PTAB

PGR2025-00028

Alliance Laundry Systems, LLC v. PayRange LLC.

Title: Method and System for Presenting Representations of Payment Accepting Unit Events
Brief Description: The ’423 patent discloses a method and system where a mobile device communicates with a payment-accepting unit (e.g., a vending or laundry machine). The system involves identifying nearby units, displaying a user interface on the mobile device to select a unit, establishing a wireless communication path, and conducting a transaction.

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. Low teaches a system for making electronic payments to non-internet-connected devices, such as vending machines, using a consumer's mobile device. Petitioner asserted that Low’s mobile "user device" running a "purchase application" meets the limitations of a mobile device executing a payment application. Low’s system identifies nearby machines using a "machine identifier," displays a menu for user selection, establishes a short-range wireless link (e.g., Bluetooth), exchanges information (like purchase approval), and updates the UI (e.g., adjusts inventory levels), thereby mapping to the core steps of independent claims 1, 13, and 15.
- Key Aspects: The argument relies on a direct, element-by-element mapping of Low's system for mobile payments to vending machines onto the challenged claims, asserting that Low teaches the entire claimed method and system.

Prior Art Relied Upon: Low (Patent 10,210,501), Arora (Patent 9,898,884).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Low provides the base system for mobile vending transactions. For claim 7, which adds using an accelerometer to cancel the wireless connection when a user walks away, Petitioner asserted Arora teaches this. Arora discloses using an accelerometer for "inertial guidance" to determine a user's location and movement relative to a vending machine. For claim 9, which adds receiving a targeted coupon, Arora explicitly teaches communicating an "incentive or promotion, such as a coupon" to the user's device.
- Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Low with Arora to add useful, known features. Adding accelerometer-based disconnect functionality would conserve device resources, a known goal in mobile device design. Adding coupons is a well-known business practice to incentivize transactions and would have been an obvious modification to Low’s system.
- Expectation of Success: A POSITA would have a reasonable expectation of success in integrating Arora’s known accelerometer and coupon features into Low's mobile payment platform, as it involved applying known techniques to improve a similar system in a predictable way.

Prior Art Relied Upon: Low (Patent 10,210,501), Arora (Patent 9,898,884), Freeny (Patent 8,958,846), Casey (Patent 8,255,323).
Core Argument for this Ground:
- Prior Art Mapping: This ground addresses the specific UI elements of claim 11. Petitioner argued a POSITA seeking to improve the UI of Low's system would combine known UI elements from the prior art. Arora teaches displaying a "visual representation" of the available vending machines (e.g., icons). Freeny teaches displaying an "indication of a prepaid balance" (an "approved credit amount"). Casey teaches an "affordance that when slid, indicates the initiation of the transaction" (a "slide bar" to confirm payment).
- Motivation to Combine: A POSITA would be motivated to combine these features into Low's system to create a more convenient, intuitive, and user-friendly interface. Providing visual icons, balance information, and a swipe-to-pay gesture were all known methods for improving usability and would have been obvious enhancements.
- Expectation of Success: The combination was merely an aggregation of known, predictable UI elements. A POSITA would have reasonably expected success in implementing these software-based UI features into Low's mobile application.

Core Argument for this Ground:
- Prior Art Mapping: Petitioner advanced two primary arguments. First, it argued that the Patent Owner should be collaterally estopped from arguing the patentability of claims 1-6, 8-10, 13-14, and 15-19. This is based on a Final Written Decision (FWD) in PGR2021-00093, where the Board found materially identical claims of a related patent (the '614 patent) invalid under §101. Second, even without estoppel, Petitioner argued the claims are directed to the patent-ineligible abstract idea of a fundamental economic practice: identifying a merchant and completing a commercial transaction.
- Key Aspects: The claims merely recite implementing this abstract idea using generic and conventional components (a mobile device, processors, a user interface) that perform their well-understood functions without providing an inventive concept or technical improvement. The collateral estoppel argument, based on a prior Board decision against the same patent family, is a central pillar of this ground.

Petitioner argued that discretionary denial would be inappropriate under multiple frameworks.
Fintiv Factors: Denial is not warranted because the parallel Delaware litigation is in a very early stage with no trial date set, and the Board's FWD would issue well before any potential trial. Petitioner also stipulated that, if review is instituted, it will not pursue the same grounds or any that could have reasonably been raised in the petition in the district court.
§325(d) Factors: Denial is not warranted because the key prior art references (Low, Arora, Freeny, Casey) and the §101 arguments were never substantively considered during prosecution. The references were merely listed in a large Information Disclosure Statement (IDS) that the Examiner signed off on without analysis, and the only rejection was for non-statutory double patenting.
General Plastic Factors: These factors do not apply as the ’423 patent has not been the subject of a prior post-grant or inter partes review proceeding.

Petitioner requested institution of a Post-Grant Review and cancellation of claims 1-20 of the ’423 patent as unpatentable under 35 U.S.C. §§ 101, 102, and 103.