DCT

1:26-cv-00126

PayRange LLC v. Airwallet ApS

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Amended Complaint
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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:26-cv-00126, D. Del., 08/28/2026
  • Venue Allegations: Venue is alleged to be proper for Airwallet Inc. due to its incorporation in Delaware. For Airwallet ApS, a Danish company, venue is asserted on the basis that it is a foreign entity and has purposefully directed infringing activities toward the United States and the District of Delaware through its U.S. subsidiary.
  • Core Dispute: Plaintiff alleges that Defendant's mobile payment platform for unattended laundry machines infringes four U.S. patents related to retrofitting offline, coin-operated machines to accept electronic payments.
  • Technical Context: The technology at issue enables legacy, unattended machines like laundry equipment, which traditionally only accept coins, to be upgraded to accept payments from a user's smartphone via a retrofitted hardware module.
  • Key Procedural History: The complaint highlights PayRange's extensive patent licensing and enforcement history. It notes that PayRange's patents have survived multiple validity challenges at the Patent Trial and Appeal Board (PTAB). The complaint also states that PayRange has successfully licensed its portfolio to major industry players, including a settlement with competitor KioSoft valued at over $62 million, and licensing agreements with WASH, Card Concepts Inc. (CCI), Nayax, and Electrolux. PayRange alleges it provided Defendant with detailed notice of infringement beginning in June 2024, but Defendant refused to take a license. On November 22, 2023, PayRange filed a disclaimer for claims 1-6, 8-10, and 12-20 of the '772 Patent.

Case Timeline

Date Event
2013-12-18 Priority Date for '608, '772, '473, and '919 Patents
2018-01-23 U.S. Patent No. 9,875,473 ('473 Patent) Issues
2021-01-12 U.S. Patent No. 10,891,608 ('608 Patent) Issues
2022-10-25 U.S. Patent No. 11,481,772 ('772 Patent) Issues
2023-11-22 PayRange files disclaimer for claims of the '772 Patent
2024-01-31 PayRange announces settlement with KioSoft
2024-04-01 PayRange resolves dispute with KioSoft's customer CSC
2024-05-01 PayRange reaches licensing deal with WASH
2024-06-28 PayRange sends initial notice letter to Airwallet
2024-07-05 Airwallet acknowledges receipt of notice letter
2024-12-01 PayRange resolves dispute with Card Concepts Inc. (CCI)
2025-03-01 PayRange resolves dispute with Nayax, Ltd.
2025-05-27 U.S. Patent No. 12,314,919 ('919 Patent) Issues
2025-09-17 Airwallet provides non-infringement arguments to PayRange
2025-10-07 PayRange sends rebuttal and infringement analysis to Airwallet
2025-12-01 PayRange acquires KioSoft
2026-08-01 PayRange signs licensing agreement with Electrolux
2026-08-28 Complaint Filed

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"

  • Patent Identification: U.S. Patent No. 10891608, "Method and System for an Offline-Payment Operated Machine to Accept Electronic Payments," issued January 12, 2021 Compl. ¶37

The Invention Explained

  • Problem Addressed: The patent describes that traditional unattended machines, such as vending or laundry machines, were designed to operate with physical currency and lack native support for modern electronic or mobile payment methods Compl. ¶74 '608 Patent, col. 1:31-60
  • The Patented Solution: The invention is a payment module designed to be retrofitted into an existing "offline" payment-operated machine '608 Patent, abstract The module contains a short-range wireless transceiver (e.g., Bluetooth) to communicate with a user's mobile device '608 Patent, abstract Upon receiving a wireless request from the mobile device to start a transaction, the module generates and sends a specific number of electrical pulses to the machine's control unit '608 Patent, abstract These pulses are configured to emulate the analog signal that the machine's coin-receiving switch would normally generate, effectively "fooling" the machine into initiating an operation as if coins had been inserted '608 Patent, col. 11:4-14
  • Technical Importance: This technology provided a cost-effective way to upgrade the large installed base of legacy offline machines to accept mobile payments without requiring a complete redesign of the machine's internal control systems or a persistent network connection Compl. ¶44 Compl. ¶74

Key Claims at a Glance

  • The complaint asserts independent claim 1 and dependent claims 5-7, 11-13, and 17-19 Compl. ¶48
  • Independent Claim 1 recites a payment module comprising:
    • One or more processors, memory, a short-range wireless transceiver, and a first interface module.
    • The memory stores instructions for:
      • Storing a required number of electrical pulses to initiate a machine operation.
      • Receiving a wireless request from a mobile device for a cashless operation.
      • In response to the request: determining a first number of electrical pulses to output, causing the machine to initiate the operation by issuing those pulses, and sending operation information back to the mobile device.

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

  • Patent Identification: U.S. Patent No. 11481772, "Method and System for Presenting Representations of Payment Accepting Unit Events," issued October 25, 2022 Compl. ¶38

The Invention Explained

  • Problem Addressed: Conventional user interfaces for selecting and paying for services on unattended machines were typically located on the machines themselves and were limited in the information they could display, offering a poor user experience when using a mobile device Compl. ¶60
  • The Patented Solution: The '772 Patent describes a method performed on a mobile device that improves the user interface for mobile payments. The mobile device identifies nearby, available payment-accepting units, displays them to the user, and accepts user input to select a unit and trigger payment '772 Patent, abstract After a transaction is initiated, the mobile device obtains a notification from the payment module indicating the event's outcome (e.g., completion, abortion, or failure) and presents this information to the user '772 Patent, col. 2:11-32
  • Technical Importance: This approach shifted the primary user interface from the limited display on the machine to the more capable and user-friendly screen of the smartphone, which the complaint alleges was an unconventional solution at the time Compl. ¶60

Key Claims at a Glance

  • The complaint asserts infringement of claim 11 Compl. ¶62 On November 22, 2023, PayRange disclaimed claims 1-6, 8-10, and 12-20, but not independent claim 7 or dependent claim 11 Compl. ¶38
  • Independent Claim 7 (prerequisite for Claim 11) recites a method at a mobile device comprising:
    • Identifying an available payment accepting unit.
    • Displaying a visual indication of the unit.
    • Accepting user input to select the unit and trigger payment.
  • Dependent Claim 11 adds that the user interface of the mobile payment application includes:
    • A visual representation of the available payment accepting unit.
    • An indication of a prepaid balance.
    • An affordance that when slid, indicates the initiation of the transaction.

U.S. Patent No. 9,875,473 - "Method and System For Retrofitting an Offline-Payment Operated Machine to Accept Electronic Payments"

  • Patent Identification: U.S. Patent No. 9,875,473, "Method and System For Retrofitting an Offline-Payment Operated Machine to Accept Electronic Payments," issued January 23, 2018 Compl. ¶39
  • Technology Synopsis: The '473 Patent addresses the problem of upgrading legacy coin-operated machines for mobile payments in a cost-effective manner Compl. ¶74 The patented solution is a retrofit payment module that interfaces with a machine's existing control circuitry and emulates the analog signals of a coin switch, enabling mobile-initiated transactions without modifying the machine's core hardware or operational logic Compl. ¶75
  • Asserted Claims: The complaint asserts at least claims 1, 4-6, 9, 10, 14-17, and 19, with claim 1 being independent Compl. ¶76
  • Accused Features: The complaint alleges that the Airwallet PRO payment modules, when installed in offline machines, communicate with the Airwallet app via Bluetooth to initiate cashless operations by emulating the machine's native coin-switch signals Compl. ¶¶78-82 A diagram from Airwallet's installation materials is included to illustrate this system architecture Compl. ¶78, Figure 1

U.S. Patent No. 12,314,919 - "Systems and Methods for Determining Electric Pulses to Provide to an Unattended Machine Based on Remotely-Configured Options"

  • Patent Identification: U.S. Patent No. 12,314,919, "Systems and Methods for Determining Electric Pulses to Provide to an Unattended Machine Based on Remotely-Configured Options," issued May 27, 2025 Compl. ¶40
  • Technology Synopsis: The '919 Patent addresses the challenge of efficiently configuring pulse-providing devices for offline machines Compl. ¶91 The invention allows an offline machine, via a coupled pulse-providing device, to accept operation options (e.g., different cycles and prices) that are configured on a remote server and communicated to the device, which then generates the corresponding electrical pulses to initiate the selected operation Compl. ¶91 Compl. ¶95
  • Asserted Claims: The complaint asserts at least claims 1-3, 5-10, 12-14, and 18-20, with claim 1 being independent Compl. ¶92
  • Accused Features: The complaint alleges that the Airwallet system allows users to select from remotely configured operation options (e.g., "Cold wash," "Warm wash") displayed in the Airwallet app, which are retrieved from Airwallet's servers Compl. ¶95 The Accused Products then allegedly receive a wireless request and output the corresponding number of electrical pulses to the machine Compl. ¶96 A screenshot from an Airwallet video is provided to show the user interface for selecting these options Compl. ¶96, Figure 2

III. The Accused Instrumentality

Product Identification

  • The Accused Products are identified as the Airwallet laundry payment platform, which includes the Airwallet App, Airwallet PRO hardware (e.g., PRO200, 310, 330, 340, and 400), Airwallet Anton Kiosk, and associated backend servers and cloud services Compl. ¶5

Functionality and Market Context

  • The Accused Products are alleged to form a system that enables mobile payments on unattended laundry machines Compl. ¶¶1-2 The system is comprised of an "Airwallet PRO" hardware module installed in a machine and a corresponding "Airwallet App" on a user's smartphone Compl. ¶5 The complaint alleges these components communicate via Bluetooth Compl. ¶78
  • The complaint alleges that after a user selects a machine and a remotely-configured operation option (e.g., a specific wash cycle) in the app, the Airwallet PRO module receives a wireless request and outputs a corresponding number of electrical pulses to the machine's control unit to initiate the operation Compl. ¶¶95-96 This functionality is depicted in a system architecture diagram provided in the complaint Compl. ¶78, Figure 1
  • The complaint alleges that Airwallet has sold, supported, and promoted its laundry payment platform to customers in the United States Compl. ¶2

IV. Analysis of Infringement Allegations

'608 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
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 of the offline payment operating machine; The Accused Products allegedly store pulse-based activation settings, including pulse timing, pulse repetition values, and relay configurations needed to initiate machine operations. ¶80; ¶81 col. 47:12-18
receiving a wireless request via the short-range wireless transceiver from a respective mobile device of the one or more mobile devices to initiate a cashless operation of the offline-payment operated machine; The Accused Products allegedly receive a wireless request from a user's mobile device via Bluetooth after the user selects and pays for a laundry cycle through the Airwallet mobile application. ¶82 col. 47:19-24
determining a first number of electrical pulses to output via the first interface module to the control unit of the offline payment-operated machine; In response to the wireless request, the Accused Products allegedly determine a corresponding number of electrical pulses to output to the laundry-machine control unit. ¶82 col. 47:27-31
causing the offline payment-operated machine to initiate the requested cashless operation by issuing the first number of electrical pulses to the control unit via the first interface module; The Accused Products allegedly initiate the requested cashless operation by outputting the determined number of electrical pulses to the laundry-machine control unit. ¶82 col. 47:32-36
and sending operation information corresponding to the initiated operation of the offline payment-operated machine to the respective mobile device via the short-range wireless transceiver. The complaint does not provide sufficient detail for analysis of this element. col. 47:37-42

'772 Patent Infringement Allegations

Claim Element (from Dependent Claim 11) Alleged Infringing Functionality Complaint Citation Patent Citation
The method of claim 7, wherein the user interface of the mobile payment application, after establishing the wireless communication path, includes: a visual representation of the available payment accepting unit; The Airwallet mobile app allegedly identifies and presents a list of available laundry machines to the user. This is illustrated in a screenshot from an Airwallet video. ¶95; ¶96 col. 15:5-15
an indication of a prepaid balance; The complaint alleges that before users request products, the mobile payment application shows the prepaid balance. ¶60 col. 15:1-4
and an affordance that when slid, indicates the initiation of the transaction. The complaint alleges infringement of this claim, and notes that the PTAB found this element to be unconventional and not disclosed in the prior art, but does not specify how the accused app meets this limitation. ¶61; ¶62 col. 16:1-2

Identified Points of Contention

  • Scope Questions: For the '608 Patent, a potential point of contention is whether the electrical signals generated by the Airwallet PRO module technically "emulate an analog signal" from a physical coin switch, as required by the claim language. For the '772 Patent, a central question will be one of scope: does the accused Airwallet App contain a user interface element that is "slid" to initiate payment, or does it use a different, non-infringing mechanism (e.g., a button tap)?
  • Evidentiary Questions: The complaint's allegations for the '608 patent do not explicitly detail how the accused system sends "operation information corresponding to the initiated operation" back to the mobile device. The evidence for this specific claim element may become a point of dispute.

V. Key Claim Terms for Construction

  • Term: "emulating an analog signal" (from '608 Patent, claim 1)

    • Context and Importance: The core of the '608 Patent's invention is retrofitting a legacy machine by tricking its control unit. The infringement case may turn on whether the digital pulses generated by the Airwallet PRO device are technically considered to be "emulating" the specific "analog signal" from a physical coin switch, or if they are functionally different.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: Language in the specification, referenced by the complaint, focuses on "reproducing the signal behavior expected by legacy control units," which may support an interpretation based on functional equivalence rather than requiring a precise electrical waveform copy Compl. ¶75
      • Evidence for a Narrower Interpretation: The claim explicitly recites "emulating an analog signal generated by the coin receiving switch" '608 Patent, col. 47:3-6 This could support a narrower construction requiring the generated signal to have characteristics closely matching the specific analog electrical properties of a physical switch, not just any digital pulse that achieves the same outcome.

  • Term: "an affordance that when slid, indicates the initiation of the transaction" (from '772 Patent, claim 11)

    • Context and Importance: This term describes a specific user interface action. Practitioners may focus on this term because the complaint highlights a PTAB decision that found this element to be unconventional and a key aspect of the claim Compl. ¶61 Infringement of claim 11 will likely depend on whether the accused Airwallet App has a UI element that a user "slides" to confirm payment.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: A plaintiff might argue that the term "slid" should be interpreted broadly to cover any continuous directional gesture on a touchscreen that initiates payment, not just a literal on-screen slider object.
      • Evidence for a Narrower Interpretation: The plain language "an affordance that when slid" suggests a specific type of UI control, distinct from a tap or a button press. The patent figures associated with this functionality in related patents depict a clear "swipe-to-pay" motion on a visual element '608 Patent, Fig. 8C, which may support a narrower construction requiring a similar, specific UI paradigm.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges active inducement of infringement, asserting that Airwallet provides customers with installation instructions, user guides, and marketing materials that encourage and direct the use of the Accused Products in an infringing manner Compl. ¶51 Compl. ¶65 Compl. ¶83 Compl. ¶98 It also alleges contributory infringement, stating the Accused Products are components especially made or adapted for use in an infringing system and are not a staple article of commerce Compl. ¶52 Compl. ¶84 Compl. ¶99
  • Willful Infringement: The complaint alleges willful infringement based on pre-suit knowledge. It states that PayRange sent Airwallet a notice letter with detailed infringement allegations on June 28, 2024, and that the parties had repeated discussions, but Airwallet refused to take a license and continued its allegedly infringing conduct Compl. ¶1 Compl. ¶17 Compl. ¶49 Compl. ¶63 Compl. ¶77 Compl. ¶93

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

  • A central technical question will be one of functional equivalence: do the electrical pulses generated by the Airwallet PRO module, which are based on remotely-configured options, perform the same function in substantially the same way to achieve the same result as "emulating an analog signal" from a physical coin switch as described in the '608 and '473 patents?
  • A core issue for the '772 patent will be one of definitional scope: can the specific claim language "an affordance that when slid" be construed to read on the user interface mechanism for initiating payment in the accused Airwallet App, or is there a dispositive difference in the user action required?
  • A key question for damages will be willfulness: given the complaint's detailed allegations of pre-suit notice, prior successful litigation and licensing of the patents-in-suit, and PTAB validations, the court will need to determine whether Defendant's alleged continued infringement was objectively reckless, which could expose it to enhanced damages.