Alliance Laundry Systems LLC v. PayRange LLC

1. Case Identification

• Case #: IPR2025-00573
• Patent #: 11,481,772
• Filed: February 3, 2025
• Petitioner(s): Alliance Laundry Systems, LLC
• Patent Owner(s): PayRange LLC
• Challenged Claims: 7 and 11

2. Patent Overview

• Title: Method and System for Presenting Representations of Payment Accepting Unit Events
• Brief Description: The ’772 patent discloses methods for using a mobile device to interact with and conduct transactions at payment-accepting units, such as vending machines. The system involves the mobile device presenting representations of events from the payment unit on its display.

3. Grounds for Unpatentability

Ground 1: Obviousness of Claim 7 - Claim 7 is obvious over Low in view of Arora.

• Prior Art Relied Upon: Low (Patent 10,210,501) and Arora (Patent 9,898,884).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Low, which discloses a system for electronic payments to non-Internet connected devices like vending machines, teaches all limitations of the disclaimed base claim 1. Dependent claim 7 adds limitations requiring the mobile device to include an accelerometer, use data from it to determine if the user is walking away from the payment unit, and cancel the wireless communication path upon such a determination. While Low did not explicitly teach this, Petitioner asserted that Arora did. Arora taught a personal electronic device with an accelerometer that uses "inertial guidance" to determine a customer's location and trajectory relative to vending machines. Petitioner argued that determining if a customer is exiting a transaction distance, as taught by Arora, inherently teaches determining if the user is "walking away" and implies the need to cancel the communication path.
  • Motivation to Combine: Petitioner contended a POSITA would combine Arora’s accelerometer-based movement detection with Low’s mobile payment system to conserve resources. Maintaining a wireless connection, particularly a near-field one, is unnecessary and wasteful if the user is no longer in proximity and is not a potential customer. Canceling the connection when the user walks away would be a predictable and desirable improvement.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success in this combination. Using an accelerometer to determine a mobile device's location and trajectory was a well-known and predictable solution, and implementing logic to terminate a wireless connection based on this data would have been a simple and routine modification to the system of Low.

Ground 2: Obviousness of Claim 11 - Claim 11 is obvious over Low in view of Arora, in further view of Freeny and Casey.

• Prior Art Relied Upon: Low (Patent 10,210,501), Arora (Patent 9,898,884), Freeny (Patent 8,958,846), and Casey (Patent 8,255,323).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that dependent claim 11 adds several user interface (UI) features not explicitly disclosed in Low. However, these features were well-known in the art and taught by the additional references.
    • The limitation of a "visual representation of the available payment accepting unit" was taught by Arora, which disclosed displaying icons of two different vending machines on the device screen.
    • The limitation of "an indication of a prepared balance" was taught by Freeny, which disclosed checking and displaying an "approved credit amount" for the user.
    • The limitation of an "affordance that when slid, indicates the initiation of the transaction" in response to a "swipe" input was taught by Casey, which disclosed a slide bar that a user drags to confirm a payment.
  • Motivation to Combine: A POSITA would have been motivated to incorporate these various UI elements from Arora, Freeny, and Casey into the system of Low to create a more convenient and user-friendly interface. Providing visual machine selection, balance information, and an intuitive swipe-to-pay gesture were all known methods for improving the user experience in mobile transaction applications. The combination was argued to be the application of known techniques to a known system to yield predictable results.
  • Expectation of Success: Integrating these known graphical UI elements into the mobile payment application of Low would have been a simple and routine task for a POSITA, such as a software developer, with a high expectation of success. Modifying the software to display icons, balance data, and a slide-to-confirm control would leverage conventional programming techniques.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial would be inappropriate under both the Fintiv and General Plastic frameworks.
• Fintiv Factors: Denial was argued to be unwarranted because the parallel Delaware litigation is in a very early stage with no trial date set, and Petitioner stipulated it would not pursue the same invalidity grounds in district court if the IPR is instituted. Petitioner also noted that the Board previously instituted an IPR against claim 11 of the same patent (IPR2023-01449) based on similar prior art, demonstrating the strength of the grounds.
• General Plastic / §325(d): Denial based on prior petitions was argued to be inappropriate because Petitioner is unrelated to the prior petitioners (Kiosoft and CSC), and those prior proceedings were terminated due to settlement before a final written decision was reached. Furthermore, the grounds presented are not identical, as claim 7 was not previously challenged in the instituted IPR. Finally, Petitioner asserted that the key prior art references were not substantively evaluated by the Examiner during the original prosecution of the ’772 patent.

5. Relief Requested

• Petitioner requests institution of IPR and cancellation of claims 7 and 11 of the ’772 patent as unpatentable.