DCT
1:19-cv-10999
Scanning Tech Innovations LLC v. Scandit Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Scanning Technologies Innovations, LLC (Texas)
- Defendant: Scandit Inc. (Delaware)
- Plaintiff’s Counsel: Chavous Intellectual Property Law LLC
- Case Identification: 1:19-cv-10999, D. Mass., 04/26/2019
- Venue Allegations: Venue is alleged to be proper because Defendant is deemed to reside in the district, has a regular and established place of business in Massachusetts, and has committed alleged acts of infringement there.
- Core Dispute: Plaintiff alleges that Defendant’s mobile barcode scanning application, which uses a local database to validate scanned items like tickets, infringes a patent directed to using a mobile device to check for the existence of online product information without first needing to connect to the internet.
- Technical Context: The technology concerns mobile barcode scanning applications that leverage both local device storage and cloud-based databases to provide users with instant information about scanned items, a common feature in retail, logistics, and event management.
- Key Procedural History: The patent-in-suit is a continuation of a chain of prior applications and is subject to a terminal disclaimer, which may limit its enforceable term to that of an earlier patent in the family. The complaint does not mention any prior litigation or licensing history involving the patent.
Case Timeline
| Date | Event |
|---|---|
| 2012-02-25 | Earliest Patent Priority Date (U.S. App. No. 13/405,246) |
| 2015-06-09 | U.S. Patent No. 9,053,498 Issues |
| 2019-04-26 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
- U.S. Patent No. 9,053,498, "Systems and Methods for Indicating the Existence of Accessible Information Pertaining to Articles of Commerce," issued June 9, 2015
- The Invention Explained:
- Problem Addressed: The patent describes the frustration users experience when using a mobile device to scan a product's barcode, only to wait for a slow or unavailable internet connection and then discover that no information is available for that product. ('498' Patent, col. 1:47-54).
- The Patented Solution: The invention proposes a system where a mobile device first downloads a "look-up table" from a server. This local table contains product identification codes (e.g., UPCs) paired with "information link indicators." When a user scans a product, the device first checks this local table. The indicator immediately signals whether or not a link to online information for that product exists, allowing the user to know if a network connection would be fruitful before attempting to connect. ('498 Patent, Abstract; col. 2:1-29).
- Technical Importance: This approach aimed to mitigate issues of network latency and unreliable connectivity in mobile environments by providing an "offline" pre-check for data availability, improving the user experience. ('498 Patent, col. 1:51-64).
- Key Claims at a Glance:
- The complaint asserts infringement of at least independent Claim 1. (Compl. ¶13).
- Claim 1 is a system claim comprising:
- A mobile device with a portable handheld housing, a communication interface, a signal processor, and a visual input device affixed within the housing.
- A local database on the mobile device.
- A server with a database storing a "look-up table" containing identification codes and corresponding "information link indicators."
- Each "information link indicator" is a "status signal" indicating the existence or absence of a link to information.
- The system is configured to: (1) capture and decode an image to get an identification code; and (2) look up that code in the local database to determine from the indicator whether a link exists, with this lookup occurring "without accessing the communication network."
- The complaint does not explicitly reserve the right to assert dependent claims.
- The Invention Explained:
III. The Accused Instrumentality
- Product Identification: The accused products are the "Scandit Flow barcode scanner app, and any similar products" (collectively, "Products"). (Compl. ¶14).
- Functionality and Market Context: The complaint describes Scandit Flow as a "web-configurable app for iOS and Android that supports a wide variety of common barcode scanning workflows," specifically citing "Mobile Ticket Validation" as an example. (Compl. ¶15). The system allegedly uses a "cloud database" that synchronizes with a local database on the mobile device, enabling the app to function even when offline. (Compl. ¶¶12, 13, 26). The complaint includes a screenshot from a Scandit tutorial explaining how to build a mobile solution to validate tickets by checking a scanned ticket ID against a database. (Compl. ¶15, p. 3). The system queries a local or cloud-synced database to determine if a scanned ticket is valid for a given event. (Compl. ¶¶25, 26).
IV. Analysis of Infringement Allegations
- 9,053,498 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a mobile device comprising a portable handheld housing and a communication interface... a signal processing device and a visual input device, the visual input device affixed within the portable handheld housing; | The Scandit Flow app runs on iOS or Android mobile devices which have a housing, camera (visual input), processor (signal processing), and network interface (communication interface). | ¶¶16, 17, 18 | col. 11:11-20 |
| a local database associated with the mobile device... | The Scandit Flow app utilizes a "built-in replicating database that is available on each phone" which can be read from and written to even when the phone is offline. | ¶26 | col. 11:21-24 |
| a server in communication with the communication network, the server comprising a server database configured to store a look-up table that includes at least a plurality of identification codes... the look-up table also storing a plurality of information link indicators... | The Product includes a server with a cloud database that stores information for mobile tickets, such as "ticketid", which functions as a look-up table with identification codes. | ¶20 | col. 11:25-30 |
| each information link indicator being configured as a status signal indicating the existence or absence of a link to information... | The link indicator is alleged to be the "link indicating availability and validity of scanned ticket online," which signals whether information corresponding to the scanned ticket is available. A screenshot shows code that checks if a ticket "exists in the database". | ¶¶21, 23, 10 | col. 11:31-36 |
| wherein the visual input device is configured to capture an image of an article of commerce and decode the image to obtain an identification code; | The mobile device's camera is used to scan a barcode and decode it to obtain an identification code, such as a ticket ID value. A visual in the complaint shows code pausing the scanner and showing the "value decoded". | ¶¶24, 3 | col. 11:37-40 |
| wherein... the signal processing device is configured to look up the identification code in the look-up table stored in the local database to determine... whether or not a link exists... without accessing the communication network. | The mobile device's processor looks up the decoded barcode in the local database. The complaint references a screenshot of Scandit’s documentation stating, "Data is continuously available, with or without a network connection." | ¶¶25, 26, 10 | col. 11:41-49 |
- Identified Points of Contention:
- Scope Questions: A central question may be whether Scandit's system of checking for the existence of a "ticketid" record in a database to determine its validity meets the claim limitation of an "information link indicator being configured as a status signal." The complaint alleges the "link indicating availability and validity" is the indicator (Compl. ¶21), while the patent describes a signal that specifically indicates the "existence or absence of a link." The court may need to determine if the simple presence or absence of a database record constitutes the claimed "status signal."
- Technical Questions: What evidence demonstrates that the lookup process occurs "without accessing the communication network"? The complaint cites Scandit's materials stating the app works offline (Compl. ¶26), which supports the allegation. However, the accused product's reliance on a "Cloud DB" that "is automatically synced" (Compl. ¶10) could raise questions about the technical definition of "accessing the communication network" during the lookup operation, especially if the local data is merely a cache. The complaint provides a screenshot detailing API functionality to check the network connection status ("disconnected, cellular, wifi"), which may become relevant evidence. (Compl. ¶16, p. 4).
V. Key Claim Terms for Construction
The Term: "information link indicator"
- Context and Importance: This term is the core of the invention's solution. Its definition will be critical to determining infringement. The dispute will likely focus on whether the mere existence of a data record for a scanned item in the accused system's database qualifies as an "indicator," or if the claim requires a more specific, separate data element explicitly designated as a status flag.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The Abstract states the indicator "indicates the existence of a link," which could be interpreted broadly to mean any data structure from which existence can be inferred. The patent also states the indicator may simply be "an indication... as to whether (or not) information about the identified article of commerce can be accessed." ('498 Patent, col. 4:51-54).
- Evidence for a Narrower Interpretation: Claim 1 requires the indicator to be a "status signal," which suggests a more explicit flag (e.g., a binary value) rather than an inferred state. The patent repeatedly describes storing a "plurality of information link indicators" separately from the "plurality of identification codes," suggesting they are distinct data elements within the look-up table. ('498 Patent, col. 11:27-31).
The Term: "without accessing the communication network"
- Context and Importance: This term defines a key functional constraint of the claimed system. Practitioners may focus on this term because the accused system uses a "Cloud DB" that synchronizes with the local device, blurring the line between a purely offline and a network-dependent operation.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent's objective is to solve the problem of waiting for a network connection. ('498 Patent, col. 1:47-54). This purpose could support an interpretation where any lookup performed on a local data copy, regardless of background syncing, meets the limitation because it provides an immediate result to the user.
- Evidence for a Narrower Interpretation: The claim language is absolute. A defendant could argue that if the local database is merely a cache that is stale without a recent sync, or if a lookup operation triggers any network traffic, the lookup is not performed "without accessing" the network. The patent repeatedly emphasizes that the user can determine information availability "without communication capabilities, e.g., not being connected to the Internet." ('498 Patent, col. 11:1-3).
VI. Other Allegations
- Indirect Infringement: The complaint does not contain a specific count for indirect infringement (35 U.S.C. § 271(b) or (c)). However, it alleges facts that could potentially support such a claim, such as Defendant providing the Scandit Flow app and online tutorials that instruct users on how to configure and use the allegedly infringing ticket validation workflow. (Compl. ¶¶14, 15).
- Willful Infringement: The complaint's prayer for relief requests enhanced damages pursuant to 35 U.S.C. § 284. (Compl. p. 14). However, the body of the complaint does not allege specific facts to support a claim of pre-suit willfulness, such as prior knowledge of the '498 Patent. The filing of the complaint itself provides Defendant with notice of the patent and the infringement allegations.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: Can the patent's term "information link indicator," described as a "status signal," be construed to read on the accused system's method of querying a database to check for the existence of a record (e.g., a valid "ticketid")? The outcome of this claim construction dispute will likely be dispositive.
- A key evidentiary question will be one of functional operation: Does the accused Scandit Flow app, with its synchronized "Cloud DB," perform the critical lookup step "without accessing the communication network" as required by the claim? The case may turn on the technical details of how and when the app's local database interacts with the network relative to the user's action of scanning a code.