DCT

1:22-cv-04975

Bright Capture LLC v. Acuant Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:22-cv-04975, N.D. Ga., 12/17/2022
  • Venue Allegations: Venue is alleged to be proper based on Defendant maintaining a regular and established place of business in the Northern District of Georgia, where it has also allegedly committed acts of patent infringement.
  • Core Dispute: Plaintiff alleges that Defendant’s products infringe three patents related to systems and methods for scanning documents of no predefined format, such as receipts, and automatically extracting and organizing the numerical data for financial management.
  • Technical Context: The technology at issue automates the historically manual and laborious process of data entry for personal and business expense tracking, a core feature in modern financial and accounting software platforms.
  • Key Procedural History: The complaint notes that the patents-in-suit descend from a family where a predecessor patent was allowed by the Board of Patent Appeals and Interferences based on the novelty of processing receipts with "no predefined format." It also highlights that U.S. Patent No. 10,453,151 was issued more than five years after the Supreme Court's decision in Alice Corp. v. CLS Bank Int'l, an assertion likely intended to preemptively defend against a patent eligibility challenge under 35 U.S.C. § 101.

Case Timeline

Date Event
2001-02-01 Earliest Priority Date for all Patents-in-Suit ('406 Prov. App.)
2013-02-12 U.S. Patent No. 8,373,912 Issues
2014-04-08 U.S. Patent No. 8,693,070 Issues
2019-10-22 U.S. Patent No. 10,453,151 Issues
2022-12-17 Complaint Filed

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

U.S. Patent No. 8,693,070 - "Receipts scanner and financial organizer," issued 04/08/2014

The Invention Explained

  • Problem Addressed: The patent's background describes the common problem of individuals struggling to track personal spending, noting that manually entering transaction data from receipts, checks, and bills into financial software is "very laborious and time consuming," leading users to abandon the practice ('070 Patent, col. 1:15-28).
  • The Patented Solution: The invention proposes a system combining a scanner and specialized software to automate this process. A user feeds receipts into the scanner, and the software automatically extracts the financial data, organizes it into a database, and allows the user to view the information in various formats like tables or charts for budgeting and analysis ('070 Patent, Abstract; col. 2:50-67). A key aspect is the system's ability to handle documents of "no predefined format," such as varied retail receipts ('070 Patent, col. 2:54-59).
  • Technical Importance: This approach aimed to significantly reduce the friction and time commitment required for diligent financial record-keeping by automating the data capture step. (Compl. ¶19).

Key Claims at a Glance

  • The complaint identifies independent claim 19 as an exemplary asserted claim (Compl. ¶25).
  • The essential elements of claim 19, directed to a non-transitory computer readable storage medium, include instructions for:
    • receiving an electronic image of a document, having no predefined format and containing numerical information, from a device capable of creating the electronic image;
    • organizing the numerical information contained in the electronic image;
    • enabling editing of the numerical information;
    • enabling viewing of the numerical information in a desired format; and
    • combining the captured numerical information with other previously captured numerical information into a report.

U.S. Patent No. 8,373,912 - "Receipts scanner and financial organizer," issued 02/12/2013

The Invention Explained

  • Problem Addressed: Similar to its relatives in the patent family, the '912 Patent addresses the inefficiency and tedium of manually entering data from physical receipts into computer-based financial management programs ('912 Patent, col. 1:24-37).
  • The Patented Solution: The patent describes a non-transitory computer readable medium with instructions to perform a method of receiving an image of a document that has "no predefined format," processing that image to extract numerical data, and creating report information from that data ('912 Patent, Abstract; col. 5:6-15). The system is designed to work with a variety of documents, including grocery and purchase receipts ('912 Patent, col. 2:57-59).
  • Technical Importance: The invention sought to streamline personal finance by directly converting unstructured physical data into structured digital information, thereby facilitating easier record-keeping and budgeting (Compl. ¶19).

Key Claims at a Glance

  • The complaint identifies independent claim 1 as an exemplary asserted claim (Compl. ¶29).
  • The essential elements of claim 1, directed to a non-transitory computer readable medium, include instructions for:
    • receiving an image of a document, with the document being of no predefined format and containing numerical information;
    • processing the image to extract the numerical information; and
    • creating report information from the extracted numerical information.

U.S. Patent No. 10,453,151 - "Receipts scanner and financial organizer," issued 10/22/2019

  • Technology Synopsis: The '151 Patent addresses the problem of manual expense tracking from physical documents ('151 Patent, col. 1:15-28). The patented solution involves a portable device obtaining an image of a document of "no predefined format," from which numerical data is extracted and automatically categorized and organized into a report within a searchable database ('151 Patent, Abstract).
  • Asserted Claims: The complaint asserts at least claim 1 (Compl. ¶33). Independent claims of the patent include 1, 9, and 16.
  • Accused Features: The complaint alleges infringement by the "Exemplary Defendant Products" identified in Exhibit 6, which is incorporated by reference (Compl. ¶33). The accused features presumably relate to the products' functionality for scanning documents and organizing the extracted financial data.

III. The Accused Instrumentality

  • Product Identification: The complaint refers to the accused instrumentalities as the "Exemplary Defendant Products" (Compl. ¶25, 29, 33). It states these products are identified in Exhibits 4, 5, and 6, which are incorporated by reference but not attached to the complaint itself.
  • Functionality and Market Context: The complaint does not provide sufficient detail for analysis of the accused products' specific functionality or market context, instead relying on the unattached exhibits.

IV. Analysis of Infringement Allegations

The complaint alleges direct infringement for each of the three patents-in-suit but provides the specific factual basis for these allegations in claim chart exhibits that are incorporated by reference rather than included in the body of the pleading (Compl. ¶26, 30, 34). As these exhibits were not filed with the complaint, a detailed element-by-element analysis is not possible from the provided document.

The narrative infringement theory for the '070 Patent is that the accused products practice the claimed method of receiving a document image, organizing the data, enabling user interaction (editing and viewing), and compiling reports (Compl. ¶25). Similarly, the theory for the '912 Patent is that the accused products receive an image of a document with no predefined format, extract the numerical data, and create a report (Compl. ¶29). The theory for the '151 Patent follows the same pattern (Compl. ¶33).

No probative visual evidence provided in complaint.

  • Identified Points of Contention:
    • Scope Questions: A central dispute may concern the meaning of a "document... of no predefined format" ('912 Patent, col. 5:9-11). The question will be whether the accused system's capabilities for handling unstructured data fall within the scope of this limitation as defined by the patent specification and its prosecution history.
    • Technical Questions: The claims require steps like "automatically extract[ing] the numerical information" and "automatically categorizing" it ('151 Patent, col. 5:15-20). A key evidentiary question will be what specific technical processes (e.g., optical character recognition, pattern matching, machine learning models) the accused products use to perform these functions and whether those processes are equivalent to what is described and enabled by the patents.

V. Key Claim Terms for Construction

  • The Term: "document... of no predefined format" (from '070 Patent, cl. 19; '912 Patent, cl. 1; '151 Patent, cl. 1)

    • Context and Importance: This term appears to be the primary point of novelty asserted during prosecution and is central to distinguishing the invention from systems that process structured forms (Compl. ¶21). The breadth of this term will likely be critical to both the infringement and validity analyses. Practitioners may focus on this term because its construction could determine whether the claims read on the accused products and whether they are valid over the prior art.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification lists a variety of document types, including "grocery receipts, various purchase receipts, credit card receipts, bank statements, etc.," suggesting the term is meant to encompass a wide range of documents that lack a standardized layout ('912 Patent, col. 2:57-59).
      • Evidence for a Narrower Interpretation: The primary embodiment shown in the patent figures is a tabular retail receipt (e.g., '912 Patent, FIG. 4A). A party could argue that "no predefined format" does not mean completely unstructured, but rather refers to documents that, while varied, still contain data in a generally columnar or otherwise machine-readable arrangement.

  • The Term: "automatically categorizing" (from '151 Patent, cl. 1)

    • Context and Importance: The degree of automation required by this term will be a key point of construction. The dispute will likely focus on whether this requires intelligent, context-aware classification (e.g., identifying "milk" as a "grocery" item) or merely sorting data into default or user-selected buckets.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification states the software "categorizes each transaction, so you have instant insight into your expenses," which could imply a functional, intelligent process that provides value to the user without significant manual input ('151 Patent, col. 2:56-58).
      • Evidence for a Narrower Interpretation: The detailed description notes that "Each receipt is entered as a separate transaction using preselected, or default categories," which the user has the "flexibility to change" ('151 Patent, col. 4:23-26). This may suggest a more rudimentary system of applying default labels rather than a dynamic, AI-driven categorization.

VI. Other Allegations

  • Willful Infringement: The complaint does not contain an explicit allegation of willful infringement or plead facts related to pre-suit knowledge of the patents. However, the prayer for relief requests that the case be "declared exceptional within the meaning of 35 U.S.C. § 285," which could allow for an award of attorneys' fees (Compl. p. 8, ¶E.i).

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

  • A core issue will be one of patent eligibility and scope: given the patents are directed to the automation of data collection and organization, a known area of § 101 scrutiny, can the claims survive a patent eligibility challenge? The outcome may depend on whether the limitation of processing a document of "no predefined format" is determined to be a specific technical improvement constituting an inventive concept, as the Plaintiff appears to contend (Compl. ¶19-23).
  • A key evidentiary question will be one of technical proof: as the complaint lacks specific details about the accused products' operation, the case will turn on evidence developed in discovery. The central question will be whether the specific algorithms and methods used by Defendant's system to extract and organize data from unstructured documents are covered by the scope of the asserted claims, as construed by the court.
  • A third question will relate to litigation conduct and potential remedies: what facts, if any, will emerge to support the Plaintiff’s prayer for an "exceptional case" finding under 35 U.S.C. § 285? The basis for this request is not apparent from the complaint, and its resolution will depend on the subsequent conduct of the parties and any evidence of bad faith or willful infringement that may arise during the litigation.