CheckWizard LLC v. Northern Trust Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: CheckWizard LLC (New Mexico)
  • Defendant: Northern Trust Corporation (Delaware)
  • Plaintiff's Counsel: Rabicoff Law LLC
• Case Identification: 7:25-cv-00514, W.D. Tex., 02/27/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant maintains an established place of business in the district and has committed acts of patent infringement there.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to methods for a mobile device to construct and transmit a composite "image entity" for display within a virtual network.
• Technical Context: The technology concerns the architecture of mobile image sharing, focusing on combining images with associated data into a single, structured digital object for efficient network communication.
• Key Procedural History: The patent-in-suit claims priority to an application filed in 2004, a period the complaint characterizes as an early stage of development for mobile devices with integrated cameras and for mobile operating systems.

Case Timeline

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

U.S. Patent No. 10,140,514 - Capturing and sharing images with mobile device users including for a limited duration of time

Issued November 27, 2018 (the "'514 Patent")

The Invention Explained

• Problem Addressed: The patent asserts that prior art mobile communication was inefficiently centered on voice and text, treating digital images as static, isolated files separate from any associated data (e.g., location, audio, related text) Compl. ¶¶10-11 '514 Patent, col. 1:18-29 This approach allegedly created inefficiencies in processing, storage, and network bandwidth, as multiple discrete files had to be handled for what was contextually a single piece of information, limiting the utility of images in communication '514 Patent, col. 1:51-57
• The Patented Solution: The invention proposes creating a unified, composite digital object called an "image entity" '514 Patent, abstract This entity is constructed by combining an acquired image with an "image profile," which associates the image with collateral information like audio, location, text, and relationships to other images '514 Patent, col. 7:4-13 This "unitized" object can then be processed and transmitted as a single, efficient packet of data across a network, enabling the creation of dynamic "image networks" (Compl. ¶13; Compl. ¶14; Compl. ¶15, Compl. ¶¶col. 7:43-47).
• Technical Importance: The claimed architecture sought to improve the technical functioning of mobile devices by replacing the paradigm of transmitting separate, discrete files with a method for constructing and transmitting a single, composite digital object for network-based display Compl. ¶13

Key Claims at a Glance

• The complaint asserts independent Claim 21 Compl. ¶19
• Claim 21 is a method claim with the following essential elements:
  • Acquiring an image using an interface to one or more cameras of the mobile device;
  • Constructing an image entity using the acquired image, one or more other images, and an image profile of the acquired image;
  • Transmitting the image entity to one or more servers to update and/or refresh display of the constructed image entity;
  • Wherein the constructed image entity is accessible to recognized users of a virtual network via client devices in communication with the servers.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products in its main body Compl. ¶¶1-28 It refers to "Exemplary Defendant Products" that are allegedly identified in claim charts in an "Exhibit 2" Compl. ¶23 Compl. ¶25 However, Exhibit 2 was not filed with the complaint document provided for this analysis.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the functionality or market context of the accused products.

IV. Analysis of Infringement Allegations

The complaint alleges direct infringement of at least Claim 21 of the '514 Patent Compl. ¶19 Compl. ¶23 It states that claim charts demonstrating this infringement are contained in Exhibit 2, which was not provided Compl. ¶25 The narrative infringement theory alleges that the accused products perform the specific sequence of Claim 21 Compl. ¶19 This includes a mobile device acquiring a camera image, constructing a composite "image entity" by combining that image with other images and an image profile, and transmitting the entity to servers, which then use it to update or refresh displays for users of a virtual network Compl. ¶19 No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: A central question may be whether the accused products "construct an image entity" that meets the patent's specific definition of a "unitized" digital object where an image and its profile are combined into a single construct '514 Patent, col. 7:14-18 The dispute may focus on whether the accused functionality creates something more than a conventional transmission of an image file alongside separate metadata.
• Technical Questions: The analysis may turn on what technical function in the accused products satisfies the "update and/or refresh display" limitation. It raises the question of whether the accused system performs an active, server-driven display update as described in the patent '514 Patent, col. 15:31-35, or if it merely makes an image available for passive client-side retrieval. The lack of detail about the accused products in the complaint prevents a more specific analysis of this point.

V. Key Claim Terms for Construction

• The Term: "image entity"

  • Context and Importance: This term is the central concept of the invention. Its construction will determine whether the accused system's data structures fall within the scope of the claims. Practitioners may focus on whether this term requires a single, integrated data object or can cover an image file transmitted with associated, but structurally separate, metadata.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term could be argued to encompass any digital representation of an image combined with its associated information for transmission.
    • Evidence for a Narrower Interpretation: The specification describes an "image entity" as a "distinct and identifiable digital entity" with "embedded multimedia capabilities, location, security and executable functions that are inherently associated with the image" '514 Patent, col. 7:14-18 It is also described as a "unitized" construct that functions as a "supersized packet of digital data" '514 Patent, col. 7:43-45 This language may support a narrower construction requiring a specific, self-contained data architecture.

• The Term: "image profile"

  • Context and Importance: This term defines the non-image data that is combined with an image to form the "image entity". Its scope will be critical to the "constructing" step of Claim 21.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term could be interpreted to mean any metadata associated with an image.
    • Evidence for a Narrower Interpretation: The specification provides a detailed, non-exhaustive list of what an image profile associates with an image, including "audio, voice, text, speech, location, time data, handwriting, encryption/decryption, compression/decompression, description, behavior, function and relationships to other images/objects" '514 Patent, col. 7:7-13 This detailed list may be used to argue for a construction that requires more than simple metadata like a timestamp or filename.

• The Term: "update and/or refresh display"

  • Context and Importance: This term describes the action performed by the servers after receiving the "image entity". The infringement analysis depends on whether the accused servers perform an action that meets this definition.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: This could be argued to cover any action that results in a new or changed image appearing on a user's device.
    • Evidence for a Narrower Interpretation: The specification describes a system where images are "dynamically rendered, delivered, modified and updated to deliver the best screen image," and the screen image "gets updated at the desired periodicity" '514 Patent, col. 15:31-35 This suggests an active, potentially continuous or periodic, server-driven process, which could support a narrower construction than merely making a static image available for download.

VI. Other Allegations

The complaint does not contain allegations of indirect or willful infringement.

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

• A core issue will be one of definitional scope: can the term "image entity", described in the patent as a "unitized" and "distinct" digital object, be construed to cover the data structures used by the accused products, or do those products handle images and their associated data in a more conventional, structurally separate manner?
• A key evidentiary question will be one of factual correspondence: given that the complaint provides no specific details on the accused products, a central issue will be whether the Plaintiff can produce evidence that demonstrates the accused functionality performs each step of Claim 21, particularly the "constructing an image entity" and server-side "update and/or refresh display" elements as defined by the patent.