DCT

1:25-cv-01794

Iscan2d Tech LLC v. Apple Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-01794, W.D. Tex., 11/07/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant maintains a "regular and established business presence" in the district, including corporate offices, multiple Apple Store retail locations, and a substantial number of employees.
  • Core Dispute: Plaintiff alleges that Defendant’s Apple Watch and Apple iPhone products infringe patents related to using a scannable visual code displayed on one device to establish a secure wireless pairing and data link with another device.
  • Technical Context: The technology addresses simplifying data exchange between consumer electronics, particularly in the health and fitness sector, by replacing proprietary hardware or software connections with a universal, camera-based scanning method.
  • Key Procedural History: The complaint notes that the two asserted patents share a common specification and priority date. It also alleges the patents are "pioneering," having been cited as relevant prior art in over 200 subsequent U.S. patent applications, including five assigned to Defendant Apple Inc.

Case Timeline

Date Event
2011-08-05 Earliest Priority Date for Asserted Patents
2023-05-30 U.S. Patent No. 11,664,123 Issued
2023-05-30 Alleged Infringement by Apple Watch Begins
2025-02-18 U.S. Patent No. 12,230,394 Issued
2025-02-18 Alleged Infringement by Apple iPhone Begins
2025-11-07 Complaint Filing Date

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

U.S. Patent No. 11,664,123 - "Barcode Generation and Implementation Method and System for Processing Information"

The Invention Explained

  • Problem Addressed: The patent's background describes the difficulty of transferring data between mobile devices and other electronics, such as fitness equipment, due to a lack of universal communication standards, the high cost of implementing diverse hardware connections, and the unreliability of proprietary protocols (’123 Patent, col. 2:17-32).
  • The Patented Solution: The invention proposes a system where a data-generating device (e.g., a piece of exercise equipment or a wearable sensor) creates and displays a "barcode" or other scannable media that encodes specific information. A user's mobile device can then scan this visual code with its camera to capture the data without needing a direct physical or complex wireless connection, thereby creating a universal bridge between devices (’123 Patent, Abstract; col. 4:1-25).
  • Technical Importance: This method provided a hardware-agnostic solution for interoperability, aiming to circumvent the "near impossible" task for equipment manufacturers to support the proprietary protocols of every available mobile device (’123 Patent, col. 2:25-32).

Key Claims at a Glance

  • The complaint asserts independent claims 1 and 11, along with multiple dependent claims (Compl. ¶42, ¶46).
  • Claim 1 is directed to a "wearable activity device" comprising a display, sensors, wireless circuitry, and a processor. The processor is configured to store wireless pairing information, generate a "color coded digital scannable media" based on that information, display the media, and then use it to establish a wireless link with a mobile device that scans the media. (’123 Patent, col. 39:27-40:1).
  • Claim 11 is directed to a method for establishing such a communications link, reciting the core steps of storing pairing information, generating and displaying the scannable media on the wearable device, and establishing the link after a mobile device scans it (’123 Patent, col. 40:47-41:12).

U.S. Patent No. 12,230,394 - "Barcode Generation and Implementation Method and System for Processing Information"

The Invention Explained

  • Problem Addressed: As a continuation of the application for the ’123 Patent, this patent addresses the same technical problems of device interoperability (Compl. ¶12; ’394 Patent, col. 2:17-32).
  • The Patented Solution: The invention utilizes the same system of visual code scanning for data transfer. However, the claims of the ’394 Patent are focused on the actions of the mobile device (e.g., the smartphone) that scans the code, whereas the ’123 Patent claims are focused on the wearable device that generates and displays the code (’394 Patent, col. 39:11-40:15).
  • Technical Importance: The solution provides a complete system-level approach, with the ’123 Patent covering the transmitting device and the ’394 Patent covering the receiving and processing device.

Key Claims at a Glance

  • The complaint asserts independent claims 1 and 11, along with multiple dependent claims (Compl. ¶42, ¶63).
  • Claim 1 is directed to a "mobile device" comprising a camera, display, and processor. The processor executes instructions to detect a "color coded digital scannable media" from an external wearable device, optically obtain wireless pairing information from that media, process the information, and establish a wireless link to receive and display data from the wearable device. (’394 Patent, col. 39:11-40:15).
  • Claim 11 is directed to a system comprising both the wearable activity tracking device (which generates and displays the scannable media) and the mobile device (which scans the media and establishes the link), thereby claiming the entire two-device interaction (’394 Patent, col. 40:50-42:12).

III. The Accused Instrumentality

Product Identification

  • The "Apple Watch Accused Instrumentalities" (including Series 8 through 11, SE, and Ultra models) are accused of infringing the ’123 Patent. The "Apple iPhone Accused Instrumentalities" (including models 15 through 17) are accused of infringing the ’394 Patent (Compl. ¶42).

Functionality and Market Context

  • The complaint alleges that the accused Apple Watch and iPhone products, when used together for device pairing, practice the claimed technology (Compl. ¶49, ¶66). The complaint does not provide specific details on the technical operation of Apple's pairing process, instead incorporating by reference Claim Charts attached as Exhibits C and D, which were not included with the complaint filing (Compl. ¶48, ¶65). The complaint makes no specific allegations regarding the products’ commercial importance beyond identifying them as products sold by the Defendant (Compl. ¶42).

IV. Analysis of Infringement Allegations

The complaint alleges infringement based on claim charts (Exhibits C and D) that were not publicly filed with the initial complaint (Compl. ¶50, ¶67). The complaint's narrative theory is that the accused products satisfy all elements of the asserted claims (Compl. ¶49, ¶66).

The infringement theory for the ’123 Patent centers on the Apple Watch acting as the claimed "wearable activity device." It is alleged to generate and display a scannable visual medium containing wireless pairing information, which is then used to establish a connection with an iPhone (Compl. ¶46, ¶49).

The infringement theory for the ’394 Patent centers on the Apple iPhone acting as the claimed "mobile device." It is alleged to use its camera to scan the visual medium displayed by the Apple Watch, optically obtain and process the pairing information from it, and thereby establish a wireless link with the watch (Compl. ¶63, ¶66).

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

  • The Term: "color coded digital scannable media" (Appears in asserted independent claims of both patents)
  • Context and Importance: This term's construction is central to the dispute, as infringement will depend on whether the animated visual pattern displayed by an Apple Watch during its initial setup process falls within the term's scope. The question is whether the term requires a code that digitally encodes specific data, like a QR code, or if it can also cover a dynamic visual pattern that functions as a synchronization or authentication target.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent specification states that the term "barcode" as used in the disclosure refers to "a 1D barcode, a 2D barcode, a 3D barcode, and/or an augmented reality marker/image/code" (’123 Patent, col. 5:32-36). This suggests the inventor contemplated a range of visual targets beyond traditional data-matrix barcodes. The complaint also highlights patent language about using color to "enhance the amount of data capture," which could be argued to support a broader reading covering complex visual patterns (Compl. ¶31; ’394 Patent, col. 36:18-21).
    • Evidence for a Narrower Interpretation: The specification's primary embodiment and figures consistently describe a process of creating a "data string" that is then "converted into barcode" (’123 Patent, Fig. 2; col. 4:39-44). The complaint itself cites a specific example from the patent where the media is a "barcode that has a wifi MAC address linked to the display electronics," indicating a direct encoding of specific pairing data (Compl. ¶30; '394 Patent, col. 36:44-48). This may support a narrower construction requiring the media to contain a parsable data string.
  • The Term: "obtain, from the memory device, the wireless pairing information" and "generate a color coded digital scannable media responsive to the wireless pairing information" (’123 Patent, Claim 1)
  • Context and Importance: Practitioners may focus on the relationship between these elements. The claim requires the scannable media to be generated "responsive to" the stored pairing information. The infringement analysis will turn on the technical evidence showing how, in the accused Apple Watch, the specific pairing information (e.g., a MAC address or other identifier) is used as an input to generate the visual pairing pattern.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term "responsive to" is broad and does not require a one-to-one encoding. It could be argued that any visual pattern whose generation is triggered by or dependent upon the pairing information meets this limitation.
    • Evidence for a Narrower Interpretation: The patent's examples, such as linking a barcode to a MAC address, suggest a direct causal link where the information dictates the content or structure of the scannable media (’394 Patent, col. 36:44-48). A defendant may argue that a generic animation that does not change based on the specific pairing data of the device does not meet this limitation.

VI. Other Allegations

  • Willful Infringement: The complaint does not include an explicit count for willful infringement. It alleges that Defendant has had knowledge of its infringement "at least as of the service of the present complaint" (Compl. ¶45, ¶62). This allegation establishes a basis for potential post-suit enhanced damages but does not allege pre-suit knowledge, which is typically a cornerstone of a willfulness claim.

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

  • A core issue will be one of definitional scope: can the claim term "color coded digital scannable media," which is described in the patent specification with reference to data-encoding barcodes, be construed to cover the animated, colored pattern displayed by the Apple Watch during its pairing sequence?
  • A key evidentiary question will be one of technical mechanism: does the accused Apple pairing process involve the iPhone optically "obtaining... wireless pairing information from" the visual pattern displayed on the Watch, as required by the claims, or does the visual scan merely initiate a separate, non-optical exchange of the pairing data? The resolution will depend on technical evidence not detailed in the complaint.