; and a decoder configured to decode the extracted code pattern into code information; | The smartphone's processor is alleged to comprise an image processor to extract the QR code from the image and a decoder to convert the QR code into a URL. | ¶¶35, 36 | col. 39:13-18 |
| and a transceiver configured to (i) transmit a content information request message to a server based on the code information; and (ii) receive content information from the server in response... | The smartphone's transceiver (e.g., LTE/CDMA/EDGE) is alleged to transmit the HTTP request and receive the webpage content. The complaint includes a screenshot of an iPhone's technical specifications to support this element. | ¶37 | col. 39:19-24 |
- Identified Points of Contention:
- Scope Questions: The patent specification frequently illustrates the invention with a "service provider server" (e.g., "FIG. 1", element 130) that appears distinct from the ultimate "Web servers" (element 150) that host content. This raises the question of whether the claimed "server" must be an intermediary as depicted, or if it can read on a standard commercial web server like Defendant's, which is accessed directly.
- Technical Questions: Claim 1 recites two distinct steps: "processing... to extract the code pattern" and "decoding the extracted code pattern." The defense may question whether modern QR code scanning applications perform two separate, identifiable steps that map directly onto these limitations, or if they perform a single, integrated recognition-and-decoding operation. Further, a distinction may be drawn between "code information" in Claim 1 and "characteristic information" in Claim 16, potentially creating different scopes of infringement.
V. Key Claim Terms for Construction
The Term: "code pattern"
Context and Importance: This term is foundational to all independent claims. Its construction will determine whether the patent covers any generic, publicly available symbol like a standard QR code, or if its scope is limited by the patent's specific embodiments and context.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification explicitly lists several types of codes, including "a QR code," as examples of a "two-dimensional barcode" that can be used (’159 Patent, col. 11:3-5). This language may support an interpretation that covers the accused QR codes.
- Evidence for a Narrower Interpretation: The patent's detailed embodiments often describe services (e.g., a taxi-calling service, a specific regional information service) where the code pattern appears to be generated for and used within a bespoke system. A party could argue that "code pattern" should be limited to codes used within such structured service systems, rather than a generic code that simply links to a public website (’159 Patent, col. 2:25-38).
The Term: "server"
Context and Importance: The claims require interaction between a "user terminal" and a "server." The nature of this server is critical, as the accused system involves a direct connection to a commercial web server, whereas the patent often illustrates a more complex architecture.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Plaintiff may argue that "server" should be given its plain and ordinary meaning: any computer that provides data or services to other computers over a network.
- Evidence for a Narrower Interpretation: Figures 1, 6, and 7 consistently depict a "service provider server" as an intermediary that processes requests and interacts with other servers (e.g., "Web server," "transport service provider server"). This may support an argument that the claimed "server" is this specific intermediary component, and that a system lacking it does not infringe. The Defendant's web server appears to function as the endpoint content provider (like element "150" in "FIG. 1"), not the intermediary ("130").
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement and contributory infringement, stating Defendant makes, uses, sells, and imports the accused system (Compl. ¶15). The factual basis appears to be that Defendant provides QR codes along with instructions ("scan this QR code"), which allegedly cause and encourage end-users to perform the patented method using their own devices (Compl. ¶19).
- Willful Infringement: Willfulness is alleged "upon information and belief," asserting that Defendant knew of the ’159 Patent and acted in disregard of Plaintiff's rights (Compl. ¶58). The complaint does not plead specific facts, such as a pre-suit notice letter, to substantiate this claim of knowledge.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of architectural scope: Can the claims, which arise from a specification that frequently illustrates a system with an intermediary "service provider server," be construed to cover the accused architecture where a user's smartphone interacts directly with a standard commercial web server?
- A second central issue will be one of definitional scope: Does the term "code pattern", in the context of the patent's overall disclosure, encompass any generic QR code used for marketing, or is it implicitly limited to codes integrated into the specific, function-driven service platforms detailed in the patent’s embodiments?
- A key evidentiary question will concern direct infringement: The complaint focuses on infringement by "Defendant, at least in internal use and testing" (e.g., Compl. ¶19). The case may turn on whether Plaintiff can prove that the defendant entity itself performed all steps of the claimed method, as opposed to merely enabling its customers to do so.