Alliance Laundry Systems LLC v. PayRange LLC

1. Case Identification

• Case #: PGR2025-00027
• Patent #: 11,966,920
• Filed: January 17, 2025
• Petitioner(s): Alliance Laundry Systems, LLC
• Patent Owner(s): PayRange LLC
• Challenged Claims: 1-20

2. Patent Overview

• Title: Method and System for Presenting Representations of Payment Accepting Unit Events
• Brief Description: The ’920 patent discloses methods for using a mobile device to interact with payment-accepting units, such as vending machines. The system involves the mobile device identifying nearby units, displaying them in a user interface, and facilitating a wireless transaction.

3. Grounds for Unpatentability

Ground 1: Obviousness of Claims 1-10 and 12-20 over Low in view of Arora and Freeny

• Prior Art Relied Upon: Low (Patent 10,210,501), Arora (Patent 9,898,884), and Freeny (Patent 8,958,846).
• 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 nearly all limitations of the independent claims. However, Petitioner contended Low does not explicitly disclose two user interface features: a "visual representation of the available payment accepting unit" and a "visual representation of... an indication of a balance." Arora, which relates to personal vending systems, was alleged to supply the first missing element by teaching a user interface that displays icons of available vending machines. Freeny, which discloses proximity authorization systems, was alleged to supply the second by teaching the display of an "approved credit amount" or balance to the user.
  • Motivation to Combine: Petitioner asserted a person of ordinary skill in the art (POSITA) would combine Low with Arora to provide a more convenient and intuitive user interface, as visual icons are a well-known method for representing selectable options. A POSITA would further combine the system with Freeny’s teachings to provide users with essential financial information (their available balance) before a transaction, allowing for more informed purchasing decisions. These modifications were presented as predictable improvements to the user experience.
  • Expectation of Success: Petitioner contended a POSITA would have a high expectation of success in integrating these known user interface elements from analogous systems, as it involved routine software modification to achieve a predictable result.
  • Key Aspects: For dependent claim 7, which adds using an accelerometer to cancel a transaction if the user walks away, Petitioner argued Arora explicitly teaches using an accelerometer to determine a user’s location relative to a vending machine.

Ground 2: Obviousness of Claim 11 over Low in view of Arora, 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: This ground specifically targeted claim 11, which depends from claim 1 and adds the limitation that the user input is a "swipe that causes the affordance to be slid." Petitioner argued that while the combination of Low, Arora, and Freeny teaches a user interacting with an affordance (e.g., a payment button), it does not explicitly disclose a swipe gesture. Casey, which describes motion-based payment confirmation, was asserted to remedy this by disclosing a user interface with a slide bar that a user can swipe to confirm a payment.
  • Motivation to Combine: Petitioner argued that a swipe-to-confirm gesture was a well-known, conventional user interface element at the time of the invention. A POSITA would be motivated to incorporate Casey’s swipeable affordance into the user interface of the base combination as a simple substitution for a button press, representing a predictable design choice from a finite number of known interaction methods.
  • Expectation of Success: Implementing a standard swipe gesture in a mobile application was a routine task for a POSITA and would be expected to function as intended.

Ground 3: Claims 1-20 are Unpatentable under 35 U.S.C. §101

• Prior Art Relied Upon: N/A.
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued the challenged claims are directed to the patent-ineligible abstract idea of "identifying a merchant and enabling completion of a purchase." Petitioner asserted that the claims merely implement this longstanding commercial practice using generic and conventional technology—a mobile device, an application, radio transceivers, and a generic user interface—without adding an inventive concept. The limitations were argued to simply recite the abstract idea itself on a generic computer, which is insufficient to confer patent eligibility.
  • Key Aspects: Petitioner heavily relied on a collateral estoppel argument. It asserted that the Board, in a Final Written Decision (FWD) for PGR2021-00093, previously found claims of a related patent (the ’614 patent) to be invalid under §101. Petitioner contended that the challenged claims of the ’920 patent are "materially identical" or even broader than the invalidated ’614 patent claims, and therefore the Board’s prior findings should apply directly.

4. Arguments Regarding Discretionary Denial

• Fintiv Factors: Petitioner argued against discretionary denial under Fintiv, asserting that a parallel district court case in Delaware is at a very early stage with no trial date set and that a stay is routinely granted in that venue pending PTAB review. Petitioner also stipulated that, if the Post-Grant Review (PGR) is instituted, it will not pursue the same invalidity grounds or any that could have reasonably been raised in the district court action.
• §325(d) Factors: Petitioner argued that denial under §325(d) is unwarranted because the primary prior art references asserted in the petition (Low, Arora, Freeny, and Casey) were not substantively evaluated by the Examiner during prosecution. They were only listed within a large Information Disclosure Statement (IDS) and were not the basis for any rejection. Furthermore, Petitioner contended the arguments presented in the petition are new and distinct from the double-patenting rejection made during prosecution.

5. Relief Requested

• Petitioner requests institution of a PGR and cancellation of claims 1-20 of the ’920 patent as unpatentable.