PayRange LLC v. Airwallet ApS

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: PayRange LLC (Tennessee)
  • Defendant: Airwallet ApS (Denmark) and Airwallet Inc. (Delaware)
  • Plaintiff’s Counsel: Potter Anderson & Corroon LLP; Wilson Sonsini Goodrich & Rosati
• Case Identification: 1:26-cv-00126, D. Del., 02/03/2026
• Venue Allegations: Venue is alleged to be proper for Airwallet Inc. because it is incorporated in Delaware, and for Airwallet ApS as a foreign entity that may be sued in any judicial district.
• Core Dispute: Plaintiff alleges that Defendant’s mobile payment system for unattended retail machines infringes patents related to retrofitting coin-operated machines for cashless payments and presenting transaction events on a mobile user interface.
• Technical Context: The technology enables legacy, offline equipment such as laundry machines and vending machines to accept payments from a smartphone app without requiring a persistent internet connection at the machine itself.
• Key Procedural History: The complaint notes that the asserted patents have previously survived multiple validity challenges at the Patent Trial and Appeal Board (PTAB). Plaintiff also cites a history of litigation and subsequent licensing deals with other industry competitors, including KioSoft, CSC, WASH, Card Concepts Inc., and Nayax, Ltd. The complaint details extensive pre-suit correspondence between PayRange and Airwallet beginning in June 2024 regarding the alleged infringement.

Case Timeline

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 10,891,608 - "Method and System for an Offline-Payment Operated Machine to Accept Electronic Payments"

The Invention Explained

• Problem Addressed: The patent addresses the technical challenge of enabling traditional, non-networked, coin-operated machines (e.g., vending, laundry) to accept modern electronic payments without costly hardware upgrades or requiring a persistent internet connection at the machine itself ( Compl. ¶41; ’608 Patent, col. 1:29-59).
• The Patented Solution: The invention is a "payment module" that is installed into the legacy machine ( Compl. ¶1; ’608 Patent, fig. 19). This module receives a wireless payment request from a user's mobile device (e.g., via Bluetooth) and, in response, generates a sequence of electrical pulses that it sends to the machine's control unit ( Compl. ¶44; ’608 Patent, abstract). These pulses are designed to emulate the analog signal that the machine's original coin-receiving switch would generate, effectively "fooling" the machine into initiating an operation as if physical coins had been inserted ( Compl. ¶41; ’608 Patent, col. 46:13-19).
• Technical Importance: This approach provided a low-cost method for rapidly upgrading a vast installed base of offline, coin-operated machines to support mobile payments, thereby extending their useful life and commercial viability Compl. ¶41

Key Claims at a Glance

• The complaint asserts at least independent claim 1 and dependent claims 5-7, 11, and 12 Compl. ¶45
• The essential elements of independent claim 1 include:
  • A payment module comprising one or more processors, memory, a short-range wireless transceiver, and a first interface module.
  • Storing, in the memory of the payment module, a number of the electrical pulses that must be received by the control unit to initiate an operation.
  • Receiving a wireless request from a mobile device to initiate a cashless operation.
  • In response to the wireless request: determining a first number of electrical pulses to output; causing the machine to initiate the operation by issuing the first number of electrical pulses to the control unit; and sending operation information to the mobile device.

U.S. Patent No. 11,481,772 - "Method and System for Presenting Representations of Payment Accepting Unit Events"

The Invention Explained

• Problem Addressed: Traditional payment-accepting units featured their own limited, built-in user interfaces (e.g., small screens, buttons) Compl. ¶57 The patent addresses the problem of how to provide a richer, more dynamic, and centralized user experience for discovering and interacting with these machines using a modern smartphone (’772 Patent, col. 2:1-15).
• The Patented Solution: The invention is a method performed on a mobile device. The device’s mobile payment application identifies nearby available payment machines, displays them in a user interface, and allows the user to select a machine and trigger a payment (Compl. ¶56; ’772 Patent, abstract). After establishing a wireless connection and exchanging information to complete the transaction, the mobile app displays an updated user interface that provides a representation of the event, such as a notification that the transaction is complete, aborted, or has failed (Compl. ¶57; ’772 Patent, col. 2:16-33).
• Technical Importance: This solution shifts the primary user interface from the physical machine to the user's mobile device, enabling a more sophisticated and consistent user experience across different types of unattended retail equipment Compl. ¶57

Key Claims at a Glance

• The complaint asserts at least independent claim 11 Compl. ¶59 A disclaimer filed November 22, 2023 disclaimed claims 1-6, 8-10, and 12-20 of the patent Compl. p. 9
• The essential elements of independent claim 11 include:
  • A method at a mobile device comprising:
  • Identifying one or more payment accepting units in proximity.
  • Displaying a user interface configured to show the units and accept user input to select a unit and trigger payment.
  • Establishing a wireless communication path with the selected unit.
  • Enabling user interaction with the interface to complete the transaction.
  • Exchanging information with the unit in conjunction with the transaction.
  • Displaying an updated user interface reflecting the transaction's outcome.

III. The Accused Instrumentality

Product Identification

• The "Accused Products" are identified as the "Airwallet App, Airwallet PRO hardware, and associated backend servers and cloud services" Compl. ¶2

Functionality and Market Context

• The complaint alleges that the Accused Products constitute a mobile payment system for use with coin-operated, unattended retail machines in industries such as laundry and vending Compl. ¶¶1-2 The system is alleged to enable mobile transactions by retrofitting these legacy machines with the Airwallet PRO hardware, which then communicates with the Airwallet App on a user's smartphone Compl. ¶48 Compl. ¶62

IV. Analysis of Infringement Allegations

The complaint references, but does not include, claim chart exhibits that allegedly provide an element-by-element comparison of the Accused Products against the asserted claims Compl. ¶47 Compl. ¶61 The narrative infringement theory for each patent is summarized below.

No probative visual evidence provided in complaint.

• ’608 Patent Infringement Allegations: The complaint's theory of infringement posits that the Airwallet PRO hardware functions as the claimed "payment module" Compl. ¶48 It alleges this hardware is installed in offline payment-operated machines and receives wireless requests from the Airwallet App to initiate a cashless transaction. In response, the hardware is alleged to determine and issue a number of electrical pulses to the machine's control unit, emulating the signal from a coin mechanism and thereby causing the machine to operate. The complaint alleges this conduct constitutes direct infringement of at least claim 1 of the ’608 Patent Compl. ¶45
• ’772 Patent Infringement Allegations: The infringement theory for the ’772 Patent focuses on the functionality of the Airwallet App on a mobile device Compl. ¶62 The complaint alleges that the app performs the patented method by identifying nearby machines equipped with Airwallet PRO hardware, displaying them in a user interface for selection, accepting user input to trigger payment, establishing a wireless communication path to complete the transaction, and subsequently updating the user interface to provide the user with the status of that transaction. This sequence of functions is alleged to directly infringe at least claim 11 of the ’772 Patent Compl. ¶59
• Identified Points of Contention:
  • Scope Questions: For the ’608 Patent, a potential point of contention may be the scope of the term "storing, in the memory of the payment module." The complaint highlights this limitation as a key point of novelty during patent prosecution and subsequent PTAB proceedings Compl. ¶40 Compl. ¶42 The analysis may turn on whether the accused Airwallet PRO hardware stores the pulse count locally in the manner described by the patent, or if it determines or receives this information dynamically from a server in a way that may fall outside the claim's scope.
  • Technical Questions: For the ’772 Patent, a key technical question may surround the "exchanging information... in conjunction with the transaction" step of claim 11. The dispute could focus on the specific nature and timing of the data exchanged between the Airwallet App and the hardware. The analysis may raise the question of whether the accused system's communications constitute the specific type of information exchange required by the claim, as interpreted in light of the patent's specification.

V. Key Claim Terms for Construction

• The Term: "storing, in the memory of the payment module, a number of the electrical pulses" (’608 Patent, claim 1)

  • Context and Importance: This limitation was identified by the patent examiner and the PTAB as a feature distinguishing the invention from prior art Compl. ¶40 Compl. ¶42 Practitioners may focus on this term because its construction will be critical to determining whether the accused hardware, which may retrieve or calculate pulse information dynamically, meets this "storing" requirement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent specification describes a "memory 760" within the adapter module capable of storing various programs and data, which could support an argument that any form of local data retention, even temporary, satisfies the "storing" limitation (’608 Patent, col. 8:1-2; ’608 Patent, fig. 20).
    • Evidence for a Narrower Interpretation: The specification describes a "training mode" where the module learns and determines a "predefined signal sequence" to emulate, suggesting a more permanent or pre-configured value is stored (’608 Patent, col. 46:1-4). This could support an argument that "storing" requires holding a pre-set value, as distinct from dynamically receiving it from a server for each transaction.

• The Term: "exchanging information with the available payment accepting unit via the one or more radio transceivers, in conjunction with the transaction" (’772 Patent, claim 11)

  • Context and Importance: The definition of this term will be central to whether the accused system's communication protocol infringes. The dispute will likely focus on what type and sequence of data transfer constitutes "exchanging information" that is "in conjunction with" the transaction itself.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language is broad and could be interpreted to cover any bi-directional communication related to the transaction, such as the mobile app sending a "start" command and the payment module returning a "complete" status (’772 Patent, col. 2:27-30).
    • Evidence for a Narrower Interpretation: Figures in the patent depict detailed, multi-step communication flows, including sending vend details, updating balances, and receiving confirmations (’772 Patent, fig. 8D). This could support a narrower construction requiring a more substantive and structured data exchange about the transaction's specific parameters, rather than simple command-and-response signals.

VI. Other Allegations

• Indirect Infringement: The complaint alleges active inducement of infringement, stating that Airwallet encourages its customers to use the Accused Products in an infringing manner through "installation and configuration instructions," "user guides," "marketing and sales materials," and "technical support" Compl. ¶48 Compl. ¶62 It also alleges contributory infringement, asserting the Accused Products are a material part of the invention and are especially made or adapted for infringing use Compl. ¶49
• Willful Infringement: Willfulness is alleged based on Airwallet's purported knowledge of the patents-in-suit since at least June 28, 2024, the date of PayRange’s initial notice letter Compl. ¶46 Compl. ¶60 The complaint details a multi-month history of correspondence between the parties regarding the infringement allegations prior to the lawsuit's filing Compl. ¶¶12-21

VII. Analyst’s Conclusion: Key Questions for the Case

This case presents several key questions for the court, revolving around both technical implementation and claim scope.

• A core issue will be one of technical implementation: Does the accused Airwallet PRO hardware "store" the required electrical pulse information in its local memory as specified by claim 1 of the ’608 Patent, or does its architecture rely on a dynamic, non-storing method that may place it outside the claim's literal scope? The extensive prosecution and PTAB history cited in the complaint suggests this limitation will be a focal point of the dispute.
• A second central question will be one of functional scope: Does the sequence of operations and information flow within the Airwallet App meet the specific method steps of claim 11 of the ’772 Patent? The analysis will likely scrutinize whether the accused app’s user interface and communication protocol perform the functions of "triggering payment" and "exchanging information" in a manner consistent with the patent's claims as construed by the court.