Iscan2d Tech LLC v. Apple Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: iScan2D Technologies, LLC (Connecticut)
  • Defendant: Apple Inc. (California)
  • Plaintiff’s Counsel: DNL Zito
• Case Identification: 1:25-cv-01794, W.D. Tex., 02/02/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Apple maintains a regular and established business presence in the district, including corporate offices and multiple retail stores.
• Core Dispute: Plaintiff alleges that Defendant’s Apple Watch and iPhone products infringe patents related to using scannable visual media to establish a wireless connection between devices for data transfer.
• Technical Context: The technology concerns methods for pairing electronic devices, such as a wearable health monitor and a smartphone, by scanning a displayed visual code to simplify the exchange of data and credentials.
• Key Procedural History: The complaint notes that U.S. Patent No. 12,230,394 is a continuation of the application that issued as U.S. Patent No. 11,664,123, indicating they share a common specification. The complaint also asserts the patents are "pioneering" and have been cited as relevant prior art in over 200 subsequent U.S. Patent Applications, including five assigned to Apple.

Case Timeline

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

U.S. Patent No. 11,664,123

• Patent Identification: U.S. Patent No. 11,664,123, “Barcode Generation and Implementation Method and System for Processing Information,” issued May 30, 2023.

The Invention Explained

• Problem Addressed: The patent’s background section identifies the difficulty of connecting mobile devices to other hardware, like exercise equipment, due to a lack of universal standards for communication protocols and connectors. This makes it “near impossible for fitness equipment manufacturers to be able to provide a universal ‘plug in’ solution” ’123 Patent, col. 2:25-31 The patent also notes the high cost and maintenance burden of hardwired data systems in fitness facilities (col. 2:32-41).
• The Patented Solution: The invention describes a system where a primary device (e.g., a wearable) generates and displays a scannable visual code that contains wireless pairing information. A second device (e.g., a smartphone) scans this code to initiate a wireless connection and transfer data, such as activity or biometric information ’123 Patent, Abstract Fig. 1A This process bypasses the need for physical cables or complex manual pairing procedures (col. 4:6-25).
• Technical Importance: This approach provided a device-agnostic method for data exchange at a time when proprietary connectors and incompatible wireless protocols were common, simplifying the user experience for tracking health and fitness data ’123 Patent, col. 2:19-31

Key Claims at a Glance

• The complaint asserts independent claims 1 and 11, along with dependent claims 2-5, 9, 10, 12-14, 19, and 20 Compl. ¶48
• Independent Claim 1 (Apparatus) is directed to a wearable activity device that comprises:
  • A display device.
  • An accelerometer or bio-metric sensor.
  • Wireless communication circuitry.
  • A processor configured to obtain wireless pairing information, generate a "color coded digital scannable media" responsive to that information, display the media, establish a wireless link with a mobile device after it scans the media, and then communicate activity/biometric data to the mobile device.
• Independent Claim 11 (Method) recites the steps for establishing a communications link that mirror the functions of the apparatus in Claim 1, including generating, displaying, and scanning the "color coded digital scannable media."

U.S. Patent No. 12,230,394

• Patent Identification: U.S. Patent No. 12230394, “Barcode Generation and Implementation Method and System for Processing Information,” issued February 18, 2025.

The Invention Explained

• Problem Addressed: As a continuation of the ’123 Patent, this patent addresses the same interoperability challenges between mobile devices and external hardware like fitness equipment ’394 Patent, col. 2:19-31
• The Patented Solution: The invention claimed in the ’394 Patent focuses on the role of the mobile device. It describes a mobile device using its camera to optically detect a "color coded digital scannable media" displayed by an external device. The mobile device processor generates an optical scanning interface, obtains the wireless pairing information from the scanned media, establishes a connection, and then receives and displays data from the external device ’394 Patent, Claim 1 This method centralizes the initiation and control of the pairing process within the mobile device ’394 Patent, col. 4:51-60
• Technical Importance: The invention leverages the now-ubiquitous camera and processing power of smartphones to enable connections with external devices, which may be less sophisticated and only need the capability to display a visual code ’394 Patent, col. 6:35-53

Key Claims at a Glance

• The complaint asserts independent claims 1 and 11, along with dependent claims 2, 3, 5-8, 12-14, and 16-18 Compl. ¶65
• Independent Claim 1 (Apparatus) is directed to a mobile device that comprises:
  • A camera sensor, processor, display, and communication circuitry.
  • Memory with instructions for the processor to generate an optical scanning interface, detect and optically obtain "wireless pairing information" from a "color coded digital scannable media" displayed on an external device, process the information, establish a wireless link, and receive and display data from the external device.
• Independent Claim 11 (System) recites a system comprising both the wearable activity tracking device (which generates and displays the scannable media) and the mobile device (which scans it and establishes the link), with elements corresponding to those in Claim 1.

III. The Accused Instrumentality

• Product Identification: The complaint identifies various models of the Apple Watch (including Series 8 and newer, and SE models) as the "Apple Watch Accused Instrumentalities" and various models of the Apple iPhone (including iPhone 15 and newer) as the "Apple iPhone Accused Instrumentalities" Compl. ¶44
• Functionality and Market Context: The complaint alleges that these products infringe when used together, for example, when pairing an Apple Watch to an iPhone Compl. ¶¶ 30, 44 The complaint does not provide technical details or visual evidence of the accused pairing process itself. It asserts that this functionality is a key feature of Apple's ecosystem, but provides no specific data on market positioning beyond naming the products Compl. ¶¶ 28-30
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references, but does not include, claim chart exhibits detailing its infringement theories Compl. ¶¶ 51, 68 The narrative allegations suggest the following infringement theories:

• ’123 Patent Infringement Allegations (vs. Apple Watch): The complaint alleges that the Apple Watch infringes claims of the ’123 Patent Compl. ¶48 The theory appears to be that the Apple Watch, a "wearable activity device," generates and shows a dynamic, animated graphic on its display during the pairing process. Plaintiff alleges this graphic is the claimed "color coded digital scannable media" containing "wireless pairing information." An iPhone, acting as the "mobile device," is alleged to "scan" this media with its camera, decode the pairing information, and establish a wireless link with the Watch, which then communicates activity data to the iPhone.

• ’394 Patent Infringement Allegations (vs. Apple iPhone): The complaint alleges that the Apple iPhone infringes claims of the ’394 Patent Compl. ¶65 The corresponding theory is that the iPhone, as the "mobile device," uses its camera and an "optical scanning user interface" to detect the animated graphic displayed by the Apple Watch. The iPhone allegedly "optically obtain[s]" the "wireless pairing information" from this graphic, processes it to establish a wireless link, and then receives and displays data from the Watch.

Identified Points of Contention:

• Scope Questions: A central issue may be whether the animated, non-static particle cloud graphic used in Apple's pairing process falls within the scope of the term "color coded digital scannable media." The patents' titles and specifications heavily reference "barcodes," which may support a narrower construction limited to static, structured codes. Conversely, language in the claims referring to "augmented reality marker" and "representation of non-human readable information using colored pixels" may support a broader interpretation that could read on Apple's animated graphic ’123 Patent, Claim 9
• Technical Questions: A key factual dispute will likely be how Apple's pairing process technically operates. The complaint's theory requires that the visual graphic itself encodes and transmits the "wireless pairing information." A question for the court will be whether the iPhone's camera "scans" and "decodes" this information from the graphic, or if the graphic is merely a visual confirmation target while the actual pairing credentials are exchanged through a separate, non-optical channel, such as a proximate Bluetooth or NFC broadcast.

V. Key Claim Terms for Construction

• The Term: "color coded digital scannable media"

• Context and Importance: This term is the lynchpin of the infringement case. Its construction will determine whether the animated graphic displayed by the Apple Watch during pairing can be considered an infringing structure. Practitioners may focus on this term because the patent's specification is grounded in barcode technology, while the accused functionality is a dynamic animation.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: Dependent claims explicitly broaden the media beyond traditional barcodes to include "a representation of non-human readable information using colored pixels, an augmented reality marker, an augmented reality image, and an augmented reality code" ’123 Patent, Claim 9 The specification also discusses using color to "enhance the amount of data capture" ’394 Patent, col. 36:18-21
  • Evidence for a Narrower Interpretation: The patents are titled "Barcode Generation..." and the specification extensively describes systems for generating and processing barcodes ’123 Patent, Abstract; col. 4:6-25 The process of determining barcode "size and characteristics" based on a "data string" suggests a structured, decodable format, which may not describe a transient animation ’394 Patent, col. 4:40-49

• The Term: "wireless pairing information"

• Context and Importance: The infringement theory requires that this specific information be contained within the "scannable media." The definition is critical to determining if the accused system meets this limitation or if it exchanges such information through a different channel.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent does not provide a restrictive definition. The specification offers an example of a barcode linked to a "wifi MAC address," suggesting the information could be a basic network identifier used to facilitate a connection ’394 Patent, col. 36:44-46
  • Evidence for a Narrower Interpretation: A defendant could argue this term requires the substantive credentials for establishing a secure wireless session (e.g., cryptographic keys) to be encoded in the visual media. If the visual media only provides a simple device identifier or serves as a visual trigger, while the substantive pairing occurs over a separate broadcast, this element might not be met.

VI. Other Allegations

• Indirect Infringement: The complaint does not include separate counts for indirect infringement. It focuses on allegations of direct infringement by Apple through its making, using, selling, and internal testing of the accused products (Compl. ¶¶ 48-49, 65-66).
• Willful Infringement: The complaint does not contain an explicit allegation of willful infringement. It alleges that Apple has knowledge of its infringement "at least as of the service of the present complaint," which lays the groundwork for potential post-filing willfulness and a claim for enhanced damages under 35 U.S.C. § 284 Compl. ¶¶ 47, 64

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

1. A core issue will be one of definitional scope: Can the claim term "color coded digital scannable media", which is rooted in the patents’ disclosure of barcodes and QR codes, be construed broadly enough to read on the dynamic, animated particle-cloud graphic used in Apple's device pairing process?

2. A second central issue will be one of technical and evidentiary proof: Does the animated graphic in Apple’s pairing system actually encode and optically transmit the claimed "wireless pairing information", or is it a purely visual guide while the essential pairing data is exchanged through a separate, non-optical wireless broadcast? The outcome will depend on technical evidence revealed during discovery.

3. A third question will relate to patent validity: Given the state of the art in device pairing at the time of invention, will the asserted claims survive anticipated challenges under 35 U.S.C. § 101 as an abstract idea or § 103 as obvious, particularly in light of the complaint's own assertions that the technology solves "long standing problems" in a "non-conventional" way Compl. ¶¶ 28-29?