DCT

7:25-cv-00512

Connected Orange LLC v. Google LLC

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 7:25-cv-00512, W.D. Tex., 11/04/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Google maintains a regular and established place of business in the district, including multiple large offices, data centers, a retail store in Austin, and numerous employees.
  • Core Dispute: Plaintiff alleges that Defendant’s Android devices (including Pixel phones), smart home products (Google Home, Nest), and associated software services (Google Wallet, Google Pay, Fast Pair Service) infringe five patents related to mobile payments, user interface for image display, and wireless device pairing and communication.
  • Technical Context: The asserted patents cover technologies central to the functionality of modern consumer electronics, addressing mobile commerce, efficient graphical user interface management for large media libraries, and secure short-range device communication.
  • Key Procedural History: The complaint states that Plaintiff provided Defendant with pre-suit notice of infringement via an email on August 28, 2025, which identified the asserted patents and accused product lines. The complaint also notes that Plaintiff had previously engaged in licensing discussions with Allied Security Trust (“AST”), of which Google is a member, but those discussions stalled.

Case Timeline

Date Event
2004-06-30 U.S. Patent No. 8,341,088 Priority Date
2007-03-30 U.S. Patent No. 10,096,016 Priority Date
2010-03-04 U.S. Patent No. 9,703,453 Priority Date
2012-12-25 U.S. Patent No. 8,341,088 Issued
2013-02-21 U.S. Patent No. 9,955,347 Priority Date
2015-06-26 U.S. Patent No. 9,924,448 Priority Date
2017-07-11 U.S. Patent No. 9,703,453 Issued
2018-03-20 U.S. Patent No. 9,924,448 Issued
2018-04-24 U.S. Patent No. 9,955,347 Issued
2018-10-09 U.S. Patent No. 10,096,016 Issued
2025-08-28 Plaintiff sent pre-suit notice letter to Defendant
2025-11-04 Complaint Filing Date

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

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

Issued Dec. 25, 2012

The Invention Explained

  • Problem Addressed: The patent describes a market where electronic payment methods for telepayment, proximity payment, and internal (on-device) payment are handled by separate, "too partial" systems, lacking a unified, multipurpose approach (’088 Patent, col. 2:61-65).
  • The Patented Solution: The invention proposes a method and system where a "payment proxy" resides on a user's multimedia terminal (e.g., a smartphone) (’088 Patent, col. 4:18-21). This proxy intercepts payment orders from applications and, based on a "specific local or remote processing criterion" such as the type of transaction or the availability of a network connection, determines whether to process the payment locally on the device or transmit it to a remote payment system (’088 Patent, col. 4:26-50). This allows the system to function flexibly, for instance by executing a local payment when network connectivity is absent (’088 Patent, col. 6:8-12).
  • Technical Importance: This architecture provides a method for mobile devices to handle various transaction types through a single gateway, potentially enabling offline or local payments that would otherwise fail, thereby increasing the reliability of mobile commerce.

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶26).
  • Claim 1 recites an electronic payment method with the essential elements:
    • transmitting from a multimedia terminal a payment order, issued by at least one multimedia application hosted by said multimedia terminal, to a payment proxy local to the multimedia terminal;
    • determining, in said local payment proxy, if said payment order is to be processed by a local payment or a remote payment;
    • processing the payment order according to a local payment method upon determining that the payment order is to be processed by local payment; and
    • transmitting the payment order to a remote system for remote payment upon determination that the payment order is to be processed by remote payment;
    • wherein the determination depends on whether the payment type is a proximity payment or a telepayment, and whether a connection to the remote system is available via a network.

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

Issued Jul. 11, 2017

The Invention Explained

  • Problem Addressed: The patent addresses the technical challenge of displaying large, high-resolution images on devices with smaller screens and limited memory (’453 Patent, col. 1:30-48). Standard methods are slow because scrolling or viewing different parts of an image often requires the entire large image file to be decoded repeatedly, degrading user experience (’453 Patent, col. 2:30-38).
  • The Patented Solution: The invention describes an apparatus that creates and stores "cache files" containing lower-resolution "shrunken images" and "map data" that helps quickly locate and decode only the necessary parts of the full-resolution image (’453 Patent, col. 2:46-65). In a "thumbnail index mode," the system improves browsing speed by not only creating a cache file for the currently viewed images but also preferentially creating cache files for adjacent thumbnails within a "predetermined range," anticipating the user's next action (’453 Patent, col. 10:45-54).
  • Technical Importance: This predictive caching method aims to reduce latency when browsing large photo galleries on mobile devices, providing a smoother and more responsive user interface.

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶38).
  • Claim 1 recites an image display apparatus with the essential elements:
    • a screen;
    • a control section that controls a thumbnail index mode in which a plurality of thumbnails are displayed;
    • a cache file creation section that creates a cache file including a shrunken image corresponding to the displayed thumbnails as a first cache file creation process; and then
    • preferentially creates a cache file including a shrunken image corresponding to a first thumbnail within a predetermined range from the displayed thumbnails as a second cache file creation process; and
    • a shrunken image output section that displays a shrunken image based on the cache file while the corresponding encoded image is being decoded.

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

Issued Mar. 20, 2018

  • Technology Synopsis: The ’448 Patent describes a local "hub" device that manages access to a remote service (e.g., cloud storage or streaming media) for a user's terminal. The hub receives an access request with identification parameters from the terminal, temporarily stores them, and uses them to connect to the remote service on the user's behalf, deleting the parameters after the session ends to enhance privacy and security (’448 Patent, Abstract).
  • Asserted Claims: The complaint asserts at least independent claim 1 (Compl. ¶50).
  • Accused Features: The complaint alleges that Google Home and Nest devices, which utilize Google Assistant and the Google Home app, infringe the ’448 Patent (Compl. ¶48).

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

Issued Apr. 24, 2018

  • Technology Synopsis: The ’347 Patent discloses a method for securely pairing a new device to a private wireless network. The coordinating entity (e.g., a hub) and the new device first connect on a separate, temporary network to securely exchange the credentials (e.g., encryption key and network ID) for the main private network, after which the new device is instructed to switch over and join the main network (’347 Patent, Abstract).
  • Asserted Claims: The complaint asserts at least independent claim 1 (Compl. ¶62).
  • Accused Features: The infringement allegations target 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 Oct. 9, 2018

  • Technology Synopsis: The ’016 Patent describes a method for informing a user about the outcome of a contactless transaction. The system detects the end of the transaction (e.g., when a phone is moved away from a payment terminal), obtains a message identifying the specific application used and the result of the transaction, and communicates that message to the user via the mobile terminal's interface (’016 Patent, Abstract).
  • Asserted Claims: The complaint contains a contradiction, alleging infringement of "at least claim 16" in one paragraph (Compl. ¶74) and referencing "claim 1" in the next paragraph concerning the associated claim chart (Compl. ¶75). U.S. Patent No. 10,096,016 contains only 12 claims, making the reference to claim 16 an error. The analysis proceeds based on independent claim 1.
  • Accused Features: The complaint accuses Android wireless devices, including Pixel phones, that "support Google Wallet and/or Google Pay" of infringing the ’016 Patent (Compl. ¶72).

III. The Accused Instrumentality

Product Identification

  • The complaint names several categories of accused products and services:
    • Android wireless devices, including specifically the Pixel phone line (Compl. ¶¶24, 36, 60, 72).
    • Google Wallet and Google Pay services (Compl. ¶¶24, 72).
    • Google Home and Nest smart home devices (Compl. ¶48).
    • Google Fast Pair Service (Compl. ¶60).

Functionality and Market Context

  • The accused products and services collectively represent Google's mobile and smart home ecosystem. The complaint alleges that Pixel phones, running the Android operating system, implement Google's contactless payment solutions (Google Pay/Wallet), a proprietary device pairing protocol (Fast Pair), and user interfaces for displaying media (Compl. ¶¶5, 24, 36, 60).
  • Google Home and Nest devices are identified as smart home hubs that utilize Google Assistant and can interact with other devices and remote services (Compl. ¶48).
  • The complaint frames these products as central to Google's business in the Western District of Texas and throughout the United States (Compl. ¶¶5, 10).

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits for each asserted patent (Exhibits A-E) but does not attach them (Compl. ¶¶27, 39, 51, 63, 75). In the absence of these exhibits, the infringement analysis is based on the narrative allegations in the complaint, which do not map specific product features to individual claim elements.

  • '088 Patent Infringement Allegations:

    • The complaint alleges that Android wireless devices like the Pixel, which support Google Wallet and/or Google Pay, infringe at least claim 1 of the ’088 Patent (Compl. ¶¶24, 26). It asserts that infringement details are provided in the unattached Exhibit A (Compl. ¶27).
    • Identified Points of Contention:
      • Scope Questions: A central question may be whether services like Google Pay or Google Wallet function as a "payment proxy local to the multimedia terminal" as required by the claim. The defense may argue that these services are primarily cloud-based and do not perform the claimed local/remote discrimination based on network availability.
      • Technical Questions: What evidence does the complaint provide that the accused services process payments "according to a local payment method" when a network connection is unavailable, as contemplated by the patent? The analysis will depend on the technical specifics of how Google's payment services handle offline transactions.

  • '453 Patent Infringement Allegations:

    • The complaint alleges that display devices including the Pixel 9 and Pixel 10 series infringe at least claim 1 of the ’453 Patent (Compl. ¶¶36, 38). It states that infringement details are provided in the unattached Exhibit B (Compl. ¶39).
    • Identified Points of Contention:
      • Scope Questions: The interpretation of "thumbnail index mode" will be significant. A key issue may be whether the accused devices' standard photo gallery application performs the specific two-step caching process required by claim 1, which includes a "first cache file creation process" and a "second cache file creation process" that preferentially creates caches for adjacent thumbnails.
      • Technical Questions: Does the accused software functionality create cache files for thumbnails "within a predetermined range from the displayed thumbnails" in a predictive manner to anticipate user scrolling? Infringement analysis will require a technical examination of the caching algorithms used in the Android gallery application on Pixel devices.

No probative visual evidence provided in complaint.

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 Google's software architecture falls within the scope of the claims. Practitioners may focus on this term because the distinction between a "local proxy" and a cloud-based service is fundamental to the infringement case.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification states the proxy is "disconnection-mounted between" an application and the communication interface, suggesting a software layer rather than a physically distinct component (’088 Patent, col. 6:41-44). This could support an argument that any software that intercepts and routes payment requests qualifies.
      • Evidence for a Narrower Interpretation: The patent repeatedly ties the proxy's function to discriminating between local and remote processing, particularly for enabling payments "in the absence of message transmission by an air interface" (’088 Patent, col. 2:5-12). This context may support a narrower definition requiring the proxy to have substantive offline processing capabilities, not just simple routing logic.

  • 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 clause describes the core inventive step of predictive caching. The case will likely turn on whether the accused devices perform this specific, forward-looking caching action, as opposed to more generic caching methods.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent does not narrowly define "predetermined range" or the mechanism of "preferentially" creating the cache, which could allow the patentee to argue it covers any form of pre-caching of nearby images in a gallery view.
      • Evidence for a Narrower Interpretation: The detailed description describes a specific process where, after a user stops scrolling, the system creates caches for images "right before and right after the current image ID being viewed" (’453 Patent, col. 10:37-43). This embodiment may be used to argue for a narrower construction requiring a specific, sequential, and anticipatory caching algorithm triggered by user behavior in a thumbnail gallery.

VI. Other Allegations

  • Indirect Infringement: For all five patents, the complaint alleges induced infringement. The basis for inducement is Google's alleged creation and dissemination of "advertisements and instructive materials that promote the infringing use" of the Accused Products, such as user manuals, developer documentation, and technical support materials (Compl. ¶¶28-29, 40-41, 52-53, 64-65, 76-77).
  • Willful Infringement: The complaint alleges willful infringement for all asserted patents. This allegation is based on Google's alleged knowledge of the patents, stemming at a minimum from the pre-suit notice letter sent on August 28, 2025, which Google allegedly ignored (Compl. ¶¶31, 43, 55, 67, 79, 80). The complaint asserts that Google's continued infringing conduct despite this notice constitutes willful, wanton, and deliberate disregard of Plaintiff's patent rights (Compl. ¶80).

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

  1. A central question will be one of architectural mapping: Does the software architecture of Google Pay and Google Wallet function as a "payment proxy local to the multimedia terminal" (’088 Patent) that makes processing decisions based on network availability, or is there a fundamental mismatch with the patent’s emphasis on enabling local, offline transactions?

  2. A key evidentiary issue will be one of algorithmic specificity: Do Google's Pixel devices, when operating in a "thumbnail index mode" (’453 Patent), employ a predictive caching algorithm that "preferentially creates a cache file" for adjacent thumbnails to anticipate user scrolling, or does the complaint lack the technical evidence to prove this specific functionality beyond generic caching?

  3. A significant legal challenge for the plaintiff may arise from pleading deficiencies: Given that the complaint makes conclusory infringement allegations for multiple complex technologies while relying on unattached claim charts, an early focus of the case may be on whether the complaint provides sufficient factual detail to state a plausible claim for infringement under the standards set by Iqbal and Twombly.