Connected Orange LLC v. Google LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Connected Orange LLC (Texas)
  • Defendant: Google LLC (Delaware)
  • Plaintiff’s Counsel: Nelson Bumgardner Conroy PC
• Case Identification: 7:25-cv-00512, W.D. Tex., 11/04/2025
• Venue Allegations: Venue is alleged to be proper in the Western District of Texas based on Defendant’s commission of infringing acts in the district and its maintenance of a regular and established place of business there, including multiple offices, data centers, and a retail store in Austin, along with authorized retailers in Midland.
• Core Dispute: Plaintiff alleges that Defendant’s Android devices, smart home products, and related services (including Google Wallet, Google Pay, and Fast Pair) infringe five patents related to electronic payments, user interface management, and wireless device communication.
• Technical Context: The patents-in-suit cover a range of technologies central to modern smart devices, including mobile payment processing, efficient display of high-resolution images, and secure pairing of wireless peripherals.
• Key Procedural History: The complaint alleges that Plaintiff provided Defendant with pre-suit notice of infringement via an email on August 28, 2025, which identified the asserted patents and accused products. Plaintiff states that this communication followed stalled discussions between Plaintiff and Allied Security Trust (AST), of which Google is a member.

Case Timeline

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

U.S. Patent No. 8,341,088 - Multipurpose Electronic Payment Method and System

Issued December 25, 2012

The Invention Explained

• Problem Addressed: The patent describes the challenge of creating a versatile electronic payment system on mobile devices that can function across different contexts—such as remote "telepayment," "proximity payment," and "internal" on-device payments—without always requiring a live connection to a remote server for authorization, which can be slow, costly, or unavailable (ʼ088 Patent, col. 1:4-16, col. 2:1-11).
• The Patented Solution: The invention introduces a "payment proxy" located on the user's multimedia terminal (e.g., a smartphone). This proxy intercepts payment orders from applications and, based on a set of criteria like payment type, network availability, or transaction amount, decides whether to process the payment locally or transmit it to a remote server for authorization ('088 Patent, col. 2:21-34). This dual-mode capability, illustrated in Figure 2a, allows for fast, offline processing of certain transactions while retaining the security of remote authorization for others ('088 Patent, col. 6:35-54, Fig. 2a).
• Technical Importance: This approach provided a framework for mobile payment systems to operate reliably and efficiently even with intermittent network connectivity, a key requirement for user adoption.

Key Claims at a Glance

• Independent Claim 1 is asserted (Compl. ¶26).
• Essential elements of Claim 1 include:
  • transmitting from a multimedia terminal a payment order to a payment proxy local to the terminal;
  • determining in the proxy whether the order should be processed locally or remotely;
  • processing the order locally if determined for local payment;
  • transmitting the order to a remote system if determined for remote payment;
  • wherein the determination for remote processing is based on the payment type being a proximity or telepayment AND a network connection being available.

U.S. Patent No. 9,703,453 - Image Display Apparatus and Processing Method for a Thumbnail Index Mode in a Device

Issued July 11, 2017

The Invention Explained

• Problem Addressed: The patent addresses the inefficiency of displaying and navigating large, high-resolution images on devices with limited memory, processing power, and smaller screens. Standard methods that require decoding an entire image file to view or scroll are slow and create a poor user experience (ʼ453 Patent, col. 1:30-44).
• The Patented Solution: The invention proposes a system that pre-processes encoded images to create and store "map data" (an index of the image's macroblock locations) and lower-resolution "shrunken images" in a cache file ('453 Patent, col. 2:46-67). When a user browses a gallery in "thumbnail index mode," the system uses these cache files to display thumbnails quickly. Crucially, it "preferentially creates a cache file" for thumbnails adjacent to the one being viewed, anticipating user scrolling and pre-loading data to make navigation appear seamless ('453 Patent, col. 10:40-52). This process is distinct from the handling of individual image viewing and is designed to optimize the gallery browsing experience ('453 Patent, col. 16:21-33, Claim 1).
• Technical Importance: This method enables fluid and responsive photo gallery navigation on mobile devices, even with libraries containing thousands of high-resolution images.

Key Claims at a Glance

• Independent Claim 1 is asserted (Compl. ¶38).
• Essential elements of Claim 1 include:
  • A screen and a control section for a thumbnail index mode.
  • A cache file creation section that performs a "first cache file creation process" for displayed thumbnails.
  • The cache file creation section then performs a "second cache file creation process" to "preferentially" create a cache file for a thumbnail within a predetermined range from the displayed thumbnails.
  • A shrunken image output section that displays a shrunken image from the cache file while the full encoded image is decoded in the background.

U.S. Patent No. 9,924,448 - Device for Short-Range Communication, Adapted to Provide Access to a Remote Service

Issued March 20, 2018

• Technology Synopsis: The patent describes a hub device (e.g., a smart home hub) that acts as an intermediary for accessing a remote service. A user's terminal (e.g., a smartphone) sends an access request with identification parameters to the hub, which temporarily stores the parameters, uses them to make a second request to the remote service, and then transfers data related to that service ('448 Patent, Abstract). This architecture is designed to enhance security by ensuring the access credentials are not stored permanently on the hub and are deleted after the session ends ('448 Patent, col. 2:25-30).
• Asserted Claims: At least Claim 1 (Compl. ¶50).
• Accused Features: The complaint accuses Google Home and Nest devices, including Nest Hub and Nest Hub Max, which utilize Google Assistant and the Google Home app (Compl. ¶48).

U.S. Patent No. 9,955,347 - Technique of Pairing In a Wireless Network

Issued April 24, 2018

• Technology Synopsis: The patent discloses a secure method for pairing a new device to a private wireless network. Instead of pairing directly on the main network, the coordinating entity (e.g., a router or hub) and the new device first connect on a separate, temporary network specific to that device ('347 Patent, Abstract). On this temporary network, they securely exchange the credentials (e.g., encryption key, network identifier) for the main private network, after which the new device is instructed to switch over and join the main network, which never had to be opened to discovery ('347 Patent, col. 2:30-49).
• Asserted Claims: At least Claim 1 (Compl. ¶62).
• Accused Features: The complaint accuses Google wireless devices such as the Pixel phone line that utilize "Google's Fast Pair Service proprietary Bluetooth Low Energy pairing standard" (Compl. ¶60).

U.S. Patent No. 10,096,016 - Method of Communicating and Transmitting a Message Relating to a Transaction of a Contactless Application, Associated Terminal, Secure Module and System

Issued October 9, 2018

• Technology Synopsis: The patent addresses the need to provide real-time user feedback after a contactless transaction (e.g., an NFC payment). The described method involves detecting the end of a transaction between a mobile terminal and an external piece of equipment (e.g., a payment reader), obtaining a message that identifies the specific application used and provides transaction information, and then communicating that message to the user via the terminal's display or speaker ('016 Patent, Abstract; col. 2:1-5). This ensures the user is immediately informed of the transaction's outcome without manual checking ('016 Patent, col. 1:39-43).
• Asserted Claims: At least Claim 1 (Compl. ¶74-75, noting a scrivener's error in ¶74 referencing Claim 16, which does not exist in the patent).
• Accused Features: The complaint accuses Android wireless devices, including Pixel phones, that support Google Wallet and/or Google Pay (Compl. ¶72).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are broadly categorized as:

1. Android wireless devices, specifically including the Pixel phone line, that utilize Google Wallet, Google Pay, and Google Fast Pair Service (Compl. ¶5, ¶24, ¶60, ¶72).
2. Display devices including the Pixel 9 and Pixel 10 series phones (Compl. ¶36).
3. Google Home and Nest smart home devices, including Nest Hub (2nd gen) and Nest Hub Max, that use Google Assistant and the Google Home app (Compl. ¶48).

Functionality and Market Context

• The complaint alleges that these products incorporate functionalities central to the modern mobile and smart home ecosystems. Google Wallet and Google Pay on Pixel phones are alleged to perform contactless payments by deciding whether to use locally stored credentials or require online authorization (Compl. ¶24). The photo gallery applications on these phones are alleged to manage and display thumbnails from large image libraries, pre-caching adjacent images for faster browsing (Compl. ¶36). The Google Fast Pair Service is alleged to provide a streamlined method for pairing Bluetooth accessories to Android devices (Compl. ¶60). Google Home and Nest devices are alleged to act as central hubs for controlling smart home functions and accessing remote services (Compl. ¶48).
• The complaint frames these products and services as core components of Google's hardware and software ecosystem, which are widely distributed and sold in the United States (Compl. ¶10).

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

The complaint states that claim charts are attached as Exhibits A through E; however, these exhibits were not provided. The infringement analysis is therefore based on the narrative allegations in the complaint body.

’088 Patent Infringement Allegations

• The complaint alleges that Google's Android devices supporting Google Wallet and/or Google Pay practice the method of Claim 1 (Compl. ¶26-27). The narrative theory suggests that when a user initiates a contactless payment, the device's software acts as the claimed "payment proxy." This proxy allegedly determines whether to complete the transaction using locally stored information (e.g., a limited-use token) or to seek real-time authorization from a remote payment server over a network. This decision process is alleged to meet the claim limitation of determining between a "local payment" and a "remote payment" based on criteria including network availability (Compl. ¶24).
• Identified Points of Contention: A central question may be whether the software architecture of Google Pay/Wallet constitutes a "payment proxy local to the multimedia terminal" that is "disconnection-mounted between" an application and the communication interface, as described in the patent ('088 Patent, col. 6:41-43). The dispute may also focus on whether the technical basis for choosing a transaction path in the accused products aligns with the specific criteria recited in the claim, particularly the interplay between "payment type" and "network availability."

’453 Patent Infringement Allegations

• The complaint alleges that Google's Pixel phones infringe at least Claim 1 by their method of displaying image thumbnails in a gallery view (Compl. ¶38-39). The theory appears to be that the Android OS or photo gallery app performs the claimed "first cache file creation process" by generating and storing low-resolution shrunken images for the thumbnails currently on screen. It is further alleged that the system performs the "second cache file creation process" by "preferentially" creating cache files for thumbnails of images that are not on screen but are adjacent in the gallery, in anticipation of the user scrolling. This pre-caching is alleged to meet the claim limitation of creating cache files for thumbnails "within a predetermined range from the displayed thumbnails" (Compl. ¶36).
• Identified Points of Contention: The analysis will likely focus on the term "preferentially creates." The parties may dispute what level of pre-caching or pre-loading of adjacent image data is required to meet this limitation. Another question may be whether the accused devices perform two distinct "processes" for caching—one for currently displayed thumbnails and a second for adjacent ones—as required by the claim language.

V. Key Claim Terms for Construction

For the ’088 Patent

• The Term: "payment proxy local to the multimedia terminal"
• Context and Importance: This term is the central component of the claimed invention. Its construction will determine whether the software architecture of Google Wallet/Pay, which may be deeply integrated into the operating system and various application layers, can be considered a single, distinct "proxy" as contemplated by the patent. Practitioners may focus on this term because the patent describes the proxy as an intercepting layer between an application and the network interface.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent states that the terminal "hosts the payment proxy application PP" ('088 Patent, col. 7:56-57), which could suggest any software on the device performing the claimed function. The claims do not specify a particular software structure.
  • Evidence for a Narrower Interpretation: The specification describes the proxy as being "disconnection-mounted between" the application and the communication interface "so as to intercept any payment order issued by this application" ('088 Patent, col. 6:41-45). This language may support an argument that the proxy must be a discrete, intercepting software module, rather than an integrated function of the payment application or operating system itself.

For the ’453 Patent

• The Term: "preferentially creates a cache file... corresponding to a first thumbnail within a predetermined range from the displayed thumbnails"
• Context and Importance: This limitation defines the core inventive step for optimizing thumbnail browsing. The dispute will likely center on what actions constitute "preferentially" creating a cache file for nearby images. The outcome will depend on whether any pre-loading of adjacent image data meets the claim, or if a more specific, structured process is required.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself is general, not specifying the mechanism of preference or the exact nature of the "predetermined range." This could support a reading that covers any system that prioritizes caching nearby images over distant ones.
  • Evidence for a Narrower Interpretation: The specification describes a specific process where, after loading the current image, the system checks for the existence of cache files for adjacent images and creates them if they are missing, repeating this for a certain range (ʼ453 Patent, col. 10:31-48). This could support an argument that "preferentially creates" requires an active, ordered process of creating new cache files for neighboring images, not merely pre-fetching existing data.

VI. Other Allegations

Indirect Infringement

For all asserted patents, the complaint alleges induced infringement, stating that Google knowingly and intentionally encourages direct infringement by end-users. The alleged acts of inducement include creating and disseminating advertisements, user manuals, technical documentation, and developer tools that instruct on the use of the accused features (e.g., Google Wallet, Fast Pair Service) in an infringing manner (Compl. ¶28, ¶40, ¶52, ¶64, ¶76).

Willful Infringement

The complaint alleges willful infringement for all asserted patents, contending that Google's infringement continued despite having knowledge of the patents. This knowledge is alleged to have been established, at a minimum, by the pre-suit notice letter sent on August 28, 2025, which Google allegedly ignored. The complaint asserts this conduct constitutes an objectively high likelihood of infringement that Google disregarded, justifying enhanced damages (Compl. ¶31, ¶43, ¶55, ¶67, ¶79, ¶80).

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

• A central issue will be one of technical implementation: Do the software architectures of Google’s accused products (e.g., Google Pay, Android Photos, Fast Pair) operate in a manner that maps onto the specific processes and components required by the patent claims? For example, does Google Pay utilize a distinct "payment proxy," or does the Android Photos app employ a "second cache file creation process" for adjacent thumbnails?
• A second key question will be one of definitional scope: How broadly will key claim terms like "payment proxy" and "preferentially creates" be construed? The resolution of these terms will be critical in determining whether the functionality of Google's highly integrated and complex software ecosystems falls within the boundaries of the patent claims.
• An evidentiary question will revolve around knowledge and intent: What evidence will be presented to support the allegations that Google's actions, particularly after receiving pre-suit notice, rose to the level of inducement and willful infringement, as opposed to representing good-faith disagreement over patent scope or validity?