DCT
1:26-cv-00634
PayRange LLC v. Alliance Laundry Systems LLC
Key Events
Complaint
Table of Contents
complaint Intelligence
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: PayRange LLC (Tennessee)
- Defendant: Alliance Laundry Systems LLC (Delaware)
- Plaintiff's Counsel: Potter Anderson & Corroon LLP
- Case Identification: 1:26-cv-00634, D. Del., 06/01/2026
- Venue Allegations: Venue is alleged to be proper as Defendant is a Delaware limited liability company that resides in the District. The complaint further notes that by previously filing a declaratory judgment action in the same district, Defendant has conceded that venue is proper.
- Core Dispute: Plaintiff alleges that Defendant's mobile payment applications and associated systems for laundry machines infringe two U.S. patents related to mobile payment technology for unattended retail machines.
- Technical Context: The technology enables users to pay for services at unattended machines, such as laundromat washers and dryers, using a smartphone application that communicates with the machine via an installed hardware module.
- Key Procedural History: The complaint alleges an extensive history of licensing and enforcement of its patent portfolio, including settlements with KioSoft, WASH, and CCI. It also notes that Defendant Alliance refused a license, filed a declaratory judgment action against Plaintiff, and initiated four validity challenges at the USPTO (two Post-Grant Reviews and two Inter Partes Reviews) after receiving notice.
Case Timeline
| Date | Event |
|---|---|
| 2013-12-18 | Priority Date for '299 and '767 Patents (Provisional App. No. 61/917,936) |
| 2024-03-14 | PayRange sends letter to Alliance providing notice of infringement |
| 2024-04-25 | Alliance responds to PayRange's letter |
| 2024-05-17 | PayRange responds to Alliance's letter |
| 2024-06-12 | PayRange sends another letter to Alliance |
| 2024-06-20 | Alliance files declaratory judgment action against PayRange |
| 2024-08-02 | Notice of Allowance issued for '299 Patent |
| 2024-08-10 | Notice of Allowance issued for '767 Patent |
| 2024-10-01 | '299 Patent Issued |
| 2025-01-17 | Alliance files two Post-Grant Review (PGR) petitions |
| 2025-02-03 | Alliance files Inter Partes Review (IPR) petition |
| 2025-02-18 | '767 Patent Issued |
| 2025-04-29 | Alliance files a fourth inter partes review petition |
| 2025-09-04 | Alliance announces launch of "Scan-Pay-Wash" product |
| 2025-12-01 | PayRange acquires KioSoft (approximate date) |
| 2026-05-29 | PayRange sends letter to Alliance alleging infringement of '299 and '767 Patents |
| 2026-06-01 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,106,299 - Method and System for Presenting Representations of Payment Accepting Unit Events, issued October 1, 2024 ('299 Patent)
The Invention Explained
- Problem Addressed: The patent addresses the challenge of enabling modern, mobile-based cashless payments on the vast installed base of legacy unattended retail machines (e.g., vending machines, laundry machines) that were originally designed to accept only physical currency or cards and often lack persistent network connectivity Compl. ¶1 '299 Patent, col. 1:49-2:18
- The Patented Solution: The invention provides a system where a hardware "adapter module" is installed in the unattended machine. A user's mobile device, running a specific application, establishes a short-range wireless connection with the module to initiate a transaction. The application communicates with a remote server over a long-range network (e.g., cellular) to secure an "authorization grant," which is then passed to the machine to enable a transaction. The system architecture is designed to manage the complexities of this multi-party communication, including a user interface that presents the machine's status and facilitates payment (Compl. ¶31; Compl. ¶32; Compl. ¶33, Compl. ¶abstract; '299 Patent, Compl. ¶Fig. 5).
- Technical Importance: This approach allowed operators to upgrade existing coin-operated machines for mobile payments without costly replacement or extensive hardware modification, bridging the gap between legacy hardware and modern payment ecosystems Compl. ¶4
Key Claims at a Glance
- The complaint asserts independent claim 1 and dependent claims 2-3, 5-8, 10, and 12-20 Compl. ¶34
- Independent Claim 1 recites a method performed at a mobile device with the following key steps:
- identifying one or more payment accepting units (e.g., laundry machines) available to accept payment from a mobile application;
- displaying a user interface on the mobile device configured to show a visual indication of the unit(s) and accept a user's selection of an available unit;
- establishing a wireless communication path including the mobile device, a server, and the selected payment accepting unit;
- enabling user interaction with the user interface to complete a transaction, which causes an authorization grant to pass from the server to the available unit;
- the user interface including a visual representation of the unit, a balance indication, and an "affordance" that indicates completion of the transaction;
- exchanging information with the available payment accepting unit via radio transceivers; and
- displaying an updated user interface on the mobile device after exchanging the information.
U.S. Patent No. 12,229,767 - Method and System for Presenting Representations of Payment Accepting Unit Events, issued February 18, 2025 ('767 Patent)
The Invention Explained
- Problem Addressed: As a continuation of the same patent family, the '767 Patent addresses the same technical problem as the '299 Patent: enabling mobile payments on legacy unattended machines Compl. ¶52 '767 Patent, col. 1:1-2:18
- The Patented Solution: The '767 Patent claims a similar solution but with a slightly different focus in the asserted claims. It describes a two-step user interaction model: first, the user selects a specific unattended machine, and second, separately triggers payment. A key claimed feature is that the authorization grant from the server causes a credit to be displayed at the machine itself, enabling the user to select a product or service directly on the machine, after which an updated interface is returned to the mobile device Compl. ¶53 '767 Patent, abstract '767 Patent, col. 47:33-45
- Technical Importance: This invention provides a user experience that more closely mimics using cash (i.e., "crediting" the machine first, then making a selection on the machine's own interface), while still leveraging a secure, server-based mobile payment architecture Compl. ¶55
Key Claims at a Glance
- The complaint asserts independent claims 1 and 16, and dependent claims 2-6, 10-13, and 17-20 Compl. ¶56
- Independent Claim 1 recites a method of executing payment events with the following key steps:
- displaying a user interface on a mobile device configured to show a visual indication of one or more payment accepting units and accept user input to (i) receive selection of a unit and (ii) trigger payment for a transaction with that unit;
- establishing a wireless connection between the mobile device and the selected unit;
- enabling user interaction to complete the transaction, causing an authorization grant to pass to the unit;
- the authorization grant causing a credit to be displayed at the unit, enabling user selection of a product/service on the unit;
- exchanging information with the unit via radio transceivers; and
- displaying an updated user interface on the mobile device in response to receiving the information.
III. The Accused Instrumentality
Product Identification
- The "Accused Products" are identified as the "Speed Queen" and "Huebsch" mobile applications, their associated backend and cloud servers, and the "Scan-Pay-Wash" product Compl. ¶16
Functionality and Market Context
- The complaint alleges that the Speed Queen and Huebsch apps allow users to pay for laundry services at facilities with compatible washers and dryers Compl. ¶35 The apps, available on Android and iPhone with over 100,000 downloads each, identify available machines by numerical identifiers (e.g., "Washer 0051") Compl. ¶36 Compl. ¶59 A user selects a machine and initiates payment through the app's interface Compl. ¶36 The complaint alleges this action causes an authorization grant to be transmitted from Alliance's server to the selected washer or dryer, which then starts the laundry cycle Compl. ¶38 Compl. ¶61 The apps then display an "in use" screen showing the machine's status and remaining time Compl. ¶38 Compl. ¶61
No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
'299 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| identifying one or more payment accepting units that are available to accept payment from a mobile payment application... | The Speed Queen and Huebsch apps identify available washers and dryers at a laundry facility and display them to the user with numerical identifiers. | ¶36 | col. 47:1-8 |
| displaying a user interface of the mobile payment application... the user interface being configured to display a visual indication of the one or more payment accepting units and accept user input selecting an available payment accepting unit... | Both apps display a user interface showing the available units and accept user input to select a specific machine for a transaction. | ¶36 | col. 47:9-14 |
| establishing via the one or more radio transceivers a wireless communication path including the mobile device, a server, and the available payment accepting unit... | After a user selects a machine, the apps establish a wireless path connecting the mobile device, Alliance's cloud servers, and the selected machine via cellular or Wi-Fi. | ¶37 | col. 47:15-19 |
| enabling user interaction with the user interface of the mobile payment application to complete a transaction... wherein completing the transaction causes an authorization grant to pass from the server to the available payment accepting unit... | Both apps enable user interaction with the user interface to complete a transaction. This causes an authorization grant to pass from Alliance's server to the selected machine. | ¶38 | col. 47:20-27 |
| ...wherein the user interface includes a visual representation of the available payment accepting unit, an indication of a balance, and an affordance that, in response to a user input, indicates completion of the transaction; | The app's transaction interface includes a visual representation of the selected machine (e.g., "Washer 0051"), an indication of balance due, and a "Pay" button. | ¶38 | col. 47:28-32 |
| exchanging information with the available payment accepting unit... and after exchanging the information, displaying, on the display, an updated user interface... | After the transaction, the apps exchange information with the machine and display an updated "in use" screen showing the machine's status and remaining cycle time. | ¶38 | col. 47:33-39 |
- Identified Points of Contention:
- Scope Question: A potential dispute may arise over whether the "wireless communication path including the mobile device, a server, and the available payment accepting unit" is met by the accused system's architecture. The court may need to determine if the alleged path, which routes through public cellular/Wi-Fi networks to a cloud server, satisfies the claim's requirement for a path that "includes" all three components in a specific, functional relationship.
- Technical Question: The complaint alleges a "Pay" button meets the claim limitation of an "affordance that, in response to a user input, indicates completion of the transaction." A point of contention may be whether a standard button press performs the same function as the "affordance" described in the patent, which may suggest a more specific user interface interaction.
'767 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| displaying a user interface... configured to display a visual indication... and accept user input to (i) receive selection... and (ii) trigger payment... | The apps display available washers/dryers with identifiers, allow a user to select a specific machine, and provide a "Pay" button to trigger payment. | ¶59 | col. 47:1-17 |
| establishing via the one or more radio transceivers a wireless connection involving the mobile device and the available payment accepting unit... | After a user selects a machine, the apps establish a wireless connection via cellular or Wi-Fi involving the mobile device and the selected machine. | ¶60 | col. 47:18-22 |
| ...enabling user interaction... to complete the transaction, wherein completing the transaction causes an authorization grant to pass to the available payment accepting unit... | Upon user interaction with the "Pay" button, an authorization grant is passed to the selected machine. | ¶61 | col. 47:23-28 |
| ...wherein the authorization grant causes a credit to be displayed at the available payment accepting unit enabling user selection of a product or service provided by the available payment accepting unit; | The complaint alleges on information and belief that the authorization grant causes a credit to be displayed at the selected washer or dryer, enabling user selection of a laundry cycle on the machine. | ¶61 | col. 47:29-34 |
| exchanging information with the available payment accepting unit... and in response to receiving the information, displaying... an updated user interface... | The apps exchange information with the machine and display an updated "in use" screen showing status and cycle time. | ¶61 | col. 47:35-42 |
- Identified Points of Contention:
- Evidentiary Question: A central factual question for the '767 Patent will be whether the accused system actually performs the step where an "authorization grant causes a credit to be displayed at the available payment accepting unit." The complaint alleges this "upon information and belief" Compl. ¶61, suggesting that discovery will be required to determine if the machine's own physical display shows a credit value before the user makes a final cycle selection on the machine itself.
- Technical Question: The claim requires a two-step user input: "(i) receive selection" of a unit and "(ii) trigger payment." The court will need to analyze whether the user flow in the accused apps separates these two actions in a manner that maps to the claim language, or if they are combined in a single user action.
V. Key Claim Terms for Construction
For the '299 and '767 Patents:
The Term: "payment accepting unit"
Context and Importance: The patents-in-suit distinguish themselves from prior art that allegedly relates to peer-to-peer or traditional retail payments by focusing on "unattended" machines Compl. ¶31 Compl. ¶52 The construction of "payment accepting unit" will be critical to establishing the scope of the invention and whether it is limited to the specific unattended machine environments described.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims themselves do not explicitly state the unit must be "unattended," only that it is a "payment operated machine[] that accept[s] payment for dispensing of products and/or services" '299 Patent, cl. 1 '767 Patent, cl. 16, which could be argued to cover a wide range of devices.
- Evidence for a Narrower Interpretation: The specification repeatedly provides examples of unattended machines like "vending machines, parking meters, toll booths, laundromat washers and dryers, arcade games, kiosks," etc. '299 Patent, col. 1:60-65 '767 Patent, col. 9:31-36 Parties may argue this context limits the claim term to such unattended environments.
The Term: "authorization grant"
Context and Importance: This term is central to the claimed security architecture. The claims require this "grant" to pass from a server to the payment unit. Its definition is key to distinguishing the invention from systems where a mobile device might directly authorize a payment or where the transaction is authorized in a different manner. Practitioners may focus on this term because the specific nature and path of this data packet is a core element of the infringement theory.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims broadly recite it as something that "pass[es] from the server to the available payment accepting unit" to enable a transaction '299 Patent, cl. 1, which could potentially cover any form of server-based credit or payment token.
- Evidence for a Narrower Interpretation: The specification describes the "Authorization Grant Token ('AuthGrant')" as a specific encrypted message passed from the server via the mobile device to the adapter module, with the mobile device being unable to decrypt it Compl. ¶¶32-33 '299 Patent, col. 11:43-52 This suggests a specific, secured data object, potentially narrowing the term's scope from a generic "authorization."
VI. Other Allegations
- Indirect Infringement: The complaint alleges active inducement of infringement against Alliance for encouraging and providing instructional materials to its business partners and end-users on how to use the Accused Products in an infringing manner Compl. ¶40 Compl. ¶62 It also alleges contributory infringement, stating the Accused Products are a material part of the invention and are especially adapted for use in an infringing manner Compl. ¶41 Compl. ¶63
- Willful Infringement: Willfulness is alleged based on both pre-suit and post-suit knowledge. The complaint alleges Alliance had knowledge of the patents-in-suit via a letter sent on May 29, 2026 Compl. ¶39 Compl. ¶57, and knowledge of the broader patent portfolio from a letter sent March 14, 2024 Compl. ¶39 Compl. ¶57 The complaint asserts Alliance willfully blinded itself to the portfolio and consciously chose to proceed with infringing activities despite a high likelihood of infringement Compl. ¶39 Compl. ¶57
VII. Analyst's Conclusion: Key Questions for the Case
This dispute appears to center on three key questions for the court:
A question of claim scope and construction: Can the claim elements describing the multi-party communication path and the user interface "affordance" be construed to read on the specific software architecture and user interface design of Alliance's Speed Queen and Huebsch apps, or is there a fundamental mismatch in technical operation?
An evidentiary question of infringement: For the '767 patent specifically, what evidence will show that Alliance's system "causes a credit to be displayed at the available payment accepting unit," as required by the claim? The "information and belief" pleading on this point suggests it will be a focal point of discovery.
A question of intent: Given the complaint's detailed allegations of PayRange's extensive industry licensing, prior litigation, and specific notice letters sent to Alliance, a central issue will be whether Alliance's decision to continue its conduct without a license rises to the level of willful infringement, potentially exposing it to enhanced damages.
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