DCT

2:90-cv-00049

Mars Inc v. Coin Acceptors Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:90-cv-00049, D.N.J., 01/05/1990
  • Venue Allegations: Venue is based on Defendant having a regular and established place of business in the District of New Jersey.
  • Core Dispute: Plaintiff alleges that Defendant’s coin mechanisms infringe four patents related to electronic and mechanical coin discrimination and handling technologies.
  • Technical Context: The technology concerns methods for authenticating and determining the denomination of coins in automated devices like vending machines, a critical function for preventing fraud and enabling automated commerce.
  • Key Procedural History: The complaint alleges that Defendant had pre-suit notice of the asserted patents and its alleged infringement, which forms the basis for the willfulness allegation. The complaint also notes that the ’719 Patent was assigned to Plaintiff MARS from Hilgreave, Incorporated.

Case Timeline

Date Event
1971-08-16 Priority Date for U.S. Patent No. 3,797,307
1972-01-20 Filing Date for U.S. Patent No. 3,797,307
1973-10-12 Filing Date for U.S. Patent No. 3,870,137
1974-03-19 Issue Date for U.S. Patent No. 3,797,307
1974-11-21 Filing Date for U.S. Patent No. 3,944,038
1975-03-11 Issue Date for U.S. Patent No. 3,870,137
1976-03-16 Issue Date for U.S. Patent No. 3,944,038
1983-07-01 Filing Date for U.S. Patent No. 4,538,719
1985-09-03 Issue Date for U.S. Patent No. 4,538,719
1986-08-28 U.S. Patent No. 4,538,719 assigned to Mars, Inc
1990-01-05 Complaint Filing Date

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

U.S. Patent No. 4,538,719, "ELECTRONIC COIN ACCEPTOR," issued September 3, 1985

The Invention Explained

  • Problem Addressed: The patent describes prior art electronic coin acceptors as suffering from several drawbacks, including the high cost and complexity of transmitter-receiver systems and the instability of oscillator-based systems, which are prone to drift from temperature changes and aging, leading to a loss of calibration and reliability (col. 1:35-col. 2:13).
  • The Patented Solution: The invention proposes an electronic coin acceptor that uses an "off-resonance" inductive filter. A computer-controlled frequency synthesizer drives the filter with signals at frequencies deliberately chosen to be above and below the filter's natural resonant frequency (col. 7:10-15). By measuring the amplitude of the filter's output at these specific off-resonance points, the system can identify a coin based on how it affects the filter's response, a method described as more stable and less susceptible to the drift that plagues oscillator-based designs (col. 2:57-col. 3:15; Fig. 1).
  • Technical Importance: This approach provided a potential path to a more robust, reliable, and dynamically programmable electronic coin acceptor that could automatically compensate for long-term drift in component values.

Key Claims at a Glance

  • The complaint does not identify specific asserted claims for analysis (Compl. ¶ 8). Independent claim 1 is representative of the core invention.
  • Essential elements of Independent Claim 1 include:
    • means for generating an input driving signal which is selectively varied between at least two predetermined characteristics
    • means for creating an electromagnetic field which is varied in response to said driving signal
    • means for producing alternating signals which are responsive to a conductive object in the presence of said electromagnetic field
    • means for measuring said alternating signals and determining whether a conductive object is an acceptable coin
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 3,944,038, "ENERGY DISSIPATING DEVICE FOR COIN HANDLING MECHANISMS," issued March 16, 1976

The Invention Explained

  • Problem Addressed: In coin handling mechanisms, coins moving at high velocity possess significant kinetic energy. When the coin's path changes or it must be stopped, this energy can cause bouncing and vibration, which interferes with the accuracy of coin testing sensors that require precise positioning (col. 1:21-34).
  • The Patented Solution: The invention discloses a simple device to dissipate a coin's kinetic energy by forcing it to strike a solid piece of material that is significantly harder than the coin itself (e.g., sintered aluminum oxide with a hardness >9 on the Mohs scale) (Abstract; col. 2:1-10). Because the dissipating device is much harder, the energy of the impact is absorbed primarily by the coin through inelastic collision, effectively deadening its bounce and allowing it to proceed along its path in a more controlled manner (col. 2:10-14; Fig. 1).
  • Technical Importance: This offered a low-cost, durable, and purely mechanical solution to improve the reliability of coin handling and sensor measurements by controlling coin dynamics.

Key Claims at a Glance

  • The complaint does not identify specific asserted claims for analysis (Compl. ¶ 10). Independent claim 1 is representative.
  • Essential elements of Independent Claim 1 include:
    • means defining a coin path through the mechanism
    • at least one energy dissipating device arranged to be struck by a coin travelling along the path and cause a change in direction
    • the energy dissipating device comprising a rigidly mounted solid piece of material having a hardness value greater than 9 on the Mohs scale
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 3,870,137, "METHOD AND APPARATUS FOR COIN SELECTION UTILIZING INDUCTIVE SENSORS," issued March 11, 1975

  • Technology Synopsis: This patent describes a method for examining coins by subjecting them to electromagnetic fields at two or more substantially different frequencies. A lower frequency is chosen to penetrate through the coin to test its bulk material properties, while a higher frequency is chosen to penetrate only a small percentage of the coin's thickness, testing its surface or cladding material (Abstract; col. 2:3-25). A coin is deemed acceptable only if it satisfies the examination criteria at both frequencies, providing a more robust test than a single-frequency system (col. 1:4-14).
  • Asserted Claims: The complaint alleges infringement of "the claims of the Two Frequency Patent" without further specification (Compl. ¶ 12).
  • Accused Features: The complaint alleges infringement by Defendant's "coin mechanisms" but provides no further detail on the specific features accused of infringing this patent (Compl. ¶ 12).

U.S. Patent No. 3,797,307, "COIN DISCRIMINATOR," issued March 19, 1974

  • Technology Synopsis: This patent discloses a method and apparatus for discriminating coins by performing at least two sequential tests. The system first performs one test and stores a value based on its result, which leads to a tentative determination of the coin's denomination (col. 2:7-19). It then evaluates the results of a second coin test in a manner that is dependent upon the outcome of the first test (Abstract). This sequential, dependent testing allows for a more discriminating range of tolerance for accepting coins than independent tests would permit (col. 2:30-34).
  • Asserted Claims: The complaint alleges infringement of "the claims of the Two Sensor Patent" without further specification (Compl. ¶ 14).
  • Accused Features: The complaint alleges infringement by Defendant's "coin mechanisms" but provides no further detail on the specific features accused of infringing this patent (Compl. ¶ 14).

III. The Accused Instrumentality

  • Product Identification: The complaint identifies the accused instrumentalities generally as "coin mechanisms" made, used, and sold by Defendant COINCO (Compl. ¶¶ 8, 10, 12, 14). No specific product models are named.
  • Functionality and Market Context: The complaint does not contain any allegations describing the technical functionality, operation, or market context of the accused COINCO coin mechanisms. The allegations are limited to conclusory statements that the mechanisms are "covered by the claims" of the patents-in-suit (Compl. ¶¶ 8, 10, 12, 14).

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

The complaint, filed under the notice pleading standards of its time, does not provide factual allegations sufficient to construct a detailed claim chart or to analyze the infringement theory on an element-by-element basis. The infringement allegations are stated in a conclusory manner for each patent (Compl. ¶¶ 8, 10, 12, 14).

  • Identified Points of Contention:
    • Given the lack of specific infringement allegations, any analysis of contention points is necessarily predictive. For the ’719 Patent, a central dispute would likely involve the scope of the means-plus-function claims, and whether the accused device's method of generating and measuring signals is structurally equivalent to the off-resonance filter and synthesizer-based system disclosed in the patent.
    • For the ’038 Patent, the primary factual question would be whether the accused mechanisms employ an energy-dissipating component that is a "solid piece of material" with a measured "hardness value greater than 9 on the Mohs scale," as strictly required by the claim.

V. Key Claim Terms for Construction

  • ’719 Patent

    • The Term: "means for generating an input driving signal having a selectively variable characteristic" (Claim 1)
    • Context and Importance: This is a means-plus-function limitation under 35 U.S.C. § 112, ¶ 6. Its construction is critical because the scope of the claim will be limited to the corresponding structure disclosed in the specification and its equivalents. The infringement analysis will depend on whether the accused device’s signal generation circuitry is equivalent to the structure disclosed in the ’719 Patent.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification describes the structure generally as a "frequency synthesizer" (col. 6:12) controlled by a "microcomputer" (col. 6:15-16), which a plaintiff might argue covers a range of digital frequency generation techniques.
      • Evidence for a Narrower Interpretation: The detailed embodiment discloses a specific structure comprising a pair of 4-bit synchronous up/down counters (64, 66) and associated flip-flops (68, 70) driven by a clock signal (Fig. 7; col. 11:4-14). A defendant would argue the claim is limited to this specific implementation and its structural equivalents.

  • ’038 Patent

    • The Term: "a hardness value greater than 9 on the Mohs scale" (Claim 1)
    • Context and Importance: This term sets a specific, quantitative physical property for the claimed energy dissipating device. Infringement will turn on a factual, evidentiary showing that the material used in the accused device meets this hardness threshold. Practitioners may focus on this term because it is a precise limitation that is potentially dispositive of infringement.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent provides an example, "a ceramic, such as sintered aluminium oxide" (col. 2:7-8), but does not limit the claim to that specific material, suggesting any material meeting the hardness requirement could infringe.
      • Evidence for a Narrower Interpretation: The specification emphasizes that the material is "much harder than any commonly used coins" (col. 2:10-11) and that this extreme hardness is the mechanism for dissipating energy within the coin itself. A defendant may argue that this functional context requires a strict interpretation of the "greater than 9" limitation, excluding materials that are merely "hard" but do not meet the specific numerical threshold.

VI. Other Allegations

  • Indirect Infringement: The complaint does not allege indirect infringement. The causes of action are explicitly for infringement in violation of 35 U.S.C. §271, with no facts alleged that would support inducement or contributory infringement (Compl. ¶¶ 17, 20, 23, 26).
  • Willful Infringement: The complaint alleges that "COINCO has continued the accused acts of infringement... after learning of the MARS patents referred to herein and after having been given notice of their infringement" (Compl. ¶ 15). The prayer for relief requests "treble damages for defendant's willful and deliberate acts of infringement" (Compl., Prayer for Relief (g)), grounding the willfulness claim in alleged pre-suit knowledge.

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

  • A central issue for the ’719 Patent will be one of structural equivalence: can the means-plus-function limitations, such as the "means for generating an input driving signal," be construed to cover the technology used in the accused products, or are they limited to the specific counter-and-flip-flop-based frequency synthesizer disclosed in the patent's embodiment?
  • A key evidentiary question for the ’038 Patent will be one of material science: does the accused device contain a component for energy dissipation that is factually demonstrated to be made from a material with a hardness "greater than 9 on the Mohs scale," as required by the claim, or does it use a different material or a different mechanism for reducing coin bounce?
  • A fundamental question for the case, arising from the complaint's lack of specificity, will be one of proof: what evidence will Plaintiff present to demonstrate that the accused COINCO "coin mechanisms" actually practice the specific technical steps and contain the specific components recited in the asserted claims of the four distinct patents-in-suit?