DCT

2:23-cv-01254

Bright Capture LLC v. Neat Co Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:23-cv-01254, E.D. Pa., 03/31/2023
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Pennsylvania because Defendant maintains a "regular and established place of business" in the district and has committed the alleged acts of patent infringement there.
  • Core Dispute: Plaintiff alleges that Defendant’s document scanning and financial organization products infringe three patents related to automatically capturing and organizing numerical data from documents, such as receipts, that lack a predefined format.
  • Technical Context: The technology at issue addresses the automated digitization and organization of financial data from physical documents to simplify expense tracking, budgeting, and record-keeping.
  • Key Procedural History: The complaint notes that U.S. Patent No. 10,049,410 issued more than four years after the Supreme Court's decision in Alice Corp. v. CLS Bank Int'l, preemptively arguing for its subject matter eligibility. It also states that the patent family was allowed by the Board of Patent Appeals and Interferences over prior art that failed to disclose "processing receipts having no predefined format," highlighting this as a key feature of the invention. Plaintiff also alleges it provided Defendant with pre-suit notice of infringement of U.S. Patent No. 7,746,510 via a letter dated March 20, 2023.

Case Timeline

Date Event
2001-02-01 Earliest Priority Date for all Patents-in-Suit
2010-06-29 U.S. Patent No. 7,746,510 Issued
2014-04-08 U.S. Patent No. 8,693,070 Issued
2018-08-14 U.S. Patent No. 10,049,410 Issued
2023-03-20 Plaintiff allegedly sent notice letter regarding ’510 Patent
2023-03-31 Complaint Filed

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

U.S. Patent No. 8,693,070 - "Receipts scanner and financial organizer"

  • Patent Identification: U.S. Patent No. 8,693,070, "Receipts scanner and financial organizer," issued April 8, 2014.

The Invention Explained

  • Problem Addressed: The patent addresses the problem that manually tracking expenses by saving receipts and entering the data into finance software is "very laborious and time consuming," leading users to abandon the practice (’070 Patent, col. 1:35-40).
  • The Patented Solution: The invention is a system combining a scanner and specialized software to automate this process. A user feeds receipts of various types (e.g., grocery, credit card) into the scanner, and the software automatically extracts the relevant information, organizes it into a database, and allows the user to view the data in various formats, such as tables or charts, for budgeting and analysis ('070 Patent, col. 2:55-65; Fig. 2).
  • Technical Importance: The invention claims to provide a "fast, easy, and convenient" alternative to manual data entry for personal and business finance management, making it easier for users to gain insight into their spending habits ('070 Patent, col. 1:43-47).

Key Claims at a Glance

  • Independent Claim Asserted: Claim 1.
  • Claim 1 Elements: A method performed in a system with a scanner and computing device, comprising the steps of:
    • Obtaining an electronic image of a document "having no predefined format" and containing numerical information;
    • Automatically capturing the numerical information from the image;
    • Organizing the captured numerical information;
    • Enabling editing of the captured information;
    • Enabling viewing of the captured information in a desired format; and
    • Combining the captured information with other previously captured numerical information into a report.

U.S. Patent No. 10,049,410 - "Receipts scanner and financial organizer"

  • Patent Identification: U.S. Patent No. 10,049,410, "Receipts scanner and financial organizer," issued August 14, 2018.

The Invention Explained

  • Problem Addressed: The patent identifies the common problem where individuals, despite earning enough money, "do not know how I am spending it" due to the difficulty of tracking numerous small transactions (’410 Patent, col. 1:14-17).
  • The Patented Solution: The patented method involves using a computer system to receive an image of a paper receipt, automatically process the image to "retrieve at least the relevant data," parse that data to obtain "expense data," and populate an electronic expense report ('410 Patent, col. 5:4-18). A key aspect is that the system is designed to handle receipts that have "no predefined format" ('410 Patent, col. 5:19-21).
  • Technical Importance: This technology aims to provide users with "instant insight into your expenses" by automatically categorizing transactions and creating customizable reports, thereby simplifying the process of financial management ('410 Patent, col. 2:55-60).

Key Claims at a Glance

  • Independent Claim Asserted: Claim 1.
  • Claim 1 Elements: A method for processing a paper expense receipt, comprising:
    • Receiving an electronic image of the receipt at a computer processor;
    • Processing the image to automatically obtain expense data by (i) using software to retrieve relevant data and (ii) parsing the relevant data;
    • Populating an electronic expense report with the expense data;
    • Displaying the electronic expense report;
    • Wherein the receipt has "no predefined format for the computer system."
  • The complaint reserves the right to assert other claims (Compl. ¶25, 29).

U.S. Patent No. 7,746,510 - "Receipts scanner and financial organizer"

  • Patent Identification: U.S. Patent No. 7,746,510, "Receipts scanner and financial organizer," issued June 29, 2010.

Technology Synopsis

This patent, the earliest in the asserted family, describes an apparatus for managing and organizing expense information. The system uses a scanner to process various types of receipts of "no predefined format," such as grocery or credit card slips, that have different widths and thicknesses ('510 Patent, col. 6:25-33). A computer then executes software to automatically categorize the expense information from each receipt and combine it with data from other receipts to produce reports for financial analysis ('510 Patent, col. 5:13-28).

Asserted Claims

The complaint asserts at least claim 11 (Compl. ¶35).

Accused Features

The complaint accuses the "Exemplary Defendant Products" and alleges that Defendant's "product literature and website materials" induce end-users to infringe ('510 Patent, col. 6:34-36).

III. The Accused Instrumentality

  • Product Identification: The complaint identifies the accused instrumentalities as the "Exemplary Defendant Products" (Compl. ¶25, 29, 34).
  • Functionality and Market Context: The complaint does not describe the specific functionality of the accused products. Instead, it incorporates by reference external exhibits (Exhibits 4, 5, and 6) that allegedly contain claim charts comparing the patent claims to the accused products (Compl. ¶26, 30, 36). As these exhibits were not filed with the complaint, the public docket does not provide a basis for analyzing the specific features or market context of the accused products. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant directly infringes the ’070 Patent and the ’410 Patent, and induces infringement of the ’510 Patent (Compl. ¶25, 29, 35). For each patent, the complaint states that a claim chart detailing the infringement theory is provided in an exhibit (Exhibits 4, 5, and 6); however, these exhibits are not attached to the publicly filed complaint (Compl. ¶26, 30, 36).

Because the complaint defers all substantive infringement allegations to these missing exhibits, it does not provide sufficient detail for a tabular claim chart analysis or to identify specific technical or legal points of contention regarding infringement. The core allegation is that the "Exemplary Defendant Products" practice the methods and systems claimed in the patents-in-suit.

V. Key Claim Terms for Construction

  • The Term: "no predefined format"
  • Context and Importance: This term appears in the asserted independent claims of the ’070 and ’410 patents and is central to the inventive concept described in all three patents-in-suit. Practitioners may focus on this term because the complaint explicitly states that the patent family was allowed by the patent office's appeal board based on a finding that the prior art "did not disclose processing receipts having no predefined format" (Compl. ¶21). The construction of this term will therefore be critical in defining the scope of the claims and distinguishing them from the prior art.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party could argue for a broad interpretation, suggesting the term means any document that does not conform to a single, rigid, pre-programmed template. The specification’s exemplary list of documents—"grocery receipts, various purchase receipts, credit card receipts, bank statements, etc." ('410 Patent, col. 2:50-52)—supports the idea that the invention is intended to handle a wide variety of documents whose data fields (e.g., vendor name, date, total amount) appear in different locations.
    • Evidence for a Narrower Interpretation: A party could argue for a narrower construction, potentially limiting the term to documents that vary in their physical dimensions or requiring a more advanced level of adaptability than simply handling a few known-but-different layouts. The specification notes the scanner is "capable of scanning receipts of different widths and thicknesses" ('410 Patent, col. 4:1-2), which could be used to tie the "format" to physical characteristics. Furthermore, the claim language requiring the extraction of specific "numerical information" or "expense data" might be used to argue the scope is limited to systems that can intelligently identify and parse financial data from truly unstructured sources, not just documents with minor formatting variations.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement of the ’510 Patent. The factual basis for this claim is that Defendant, after allegedly receiving notice of the patent, continued to provide its products and distribute "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes" ('510 Patent, col. 6:34-36).
  • Willful Infringement: The complaint does not use the word "willful" but does request that the case be declared "exceptional" under 35 U.S.C. § 285, which can be a predicate for enhanced damages (Compl., p. 7, ¶E.i). The factual basis for this appears to be the allegation of pre-suit knowledge of the ’510 Patent, based on a notice letter and claim chart allegedly sent to and received by Defendant on or before March 20, 2023 (Compl. ¶33).

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

  1. A core issue will be one of definitional scope: can the phrase "no predefined format," which was key to the patents’ allowance, be construed broadly enough to cover the capabilities of the accused products while remaining valid over the prior art? The case will likely depend on whether this term is interpreted to mean merely handling different document layouts or if it requires a more sophisticated adaptability to truly unstructured data and physical dimensions.

  2. A second central question relates to pleading sufficiency and evidence: given that the complaint's infringement contentions are made entirely by reference to external exhibits not included in the filing, a key early issue may be whether the complaint, on its face, provides sufficient factual detail to support a plausible claim for relief under the Twombly/Iqbal standard.

  3. Finally, a key question for damages and potential enhancement will be one of knowledge and intent: what evidence will emerge regarding Defendant’s alleged pre-suit knowledge of the ’510 patent, and can Plaintiff show that Defendant’s "product literature" specifically and knowingly instructed users to perform the patented methods, as required for a finding of induced infringement?