PTAB

IPR2025-00950

Alliance Laundry Systems LLC v. PayRange LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and System for an Offline-Payment Operated Machine to Accept Electronic Payments
  • Brief Description: The ’608 patent discloses systems and methods for retrofitting offline, coin-operated machines (e.g., vending or laundry machines) to accept electronic payments from mobile devices. The invention centers on a payment module that communicates wirelessly with a mobile device and interfaces with the machine’s existing control unit by emulating the electrical pulse signals typically generated by coin insertion to initiate operation.

3. Grounds for Unpatentability

Ground 1: Obviousness over Breitenbach and Brown - Claims 1-3, 5-9, 11-15, 17, and 18 are obvious over Breitenbach in view of Brown.

  • Prior Art Relied Upon: Breitenbach (Patent 9,092,768) and Brown (Patent 5,734,150).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Breitenbach taught nearly all limitations of the independent claims, including a retrofit payment module for an offline machine, a short-range wireless transceiver for communicating with a mobile device, and a first interface module. Critically, Breitenbach disclosed "fooling" the machine by replicating a "coin-in" signal to initiate operation, which corresponds to emulating electrical pulses. Petitioner contended the only limitation not expressly taught by Breitenbach was storing in memory the specific number of electrical pulses required to initiate an operation. Petitioner asserted that Brown, which is in the same field of retrofitting vending machines, supplied this missing element by explicitly teaching an electronic funds acceptor that predetermines and stores the "exact nature of which coin signals are to be generated" in a memory to "improve the speed of the transaction."
    • Motivation to Combine: A POSITA would combine Brown’s memory storage feature with Breitenbach’s retrofit system to achieve greater efficiency and predictability. Storing the required number of electrical pulses in local memory, as taught by Brown, would eliminate the need for Breitenbach’s device to determine the pulse count for every transaction. This modification would reduce the processing load on the retrofit device's hardware and speed up transactions, a known goal in the art.
    • Expectation of Success: Petitioner argued that a POSITA would have a high expectation of success because the combination involved a simple, routine modification. Breitenbach already disclosed a retrofit device with a processor and memory capable of storing various instructions, making the integration of Brown's teaching—storing a predetermined number of pulses—a straightforward programming task.

Ground 2: Obviousness over Breitenbach, Brown, and Kaspar - Claims 4, 10, 16, and 19-20 are obvious over Breitenbach in view of Brown, further in view of Kaspar.

  • Prior Art Relied Upon: Breitenbach (Patent 9,092,768), Brown (Patent 5,734,150), and Kaspar (Patent 5,036,966).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the Breitenbach/Brown combination from Ground 1 to address dependent claims requiring a "second interface module" and related functions. Petitioner argued that the combination of Breitenbach and Brown did not expressly disclose a second interface module configured to store or sample control signals from the machine's control unit (claims 4, 10, 16) or to count coin pulses and store an output (claims 19-20). Petitioner asserted that Kaspar, which disclosed a retrofit coin mechanism, taught these missing features. Kaspar described storing transaction data (e.g., time, date, price), which Petitioner contended constituted storing control signals that indicate the initiation of the machine’s operation. Further, Kaspar's function of totaling the monetary value of inserted coins was mapped to the limitation of counting electrical pulses generated by the coin switch.
    • Motivation to Combine: A POSITA would be motivated to add Kaspar's data monitoring and storage capabilities to the Breitenbach/Brown system to enable enhanced analytics. Breitenbach itself suggested this functionality by disclosing a DEX connector for data exchange and discussing revenue management and restocking analysis. A POSITA would look to a known technique, like that in Kaspar, for logging operational data and apply it to the Breitenbach/Brown device to yield the predictable result of improved data collection for business intelligence. For example, storing control signals would allow an operator to track sales frequency and inventory levels.
    • Expectation of Success: Petitioner contended that implementation would be routine. The Breitenbach device already included a data port (DEX connector) suitable for interfacing with the machine's control unit. A POSITA would understand that programming the existing processor to sample or store control signals received via this port, as taught by Kaspar, was a simple and predictable task using existing hardware.

4. Relief Requested

  • Petitioner requests institution of an IPR and cancellation of claims 1-20 of the ’608 patent as unpatentable.