Bright Capture LLC v. SAP America

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Bright Capture LLC (Delaware)
  • Defendant: SAP America, Inc. (Delaware)
  • Plaintiff’s Counsel: Kent & Risley LLC
• Case Identification: Bright Capture LLC v. SAP America, Inc., 2:22-cv-00019, E.D. Tex., 01/13/2022
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains an established place of business in the district and has allegedly committed acts of patent infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s financial software and services infringe three patents related to automatically scanning, extracting, and organizing data from expense receipts.
• Technical Context: The patents address technology for automating expense management by digitally capturing and processing financial data from unstructured physical documents, a key function in both personal and enterprise financial software.
• Key Procedural History: The three asserted patents are part of the same patent family. The complaint does not mention any prior litigation or administrative proceedings involving these patents.

Case Timeline

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

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’s background describes the process of manually entering financial data from receipts into budgeting or finance software as "very laborious and time consuming," leading users to lose patience and abandon the practice ('410 Patent, col. 1:21-26).
• The Patented Solution: The invention is a system comprising a scanner and software that automates this process. A user feeds receipts into the scanner, and the software automatically extracts the financial information and organizes it into a report viewable in various formats, such as tables or charts, without requiring the receipts to have a predefined format ('410 Patent, Abstract; col. 2:41-51). The process is illustrated in a flowchart showing the automatic entry and organization of information after scanning ('410 Patent, Fig. 2).
• Technical Importance: The technology aims to reduce the friction of manual data entry, thereby making digital expense tracking more accessible and consistent for individuals and businesses ('410 Patent, col. 1:27-33).

Key Claims at a Glance

• The complaint asserts "Exemplary '410 Patent Claims" identified in an external exhibit (Compl. ¶13). Independent claim 1 is representative and includes the following essential elements:
  • A method of receiving an electronic image of a paper expense receipt from a computer input device.
  • Processing the image to automatically obtain expense data by using software to retrieve and parse relevant data.
  • Populating an electronic expense report with the data.
  • Displaying the report to the individual.
  • A condition that the expense receipt has "no predefined format for the computer system."

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

• Patent Identification: U.S. Patent No. 10,453,151, “Receipts scanner and financial organizer,” issued October 22, 2019.

The Invention Explained

• Problem Addressed: The ’151 Patent addresses the same technical problem as the ’410 Patent: the inefficiency and labor-intensive nature of manually transcribing data from physical receipts for digital financial management ('151 Patent, col. 1:20-29).
• The Patented Solution: The solution is a system that processes an image of a document, such as a receipt, that lacks a predefined format. It automatically extracts numerical data from the image and categorizes it to create a financial report, thereby automating the data capture and organization workflow ('151 Patent, Abstract; col. 2:44-54).
• Technical Importance: As with the ’410 Patent, this technology is presented as a way to streamline personal and business expense management by automating a key data-entry bottleneck ('151 Patent, col. 1:29-35).

Key Claims at a Glance

• The complaint asserts "Exemplary '151 Patent Claims" identified in an external exhibit (Compl. ¶22). Independent claim 1 is representative and claims a non-transitory computer readable medium with instructions to perform steps including:
  • Obtaining image information of a document having "no predefined format" and containing numerical information.
  • Processing the image information to "automatically extract" the numerical information.
  • "Automatically categorizing" the extracted information into at least one predefined category to enable creating a report.

Multi-Patent Capsule: 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.
• Technology Synopsis: As an earlier patent in the same family, the ’070 Patent describes a system for financial organization where a scanner provides an electronic image of a document with "no predefined format" to a computer ('070 Patent, Claim 1). The system automatically captures, organizes, and combines numerical data from these documents into a unified report, addressing the problem of tedious manual data entry for expense tracking ('070 Patent, col. 1:30-39).
• Asserted Claims: The complaint asserts "Exemplary '070 Patent Claims" identified in an external exhibit (Compl. ¶31).
• Accused Features: The complaint alleges that the "Exemplary Defendant Products" practice the technology claimed by the ’070 Patent (Compl. ¶31).

III. The Accused Instrumentality

Product Identification

• The complaint does not name specific accused products. It refers to them as the "Exemplary Defendant Products" identified in claim charts attached as Exhibits 4, 5, and 6 (Compl. ¶¶ 13, 22, 31). These exhibits were not filed with the complaint.

Functionality and Market Context

• Based on the infringement allegations, the accused instrumentalities are software products or services offered by SAP America, Inc., that are alleged to process images of financial documents (like receipts), extract data, and organize it for expense management purposes (Compl. ¶¶ 18, 27, 36). The complaint alleges these products are made, used, sold, and tested by Defendant and its employees (Compl. ¶¶ 13-14). The complaint does not provide sufficient detail for analysis of the specific functionality or market positioning of the accused products. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not contain claim charts within the body of the document; instead, it incorporates them by reference as external exhibits that were not provided with the public filing (Compl. ¶¶ 19, 28, 37). As such, a detailed claim chart summary cannot be constructed.

The narrative infringement theory alleges that the Defendant's products directly infringe by performing all steps of the claimed methods or containing all elements of the claimed systems (Compl. ¶¶ 18, 27, 36). The core of the allegation is that the accused products receive images of receipts, automatically extract numerical and expense data from them without relying on a predefined document format, and organize that data into financial reports for users.

• Identified Points of Contention:
  • Scope Questions: A central issue may be the scope of the claim term "no predefined format." The analysis will likely explore whether the accused SAP products, which may use sophisticated optical character recognition (OCR) and machine learning models, operate on documents with "no predefined format" in the manner contemplated by the patent, or if they implicitly rely on learned templates or formats that fall outside the claim's scope.
  • Technical Questions: The complaint alleges automatic extraction and organization of expense data. A key factual question will be what level of automation the accused products achieve versus what is required by the claims. For example, what evidence does the complaint provide that the accused product’s processing is "automatic" if it requires user intervention or correction to categorize data, as distinguished from the claimed "automatic" processing?

V. Key Claim Terms for Construction

1. The Term: "no predefined format"

• Context and Importance: This term appears in the independent claims of all asserted patents and is central to the invention's scope. Its construction will determine whether the claims are limited to systems that are truly agnostic to document layout or if they can read on modern data capture systems that may use pattern recognition or templates.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification lists a variety of document types the invention can process, including "grocery receipts, various purchase receipts, credit card receipts, bank statements, etc.," suggesting the invention is intended to be versatile and handle diverse layouts ('410 Patent, col. 2:50-52).
  • Evidence for a Narrower Interpretation: The abstract states the invention obtains an image of "a document, the document being of no predefined format," which could be argued to require a complete absence of any expected structure ('410 Patent, Abstract). A defendant may argue that modern systems, even if flexible, still rely on learned structures that constitute a "predefined format" in some sense.

2. The Term: "automatically extract" / "automatically obtain"

• Context and Importance: The degree of automation is a critical limitation. The dispute will likely focus on whether the accused products perform the extraction and organization steps without the level of human intervention that would negate the "automatic" nature of the process.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent contrasts the invention with "laborious and time consuming" manual entry, suggesting that "automatically" means a process that avoids this specific user burden ('410 Patent, col. 1:21-23). The patent's flowchart depicts "Information from scanned receipts automatically entered in computer" as a discrete, automated step ('410 Patent, Fig. 2, step 16).
  • Evidence for a Narrower Interpretation: The specification discloses that a user can "modify or edit each transaction" after the information is organized ('410 Patent, col. 4:29-31). This may suggest that the term "automatically" does not require perfect, error-free extraction and that some level of user correction is contemplated by the patent.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials inducing end users and others to use its products" in a manner that infringes the patents-in-suit (Compl. ¶¶ 17, 26, 35).
• Willful Infringement: The complaint alleges that Defendant has had "actual knowledge" of its infringement at least since being served with the complaint and the associated claim charts (Compl. ¶¶ 15, 24, 33). This allegation appears to be based on post-suit conduct.

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

• A central question will be the construction of the phrase "no predefined format." The case may turn on whether this term, which has priority to 2001, can be interpreted to read on modern, sophisticated data extraction systems that may use AI and learned models, or if its meaning is limited to the specific types of unstructured documents contemplated in the patent's specification.
• A key evidentiary issue will be the degree of automation in the accused SAP products. The dispute will likely focus on factual evidence demonstrating whether the accused systems "automatically extract" and "automatically categoriz[e]" data as claimed, or if the level of required user intervention, correction, or pre-configuration places their functionality outside the scope of the claims.
• As the complaint identifies the accused products and specific infringement theories only in extrinsic exhibits, a primary initial issue will be for the Plaintiff to provide specific factual allegations connecting the functionality of named SAP products to the limitations of the asserted claims.