Bright Capture LLC v. Fyle Tech Pvt Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Bright Capture LLC (Delaware)
  • Defendant: Fyle Technologies Private Limited (India)
  • Plaintiff’s Counsel: Kent & Risley LLC
• Case Identification: 6:23-cv-00001, W.D. Tex., 01/03/2023
• Venue Allegations: Venue is asserted on the basis that the Defendant is a foreign corporation, which may be sued in any judicial district pursuant to 28 U.S.C. § 1391(c).
• Core Dispute: Plaintiff alleges that Defendant’s expense management software infringes patents related to systems and methods for automatically scanning, extracting data from, and organizing information from unstructured documents like financial receipts.
• Technical Context: The technology at issue addresses the automation of expense reporting by using scanning and data processing to eliminate manual data entry from physical or digital receipts.
• Key Procedural History: The complaint notes that the '510 Patent was allowed following a decision by the Board of Patent Appeals and Interferences which found that the prior art did not disclose processing receipts with "no predefined format." It also highlights that the '410 Patent was examined and issued by the USPTO more than four years after the Supreme Court's decision in Alice Corp. v. CLS Bank Int’l, a point raised to support the patent-eligibility of the asserted claims.

Case Timeline

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

U.S. Patent No. 8,693,070 - “Receipts scanner and financial organizer,” issued Apr. 8, 2014

The Invention Explained

• Problem Addressed: The patent describes the process of manually entering financial data from receipts into budgeting or finance software as "very laborious and time consuming," leading users to abandon the practice of tracking their expenses ('070 Patent, col. 1:28-35).
• The Patented Solution: The invention proposes a system combining a scanner and specialized software to automate this process. A user feeds receipts into the scanner, and the software automatically extracts the financial information, organizes it into a database, and allows the user to view the data in various formats, such as reports or charts, without manual transcription ('070 Patent, Abstract; col. 2:54-65). A key aspect is the system's ability to handle documents of "no predefined format" ('070 Patent, col. 4:57-58).
• Technical Importance: This approach aimed to solve a practical data-entry bottleneck by automating the conversion of unstructured paper-based financial data into an organized, digital format for analysis and record-keeping ('070 Patent, col. 1:36-44).

Key Claims at a Glance

• The complaint asserts independent claim 1 and reserves the right to assert others (Compl. ¶28).
• Independent Claim 1 recites a method with the following essential elements:
  • Obtaining, via a scanner, an electronic image of a document with "no predefined format" containing numerical information.
  • Automatically capturing the electronic image including the numerical information in a computing device.
  • Organizing the captured numerical information.
  • Enabling editing of the captured information.
  • Enabling viewing of the captured information in a desired format.
  • Combining the captured information with previously captured information to form a report.

U.S. Patent No. 10,049,410 - “Receipts scanner and financial organizer,” issued Aug. 14, 2018

The Invention Explained

• Problem Addressed: The patent identifies the same problem as its family members: the tedious and time-consuming manual labor required to save receipts and enter transaction data into finance management software ('410 Patent, col. 1:18-26).
• The Patented Solution: The invention claims a method for processing a paper expense receipt where a computer system receives an electronic image of the receipt, uses software to automatically retrieve and parse relevant expense data from that image, and populates an electronic expense report with the data ('410 Patent, Abstract; col. 5:4-18). The system is designed to handle receipts that have "no predefined format" ('410 Patent, col. 5:19-20). The detailed description explains that the software can categorize transactions and generate reports like cash flow or budget comparisons ('410 Patent, col. 2:54-60).
• Technical Importance: The invention provided a specific technological improvement in computer and scanning technology by enabling the automated processing of documents without a predefined format, which was noted during prosecution as a feature lacking in the prior art (Compl. ¶22, 24).

Key Claims at a Glance

• The complaint asserts independent claim 1 and reserves the right to assert others (Compl. ¶32).
• Independent Claim 1 recites a method with the following essential elements:
  • Receiving a paper expense receipt at a computer input device.
  • Receiving an electronic image of the receipt on a computer processor.
  • Processing the image to "automatically obtain expense data" by using software to retrieve and parse relevant data.
  • Populating an electronic expense report with the expense data.
  • Displaying the electronic expense report.
  • The method is specified to work on an expense receipt having "no predefined format for the computer system."

Multi-Patent Capsule

• Patent Identification: U.S. Patent No. 7,746,510, “Receipts scanner and financial organizer,” issued June 29, 2010 ('510 Patent).
• Technology Synopsis: This patent describes an apparatus for managing expense information. The system uses a scanner to scan various types of receipts, which may have no predefined format, and a computer with software that processes the scanned information to automatically extract numerical data, categorize the expenses, and generate reports for financial management ('510 Patent, Abstract; col. 2:46-59).
• Asserted Claims: The complaint asserts independent claim 11 (Compl. ¶38).
• Accused Features: The complaint alleges that Defendant provides its "Exemplary Defendant Products" and distributes "product literature and website materials" that induce customers to use the products in a way that infringes the '510 Patent (Compl. ¶37-38).

III. The Accused Instrumentality

Product Identification

• The complaint identifies the accused instrumentalities as the "Exemplary Defendant Products" (Compl. ¶28, 32, 37).

Functionality and Market Context

• The complaint does not describe the specific functionality of the accused products in detail. It alleges that Defendant's products are used for expense management and infringe by performing the methods claimed in the patents-in-suit (Compl. ¶28, 32, 38). The complaint incorporates by reference claim charts in Exhibits 4, 5, and 6, which purportedly provide details on the accused products and the infringement allegations; however, these exhibits were not filed with the complaint document (Compl. ¶29, 33, 39).
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references external claim-chart exhibits that were not provided. The infringement theories are summarized below based on the complaint's narrative allegations.

• ’070 Patent Infringement Allegations: The complaint asserts that Defendant directly infringes at least claim 1 of the '070 Patent by "making, using, offering to sell, selling and/or importing" the accused products (Compl. ¶28). The infringement theory appears to be that the accused products, when used as intended, practice the claimed method of obtaining an image of an unstructured receipt, automatically capturing and organizing the numerical data from it, and combining that data into a report ('070 Patent, col. 5:35-col. 6:1).
• ’410 Patent Infringement Allegations: The complaint asserts direct infringement of at least claim 1 of the '410 Patent (Compl. ¶32). The narrative theory suggests that Defendant's products and services implement the claimed method by receiving an image of a paper receipt, using software to automatically parse and extract expense data, and populating an electronic expense report for display to the user, all while operating on receipts that have no predefined format ('410 Patent, col. 5:4-20).
• Identified Points of Contention:
  • Scope Questions: A question may arise as to whether the term "scanner" ('070 Patent, col. 5:36) or "computer input device" for a paper receipt ('410 Patent, col. 5:6), in patents with a 2001 priority date, can be construed to cover modern image capture devices like smartphone cameras that transmit data to a cloud-based processing system.
  • Technical Questions: The patent claims require a system to "automatically" process receipts with "no predefined format." A central technical question will be what evidence shows that the accused software's data extraction and organization process functions in the manner claimed, particularly concerning its ability to handle unstructured documents without relying on a set of predefined templates that might fall outside the claim's scope.

V. Key Claim Terms for Construction

• The Term: "no predefined format" (appears in '070 Patent, claim 1; '410 Patent, claim 1)

• Context and Importance: This term is central to the invention's purported novelty and patentability, as the complaint emphasizes that this capability was lacking in the prior art (Compl. ¶24). The infringement analysis will likely depend on whether the accused system is truly format-agnostic or if it relies on a library of known receipt layouts, which could place it outside the scope of this limitation.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification suggests a broad scope by listing a wide variety of document types, including "grocery receipts, various purchase receipts, credit card receipts, bank statements, etc." ('410 Patent, col. 2:50-52). This language may support an interpretation that covers any document containing numerical financial data, regardless of its specific layout.
  • Evidence for a Narrower Interpretation: A party could argue that the specific examples shown, such as the tabular grocery receipt in Figure 4A ('410 Patent, FIG. 4A), implicitly limit the scope to common, consumer-style documents. It could be argued that if an accused system uses any form of structural analysis or template matching, it is not handling documents with "no predefined format."

• The Term: "automatically" (appears in '070 Patent, claim 1; '410 Patent, claim 1)

• Context and Importance: Practitioners may focus on this term because it defines the degree of automation required by the claims and distinguishes the invention from prior art manual data entry. The dispute may turn on how much, if any, user intervention is permissible for a process to be considered "automatic."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification states that "all the information from the scanned receipts is automatically entered into the computer" ('410 Patent, col. 4:20-22). This supports a reading where the core data extraction occurs without manual transcription by the user, even if subsequent editing is an option.
  • Evidence for a Narrower Interpretation: The flowchart in Figure 2 depicts a sequential process where information is scanned (Step 15), "automatically entered" (Step 16), and then "process[ed] and organiz[ed]" (Step 17) before any optional user editing (Step 19) ('410 Patent, FIG. 2). A party might argue this implies a fully hands-off process and that a system requiring user guidance to identify data fields or correct significant OCR errors does not meet the "automatically" limitation.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement of the '510 Patent. The factual basis for this claim is the allegation that Defendant distributes "product literature and website materials" that instruct and encourage end-users to operate the accused products in a manner that directly infringes the patent's claims (Compl. ¶37-38).
• Willful Infringement: Willfulness is implicitly alleged for the '510 Patent. The complaint asserts that Defendant had "actual knowledge" of the '510 Patent and its alleged infringement based on a notice letter and claim chart sent on December 28, 2022, prior to the filing of the lawsuit (Compl. ¶36). The complaint alleges that Defendant continued its infringing conduct despite this notice (Compl. ¶37).

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

• A core issue will be one of technological evolution and claim scope: How will claim terms like "scanner" and a "computer input device" that receives a "paper...receipt," originating from a 2001 priority date, be construed in the context of modern cloud-based software that receives digital images from smartphone cameras? The viability of the infringement case may depend on whether the claims are interpreted to cover these contemporary system architectures.
• A key evidentiary question will be one of technical implementation: The patents claim the novel capability of processing receipts with "no predefined format." The case will likely require a detailed factual analysis of whether the accused Fyle software operates using the specific automated parsing and organizing methods recited in the claims, or if it employs a different technology, such as template libraries or machine learning models, that could create a mismatch with the claimed invention.
• A threshold legal question will be patent eligibility under 35 U.S.C. § 101: While the complaint argues for eligibility, claims directed to collecting, parsing, and organizing financial data are frequently challenged as being directed to abstract ideas. The court will likely need to determine whether the asserted claims are directed to an abstract concept and, if so, whether the specific limitations—such as processing documents with "no predefined format"—constitute a sufficient "inventive concept" to render the claims patent-eligible.