Alliance Laundry Systems LLC v. PayRange LLC

1. Case Identification

• Case #: PGR2025-00028
• Patent #: 11,972,423
• 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 ’423 patent discloses a system and method where a mobile device is used to conduct transactions with payment-accepting units, such as vending machines. The system involves the mobile device identifying nearby units, displaying them in a user interface, establishing a wireless connection, and enabling payment and transaction-related notifications.

3. Grounds for Unpatentability

Ground 1: Claims 1-6, 8, 10, and 12-20 are anticipated by Low under 35 U.S.C. §102

• Prior Art Relied Upon: Low (Patent 10,210,501).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Low discloses every limitation of the challenged claims. Independent claim 1, representative of the other independent claims, recites a method performed on a mobile device for transacting with payment-accepting units. Petitioner asserted that Low teaches a "user device" (e.g., a smartphone) with a "purchase application" that serves as a convenient interface for transactions with a "vending machine." Low allegedly discloses identifying proximal payment units via machine identifiers, displaying a user interface with selectable machines, establishing a short-range wireless communication path (e.g., Bluetooth), enabling user interaction to complete a transaction, exchanging information (e.g., payment approval), and displaying an updated user interface (e.g., adjusted inventory) after the transaction. Petitioner further mapped limitations of the dependent claims to specific disclosures in Low, such as displaying cross-promotional messages (claim 2) and sending transaction data to a server (claim 4).

Ground 2: Claim 11 is obvious over Low in view of Arora, Freeny, and Casey under 35 U.S.C. §103

• 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 contended that claim 11, which depends from claim 1, adds user interface features that were well-known in the art and would have been obvious to combine with the system of Low. Specifically, Petitioner argued Low fails to explicitly disclose three UI features recited in claim 11. Arora was cited for teaching a UI with a "visual representation of the available payment accepting unit" (e.g., icons of vending machines). Freeny was cited for teaching "an indication of a prepaid balance," such as an approved credit amount that can be checked by the user. Finally, Casey was cited for teaching "an affordance that when slid, indicates the initiation of the transaction" and is slid in response to a user swipe, disclosing a common "slide-to-confirm" payment mechanism.
  • Motivation to Combine: A POSITA would combine these known UI elements from Arora, Freeny, and Casey into the Low system to make the user interface more convenient, intuitive, and informative. Providing visual icons, balance information, and a familiar swipe-to-pay gesture were all predictable improvements to the user experience for a mobile payment application.
  • Expectation of Success: The combination involved implementing known graphical user interface elements into a software application. A POSITA would have had a high expectation of success, as these were routine and predictable software modifications.

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

• Prior Art Relied Upon: N/A (relies on legal precedent and a prior PTAB Final Written Decision).

• Core Argument for this Ground:

  • Prior Art Mapping: Petitioner presented two main arguments for patent ineligibility. First, it argued that Patent Owner should be collaterally estopped from asserting the patentability of most claims. Petitioner contended that claims 1-6, 8-10, 13-14, and 15-19 of the ’423 patent are materially identical or broader than claims of a related patent (Patent 10,891,614) that the Board previously found invalid under §101 in a Final Written Decision (FWD) in case PGR2021-00093.
  • Key Aspects: Second, arguing in the alternative, Petitioner asserted the claims are directed to the abstract idea of "identifying a merchant and enabling completion of a purchase." Petitioner argued this is a fundamental economic practice that can be performed in the human mind. The claims then merely implement this abstract idea using generic and conventional components (e.g., a smartphone, display, radio transceivers, server) without adding an "inventive concept." The recited steps and components, taken individually and as a whole, simply append well-understood, routine activities to the abstract idea, failing to transform it into a patent-eligible application.

• Additional Grounds: Petitioner asserted that claims 7 and 9 are obvious under §103 over Low in view of Arora. This combination was argued to teach adding an accelerometer to detect when a user walks away to cancel the connection (claim 7) and receiving a targeted coupon based on the transaction (claim 9).

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial would be inappropriate. Under the Fintiv factors, denial is not warranted because the parallel district court litigation is in a very early stage with no trial date set, and Petitioner stipulated that it would not pursue the same invalidity grounds in the district court if the PGR is instituted.
• Under 35 U.S.C. §325(d), Petitioner contended denial is improper because the primary prior art references (Low, Arora, Freeny, Casey) and the §101 arguments were not substantively considered by the Examiner during prosecution. The references were submitted as part of a large Information Disclosure Statement (IDS) that was signed off by the Examiner without substantive comment shortly before allowance, and the only rejection on the merits was for non-statutory double patenting.

5. Relief Requested

• Petitioner requests the institution of a Post-Grant Review and the cancellation of claims 1-20 of the ’423 patent as unpatentable.