CheckWizard LLC v. JPMorgan Chase Bank NA

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: CheckWizard LLC (New Mexico)
  • Defendant: JPMorgan Chase Bank, N.A. (New York)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00829, E.D. Tex., 08/21/2025
• 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 there.
• Core Dispute: Plaintiff alleges that Defendant’s mobile products infringe a patent related to capturing, packaging, and sharing images as "image entities" that include associated data profiles and exist for a limited time within a network.
• Technical Context: The technology concerns a system for managing image-based communication on mobile devices, where images are combined with metadata and executable functions to create distinct digital objects for transmission and use within a networked environment.
• Key Procedural History: The patent-in-suit is a continuation of a series of applications dating back to January 2004, indicating a long prosecution history. The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patent.

Case Timeline

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

U.S. Patent No. 10,140,514 - Capturing and sharing images with mobile device users including for a limited duration of time

• Patent Identification: U.S. Patent No. 10,140,514, titled “Capturing and sharing images with mobile device users including for a limited duration of time,” issued November 27, 2018 (’514 Patent).

The Invention Explained

• Problem Addressed: The patent’s background section identifies limitations in prior art mobile communication, which was primarily voice-based or handled digital files like image attachments as "discrete and separate," thus "limiting utility." (’514 Patent, col. 1:19-29). It asserts a need for image-based communication that more deeply integrates images with "different types of related information" and functionality beyond simple viewing. (’514 Patent, col. 1:50-54).
• The Patented Solution: The invention describes a method for creating a "virtual image entity," which is a composite digital object combining a captured image with an "image profile." (’514 Patent, col. 6:37-41). This profile associates the image with collateral information such as text, voice, location, time data, and even executable functions. (’514 Patent, col. 5:65–6:2, Fig. 1). These image entities can be constructed on a mobile device and propagated across a network to be accessible to specific users, potentially for a limited duration of time. (’514 Patent, Abstract; col. 4:14-24).
• Technical Importance: The described technology aims to elevate an image from a static file to an interactive, data-rich object that can be managed and controlled within a secure, networked system. (’514 Patent, col. 2:11-23).

Key Claims at a Glance

• The complaint does not specify which claims are asserted, referring only to "Exemplary '514 Patent Claims" in an unattached exhibit (Compl. ¶13). Analysis of the patent’s first independent claim, Claim 1, is presented for context.
• Independent Claim 1 requires a mobile device comprising:
  • one or more cameras configured to acquire an image;
  • one or more processors configured to construct an image entity using the acquired image and an image profile of the acquired image; and
  • a transmit unit configured to send the image entity to one or more servers, wherein the sent image entity is accessible to one or more recognized users of the virtual network via one or more user devices and/or applications.
• The complaint states that both device and method claims are infringed, and it may assert infringement of claims beyond those identified in its referenced charts. (Compl. ¶11-12).

III. The Accused Instrumentality

Product Identification

The complaint does not name specific accused products. It refers to "Exemplary Defendant Products" detailed in "charts incorporated into this Count" via Exhibit 2. (Compl. ¶11, ¶13). Exhibit 2 was not filed with the complaint. Given the defendant is JPMorgan Chase Bank, N.A., the accused instrumentalities are presumably its mobile banking applications or related services.

Functionality and Market Context

The complaint provides no specific details on the functionality of the accused products. It alleges globally that the products "practice the technology claimed by the '514 Patent" and "satisfy all elements of the Exemplary '514 Patent Claims." (Compl. ¶13).

IV. Analysis of Infringement Allegations

The complaint references claim charts in an exhibit that was not provided, preventing a detailed, element-by-element analysis of the infringement allegations. (Compl. ¶14). The narrative infringement theory alleges that Defendant’s mobile products perform the functions recited in the ’514 Patent’s claims. (Compl. ¶13). This would presumably involve a user capturing an image (such as a check for mobile deposit), the device or system associating that image with other data (such as account information, deposit amount, and user credentials), and transmitting this combined data package to Defendant's servers for processing within its banking network.

No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: A central dispute may arise over the proper construction of the patent's terminology in the context of a mobile banking application. For example, does the transmission of a check image with associated transactional data to a bank's server constitute sending an "image entity" to be accessed by "recognized users of the virtual network" as claimed, or does the claim language require a more peer-to-peer or social-networking context as described in the specification? (’514 Patent, Abstract).
• Technical Questions: The complaint lacks factual allegations detailing how the accused products technically operate. A key question will be what evidence demonstrates that the accused products "construct an image entity using... an image profile," particularly whether the data associated with a mobile banking transaction meets the patent's definition of an "image profile," which includes elements like "behavior, function and relationships to other images/objects." (’514 Patent, col. 5:1-5).

V. Key Claim Terms for Construction

The Term: "image entity"

• Context and Importance: This term is the foundational concept of the invention. Whether the data package transmitted by the accused product (e.g., a check image bundled with transaction metadata) meets the definition of an "image entity" will be dispositive for infringement.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent defines the term broadly as a composite data structure, comprising an image and an "image profile" that associates the image with "collateral information such as audio, voice, text," location, and time data. (’514 Patent, col. 5:65-col. 6:2). This could support an argument that any image bundled with its relevant metadata qualifies.
  • Evidence for a Narrower Interpretation: The specification describes an "image entity" as a "unitized" object with "embedded multimedia capabilities... and executable functions." (’514 Patent, col. 7:14-19). Furthermore, the abstract notes that the "digital image entity comes into existence at a specified time, exists for a desired duration of time, and ceases to exist at a set time." (’514 Patent, Abstract). A defendant may argue that a standard financial transaction record, which is typically archived permanently and lacks executable functions, does not meet this more specific description.

The Term: "virtual network"

• Context and Importance: Claim 1 requires the user to be "affiliated with a virtual network" and the image entity to be accessible to "recognized users" of that network. The definition of this term will determine whether a bank's customer base using a mobile app constitutes such a network.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term is not explicitly defined, which could support a plain-meaning interpretation covering any group of users authorized to interact with a common server or data repository.
  • Evidence for a Narrower Interpretation: The patent’s abstract and specification provide examples of such networks, including "social networks, professional networks, enterprise networks, family networks, [and] friends networks." (’514 Patent, Abstract; col. 9:39-42). This context may support an argument that the term implies a network for interpersonal communication or data sharing among a group of users, rather than the client-server relationship between an individual customer and a financial institution.

VI. Other Allegations

Willful Infringement

The complaint does not explicitly allege willful infringement or plead facts suggesting Defendant had pre-suit knowledge of the ’514 Patent. The prayer for relief requests that the case be declared "exceptional" under 35 U.S.C. § 285 for the purpose of recovering attorneys' fees but does not specifically request enhanced damages for willfulness under 35 U.S.C. § 284. (Compl. p. 4).

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

This case will likely depend on the resolution of fundamental questions of claim scope and evidentiary proof, particularly given the complaint’s lack of specific factual allegations.

1. A core issue will be one of definitional scope: can key terms from the patent, such as "image entity" and "virtual network"—which are described in the specification with reference to dynamic, multimedia-rich, and often ephemeral social communications—be construed broadly enough to read on the transmission of a check image and its associated data within the structured, transactional environment of a mobile banking application?
2. A key evidentiary question will be one of technical implementation: assuming a favorable claim construction, what technical evidence will Plaintiff provide to demonstrate that Defendant's products actually "construct" an "image entity" with an "image profile" as required by the claims, as opposed to simply transmitting an image file with conventional metadata? The resolution of this question will require a deep dive into the architecture of the accused systems.