Case 1:24-cv-00279-MN Document 1 Filed 03/04/24 Page 1 of 30 PageID #: 259
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`C.A. No. ________________
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`JURY TRIAL DEMANDED
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`)))))))))
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`PAYRANGE INC.,
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`Plaintiff,
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`v.
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`CSC SERVICEWORKS, INC.,
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`Defendant.
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`COMPLAINT FOR PATENT INFRINGEMENT
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`1.
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`Plaintiff PayRange Inc. (“PayRange”) hereby alleges as follows for Complaint
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`against Defendant CSC ServiceWorks, Inc. (“CSC”). As set forth herein, CSC has been
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`infringing and continues to infringe PayRange’s patents, namely, United States Patent Nos.
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`10,719,833; 10,891,614; and 11,488,174 (the “’833 Patent,” “’614 Patent,” and “’174 Patent”
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`respectively or, collectively the “patents-in-suit”) and continues to do so through the present
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`date.
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`FACTUAL BACKGROUND
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`2.
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`This case is about two companies: PayRange, which pioneered a mobile payment
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`system for unattended retail machines through its patented technology and, CSC, which strung
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`PayRange along with promises of a partnership all the while copying PayRange’s technology. In
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`doing so, CSC willfully infringed PayRange’s patent rights.
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`3.
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`As background, PayRange’s acclaimed technology enables its customers to
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`upgrade a coin-operated unattended retail machine into a state-of-the-art mobile payment
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`solution with a small module, called “BluKey.” PayRange’s mobile app communicates with
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`BluKey to enable mobile transactions. The United States Patent & Trademark Office
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`(“USPTO”) awarded PayRange a portfolio of patents for its innovations. Several of PayRange’s
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`patents have been challenged with the Patent Trademark Appeals Board (“PTAB”) in part due to
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`other related litigation. Claims from each challenged patent have been confirmed patentable,
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`thus further exemplifying the strength of the PayRange’s patent portfolio.
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`4.
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`In 2013, a private entity firm (Pamplona Capital Management, LLP) acquired and
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`merged two companies: Coinmach Service Corporation and AIR-serv Group. From this merger,
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`CSC was formed as the preeminent owner, nationwide, of coin-operated laundry machines,
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`which are leased to apartment complexes and hotels for use by occupants. The Ontario
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`Teacher’s Pension Plan and Neurberger Berman private equity firm subsequently acquired a
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`significant stake in CSC.
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`5.
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`On information and belief, CSC witnessed PayRange’s emergence and devised a
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`scheme to transform itself from a laundry machine operator into a profitable technology
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`company. On information and belief, CSC began in 2016 by fraudulently notifying thousands of
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`CSC customers that CSC was authorized to immediately begin charging a 9.75% administrative
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`fee. CSC’s assertion was false and this resulted in a class action lawsuit. Undeterred, CSC
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`sought to accelerate its transformation by deceiving PayRange into disclosing its patented
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`technology under the guise that CSC was evaluating PayRange’s technology for a partnership.
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`In truth, there was never to be a partnership. CSC was systematically copying PayRange’s
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`patented technology to develop its own copycat system (named CSC Go).
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`6.
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`On information and belief, CSC initiated its scheme to deceive PayRange in
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`October 2016. At an initial meeting, CSC’s Executive Vice President (Taylor Doggett)
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`commented that PayRange’s “timing is impeccable, as we are looking for ways in payment
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`systems to take coins out of the room cost effectively …” (emphasis added). CSC clearly
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`recognized the need to rapidly upgrade its payment systems to increase its profitability and
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`valuation. To do so, CSC needed PayRange’s patented technology, but, did not want to pay
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`PayRange for at least two reasons: (1) CSC wanted to reposition itself as a technology company
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`with current and future investors and (2) paying a license fee would reduce CSC’s profitability.
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`7.
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`Impressed with PayRange’s technology, CSC scheduled a face-to-face meeting in
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`early 2017. On information and belief, even though CSC was working to build its own solution,
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`CSC continued engaging PayRange under the pretense of “evaluating” its technology. At the
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`meeting, PayRange made a detailed technical presentation. The following annotated meeting
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`slide emphasizes PayRange’s “patented technology”:
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`8.
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`CSC therefore knew that PayRange’s solution was covered by one or more
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`patents. Further, on information and belief, CSC knew that copying PayRange’s products would
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`constitute patent infringement. To the extent that CSC did not have pre-suit knowledge of any
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`patent-in-suit, it was because CSC willfully blinded itself to such knowledge. On information
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`and belief, CSC willfully avoided looking at PayRange patents, despite knowing (or reasonably
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`suspecting) that PayRange had relevant patents. PayRange’s presentation also provided
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`information regarding its “connected room” device, named “BluKey Connect”:
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`9.
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`CSC expressed keen interest in PayRange’s connected room. CSC then requested
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`sample BluKey devices “for immediate testing.” (emphasis added). PayRange shipped three
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`devices to CSC at no cost for CSC to evaluate. The invoice included with the order references
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`the Operator Terms of Service on the PayRange website.
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`10.
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`The website referenced on the invoice has clear notification for the PayRange
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`patents, along with the terms of service which confirm PayRange’s ownership of intellectual
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`property rights.
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`11.
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`On information and belief, CSC opened the packaging to retrieve the devices
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`upon receipt. The packaging of the devices has clear notification for the patents plainly visible
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`from the exterior, and CSC likely opened the package from the back side with the notification to
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`remove the device from the packaging.
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`12.
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`Upon information and belief, after CSC removed the devices from the packaging,
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`the devices were registered the PayRange website. Again, the website has patent notifications.
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`The user creating the CSC operator account must accept the terms and conditions of the
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`PayRange service prior to account sign-in. The terms and conditions state that the PayRange
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`service is protected by intellectual property laws. To the extent that CSC did not have pre-suit
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`knowledge of any patent-in-suit, CSC’s behavior (including its failure to ever explain non-
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`infringement or invalidity) is evidence of willful blindness.
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`13.
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`CSC’s account (No. A11746) was created on the PayRange platform and is
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`registered to Mr. Taylor Doggett, who PayRange was communicating with regarding the
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`evaluation of the product and who had previously commented in October 2016 that PayRange’s
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`“timing is impeccable, as we are looking for ways in payment systems to take coins out of the
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`room cost effectively …” (emphasis added).
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`14.
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`Once signed in, CSC registered the device on the PayRange Manage web portal.
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`The PayRange BluKey device serial number and PIN were required for registration, which are
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`found on a label on the back of the device. The label contains a patent notification for a patent
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`related to the patents-in-suit (the device picture below is the same model sent to CSC, but not the
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`actual serial number).
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`On information and belief, CSC looked at the device label to obtain the serial number and PIN.
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`Further, CSC must have looked at the label because the devices were registered to CSC’s
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`account between April 19, 2017 and May 5, 2017.
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`Once registered, CSC performed 32 test transactions using the evaluation devices they received,
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`unpacked, and registered.
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`15.
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`Impressed with the testing results, CSC scheduled an in-depth private meeting at
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`the June 2017 “Clean Show,” which is a major trade show for laundry route operators. CSC’s
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`senior management, including its then Chief Operations Officer (Phil Emma) and then Executive
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`Vice President (Taylor Doggett) attended the show. After the meeting, Mr. Emma wrote that he
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`was “impressed with the progress that you and the team have made connecting laundry into
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`PayRange.” (emphasis added). CSC encouraged PayRange to provide even more detailed
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`technical information.
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`16.
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`Believing that a deal with CSC was imminent, PayRange provided another
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`detailed presentation which, in the executive summary section, noted that “[a] partnership with
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`PayRange will include appropriate licenses of our extensive intellectual property portfolio
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`which can help protect CSC against claims of infringement by others as you will be using our
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`intellectual property and technology.” (emphasis added). PayRange’s presentation went on to
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`provide the following overview of its system architecture:
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`17.
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`PayRange’s technical presentation also identified its then issued patents, including
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`patents related to the patents-in-suit:
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`18.
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`The ’833 patent is a continuation of application No. 14/335,762, filed on Jul. 18,
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`2014, now Pat. No. 9,547,859, which is a continuation of application No. 14/214,644, filed on
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`Mar. 14, 2014, now Pat. No. 8,856,045, which is a continuation-in-part of application No.
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`29/477,025, filed on Dec. 18, 2013, now Pat. No. Des. 755,183. These related patents were
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`expressly identified to CSC. To the extent that CSC did not expressly have knowledge of the
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`’833 patent by virtue of the above presentation, CSC willfully blinded itself to such knowledge
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`by failing to investigate patent families which PayRange identified as relevant.
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`19.
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`The ’614 patent is a continuation of application No. 14/458,199, filed on Aug. 12,
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`2014, now Pat. No. 9,659,296, which is a continuation-in-part of application No. 14/456,683,
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`filed on Aug. 11, 2014, now Pat. No. 9,256,873, which is a continuation of application No.
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`14/335,762, filed on Jul. 18, 2014, now Pat. No. 9,547,859, which is a continuation of
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`application No. 14/214, 644 , filed on Mar. 14 , 2014 , now Pat. No. 8,856,045, and a
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`continuation-in-part of application No. 29/477, 025, filed on Dec. 18, 2013, now Pat. No. Des.
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`755,183. These related patents were expressly identified to CSC. To the extent that CSC did not
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`expressly have knowledge of the ’614 patent by virtue of the above presentation, CSC willfully
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`blinded itself to such knowledge by failing to investigate patent families which PayRange
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`identified as relevant.
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`20.
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`The ’174 patent is a Continuation of application No. 15 / 406,492, filed on Jan.
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`13, 2017, now Pat. No. 10,719,833, which is a continuation of application No. 14 / 335,762, filed
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`on Jul. 18, 2014, now Pat. No. 9,547,859, which is a continuation of application No. 14/214,644,
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`filed on Mar. 14, 2014, now Pat. No. 8,856,045, which is a continuation-in-part of application
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`No. 29/477,025, filed on Dec. 18, 2013, now Pat. No. Des. 755,183. These related patents were
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`expressly identified to CSC. To the extent that CSC did not expressly have knowledge of the
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`’174 patent by virtue of the above presentation, CSC willfully blinded itself to such knowledge
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`by failing to investigate patent families which PayRange identified as relevant.
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`21.
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`CSC clearly knew that copying PayRange’s products was patent infringement.
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`On information and belief, CSC was impressed with PayRange’s proposal, including PayRange’s
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`extensive patent portfolio. PayRange, in fact, met with CSC twice more to discuss PayRange’s
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`patented technology in even greater detail. After improperly obtaining as much information
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`from PayRange as it could, in early 2018, CSC abruptly terminated communications with
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`PayRange. PayRange sought an explanation, but CSC remained suspiciously tight-lipped. To
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`the extent that CSC did not have pre-suit knowledge of any patent-in-suit, CSC’s behavior
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`(including its failure to ever explain non-infringement or invalidity) is evidence of willful
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`blindness.
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`22.
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`In 2018, CSC released an initial mobile app (CSCPay Mobile) and then, in 2020,
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`CSC released a second mobile app (CSC Go). In doing so, its true motives came to light. CSC
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`had extracted information from PayRange to provide CSC with a technical shortcut, thus
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`brazenly disregarding PayRange’s patent rights. The release of CSC Go coincided with CSC’s
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`valuation increasing from $3 billion in 2018 to over $4 billion in 2020 as it was now repositioned
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`from an operator of automated retail machines into a technology company operating automated
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`retail machines.
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`23.
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`On Mach 4, 2021, CSC was deposed in another patent lawsuit brought by
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`PayRange against KioSoft, its technology supplier at the time. On information and belief, the
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`fact that CSC’s technology supplier was being accused of patent infringement caused CSC to
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`investigate PayRange’s patent portfolio, resulting in CSC attaining knowledge of the patents-in-
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`suit.
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`24.
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`On March 3, 2023, PayRange sent CSC’s counsel a detailed presentation
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`discussing its intellectual property and CSC’s continued infringement. PayRange also sent a
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`draft complaint which included specific and detailed allegations for PayRange patents which are
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`related to the patents-in-suit. CSC did not substantively respond, forcing PayRange to file an
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`action, which is pending (C.A. No. 23-278-MN). On information and belief, CSC did nothing to
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`abate its ongoing infringement and further willfully blinded itself to infringement of the patents-
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`in-suit.
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`25.
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`On January 31, 2024, PayRange issued a press release announcing a licensing
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`deal with KioSoft worth $62 Million. (See Exhibit 6). In the press release, KioSoft’s president
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`(Charles Lee) stated: “While we had challenged the PayRange patents vigorously, the Patent
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`Trial and Appeal Board (PTAB) upheld the PayRange patents and, although we disagreed with
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`the result, we must now accept that PayRange has valid claims.” The patents referenced by Mr.
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`Lee included at least the ’833 and ’614 Patents, as discussed below. KioSoft decision to license
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`and acknowledge PayRange’s patents while, on information and belief, CSC continued to
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`willfully blind itself further underscore CSC’s willful infringement.
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`26.
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`PayRange brings this case to hold CSC accountable for its willful infringement of
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`PayRange’s patent rights. PayRange has suffered monetary damages and is entitled to a money
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`judgment in an amount adequate to compensate for CSC’s infringement, together with interest
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`and costs as fixed by the Court. The lost profits damages alone could exceed $108 million over
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`the life of the patents-in-suit. PayRange also seeks to enjoin further installations of infringing
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`payment modules and to remove the infringing apps from the Google Play Store and Apple App
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`Store.
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`NATURE OF ACTION
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`27.
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`This is a civil action for patent infringement arising under the patent laws of the
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`United States, Title 35 of the United States Code.
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`28.
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`As set forth in more detail below, CSC has been infringing and continues to
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`infringe PayRange’s patents-in-suit and continues to do so through the present date.
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`THE PARTIES
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`29.
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`PayRange is a Tennessee corporation with its principal place of business at 9600
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`NE Cascades Pkwy, Suite 280, Portland, OR 97220.
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`30.
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`CSC is a Florida corporation with its principal place of business at 35 Pinelawn
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`Road, Suite 120, Melville, NY 11747. On information and belief, CSC operated as a Delaware
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`corporation for some time prior to March 22, 2019.
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`JURISDICTION AND VENUE
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`31.
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`This is a civil action for patent infringement arising under the patent laws of the
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`United States, 35 U.S.C. §§ 1 et seq.
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`32.
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`This Court has subject matter jurisdiction over this patent infringement action
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`pursuant to 28 U.S.C. §§ 1331 and 1338(a).
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`33.
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`Also, upon information and belief, CSC has infringed PayRange’s patents-in-suit
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`in this District by, among other things, engaging in infringing conduct within and directed at, or
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`from, this District. For example, upon information and belief CSC engaged in the conduct
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`underlying this action while organized as a Delaware Corporation. CSC has purposefully and
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`voluntarily placed one or more of its infringing products, as described below, into the stream of
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`commerce with the expectation that these infringing products will be used in this District. CSC’s
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`infringing products have been and continue to be used in this District.
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`34.
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`This Court also personal jurisdiction over CSC because CSC has consented to
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`personal jurisdiction for C.A. No. 23-278-MN.
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`35.
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`This Court also has personal jurisdiction over CSC because, upon information and
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`belief, its corporate parent CSC ServiceWorks Holdings, Inc., is a corporation organized and
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`existing under the laws of the State of Delaware. On information and belief, CSC is a wholly
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`owned subsidiary of Coinmach Laundry, LLC, a Delaware corporation. CSC operates as an
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`agent or alter ego of its Delaware parent, CSC ServiceWorks Holdings, Inc. For example, in the
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`Apple App store, CSC ServiceWorks Holding, Inc. is identified as the publisher of CSC Go but
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`the “developer’s privacy policy” identifies CSC as the publisher. Further, CSC is a wholly
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`owned subsidiary of CSC ServiceWorks Holding, Inc.
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`36.
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`Venue is proper in this District pursuant to 28 U.S.C § 1391(b) and 28 U.S.C.
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`§ 1400(b). CSC has consented to venue for purposes of this case. Additionally, CSC has
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`consented to venue in this District through its appointment of a registered agent for service of
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`process in Delaware: The Corporation Trust Company, Corporation Trust Center, 1209 Orange
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`St., Wilmington, DE, 19801.
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`PAYRANGE’S PATENTS-IN-SUIT
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`37.
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`To protect its unique and innovative technologies, PayRange filed a provisional
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`patent application (No. 61/917,936) on December 18, 2013.
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`38.
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`On July 21, 2020, the USPTO issued the ’833 Patent, titled “METHOD AND
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`SYSTEM FOR PERFORMING MOBILE DEVICE-TO-MACHINE PAYMENTS.” A true and
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`correct copy of the ’833 Patent is attached hereto as Exhibit 1.
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`39.
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`On January 12, 2021, the USPTO issued the ’614 Patent, titled “METHOD AND
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`SYSTEM FOR PRESENTING REPRESENTATIONS OF PAYMENT ACCEPTING UNIT
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`EVENTS.” A true and correct copy of the ’614 Patent is attached hereto as Exhibit 2.
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`40.
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`On November 1, 2022, the USPTO issued the ’174 Patent, titled “METHOD
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`AND SYSTEM FOR PERFORMING MOBILE DEVICE-TO-MACHINE PAYMENTS.” A
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`true and correct copy of the ’174 Patent is attached hereto as Exhibit 3.
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`COUNT I
`INFRINGEMENT OF THE ’833 PATENT
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`41.
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`PayRange realleges and incorporates the allegations of the preceding paragraphs
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`of this complaint as if fully set forth herein.
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`42.
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`PayRange is the assignee and owner of all right, title, and interest in and to the
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`’833 Patent. PayRange has the exclusive right to make, use, sell, and offer to sell any product
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`embodying the ’833 Patent throughout the United States, and to import any product embodying
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`the ’833 Patent into the United States.
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`43.
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`The ’833 Patent is an invention of mobile-device-to-machine payment systems
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`and, more specifically, mobile-device-to-machine payment systems over a non-persistent
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`network connection and featuring hands-free and manual modes.
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`44.
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`Figure 5 depicts “block schematic[s] that show[] elements of the system.” ’833
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`Patent at 6:49-50. The system includes Machine 120, Adapter Module 100, Mobile Device 150,
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`Operators’ Server 170, System Management Server 130, and Funding Source Server 160. Figure
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`5 of the ’833 Patent is reproduced below.
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`45.
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`“Payment Accepting Unit” or Machine 120 is connected to Adapter Module 100
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`by a wired serial connection. Id. at 13:4-7. Adapter Module 100 may be a dongle installed in
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`Machine 120 that bridges the communication between Machine 120 and Mobile Device 150. Id.
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`at 12:11-33.
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`46.
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`Adapter Module 100 is connected to Mobile Device 150 via a short-range
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`communication technology, such as Bluetooth, RFID, infrared wireless, or “any wired or
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`wireless technology that could be used to communicate a small distance.” Id. at 13:50–53,
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`19:10–13. Alternatively, “the shown short-range communication technology may be replaced
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`with alternative short-range communication technology known or yet to be discovered.” Id. at
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`20:6–12; see also id. at 13:44–53, 17:40–42. “The user’s mobile device 150 acts as a
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`communication bridge between the adapter module 100 and the server 130.” Id. at 13:38–40.
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`Mobile Device 150 maybe a smart phone, tablet, laptop computer, personal digital assistant,
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`smart card, or other technology known or yet to be discovered that has similar capabilities. Id. at
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`12:47-53. Mobile Device 150 has an App 140 (“any software program(s) capable of
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`implementing the features”) running on it. Id. at 12:53–57. Mobile Device 150 also is connected
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`to System Management Server 130 and/or Funding Source Server 160 via a long-range
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`communication technology, such as WiFi or Cellular connection. Id. at 19:19–25. “[T]he shown
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`long-range communications technology may be replaced with alternative long-range
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`communications technology known or yet to be discovered.” Id. at 20:6–9; see also id. at 17:42–
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`45. Machine 120 also may be connected to an Operators’ Server 170, via a handheld computer
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`sync or a cellular connection. Id. at 19:33–39.
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`47.
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`Figure 1 of the ’833 Patent is reproduced below. Figure 1 depicts a schematic
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`diagram of Machine 120 with Adapter Module 100, and “three zones: a first ‘communication
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`zone” (e.g., ‘Bluetooth range’), a second ‘authorization zone,’ and a third ‘payment zone.’” Id.
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`at 6:36–38. App 140 on Mobile Device 150 continuously scans for a signal, communication, or
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`transmission from Adapter Module 100, which constantly advertises its availability, for example,
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`via Bluetooth. Id. at 28:64–67, 29:18–25. Mobile Device 150 then tracks and monitors the signal
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`strength until the user is in the authorization zone threshold. Id. at 29:25-28. The zone
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`thresholds are determined, for example, by an In-Range Heuristics mathematical computation to
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`derive an optimal Received Signal Strength Indicator threshold. Id. at 14:35–56.
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`48.
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`As the user enters authorization zone 104, Mobile Device 150 establishes a
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`connection to Adapter Module 100. Id. at 23:1-5. After a successful handshake with Adapter
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`Module 100, Adapter Module 100 requests an authorization from Server 130 via Mobile Device
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`150’s network connection. Id. at 23:5-10. App 140 on Mobile Device 150 “creates a request for
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`authorization (AuthRequest) and passes the AuthRequest to the server 130 using appropriate
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`communication technology (e.g. cellular or WiFi).” Id. at 29:33-37. Server 130 “responds with
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`an authorization grant (AuthGrant)” and Mobile Device 150 retains the AuthGrant from Server
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`130 until Mobile Device 150 is ready to issue payment to Adapter Module 100. Id. at 29:37-44.
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`Unused AuthGrants expire and are purged from Mobile Device 150. Id. at 29:47-48. As the user
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`continues to approach Adapter Module 100, the user enters payment zone 102 and an event
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`threshold is triggered based on heuristics performed by the Mobile Device 150. Id. at 29:59-62.
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`If the authorization grant has not expired, Mobile Device 150 sends the authorization grant to
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`-17-
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`Adapter Module 100 to start a transaction. Id. at 30:2-8. In a hands-free mode, (id. at 11:12–36),
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`Mobile Device 150 sends the authorization grant automatically without user interaction, and, in
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`manual (swipe to pay) mode (id. at 10:58–11:11), Mobile Device 150 sends the authorization
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`grant after a prompt from the user, such as a “swipe” on Mobile Device 150. Id. at 30:8-16.
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`“The user completes the transaction on the payment accepting unit 120 in much the same manner
`
`as if cash had been inserted into the payment accepting unit 120 to establish credit.” Id. at 23:38-
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`41; see also 11:5-9, 11:30-34, 21:7-11. Details of the transaction are then returned to Mobile
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`Device 150 and Server 130. Id. at 23:41-45.
`
`49.
`
`Claim 1 recites “[a] method of payment processing” and steps for authorizing a
`
`cashless transaction at an automatic retail machine. ’833 Patent at 33:6–34. Claim 1 recites
`
`obtaining authorization for a purchase and then conducting the purchase. Claim 1 also recites
`
`steps for conducting a purchase (i.e., cashless transaction) — detecting a trigger condition and
`
`sending the authorization grant to the electronic payment device to complete the transaction.
`
`50.
`
`Independent claims 14 and 21 recite additional elements not recited by claim 1.
`
`By way of example, claims 14 and 21 recite: “a first transceiver corresponding to a short-range
`
`communication mode, and a second transceiver, distinct from the first transceiver, corresponding
`
`to a long-range communication mode distinct from the short-range communication mode.” Id. at
`
`34:44-48; 35:64-36:1.
`
`51.
`
`Dependent claims 2-13, 15-20, and 22-27 recite further additional elements not
`
`recited by claim 1. By way of example, claim 2 recites:
`
`2. The method of claim 1, wherein:
`the transmission at least includes authorization zone threshold
`criterion; and after receiving the transmission, initiating a
`handshake process with the electronic payment device,
`wherein the handshake process includes:
`
`-18-
`
`

`

`Case 1:24-cv-00279-MN Document 1 Filed 03/04/24 Page 19 of 30 PageID #: 277
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`sending, to the electronic payment device, mobile device
`information corresponding to the mobile device via a first
`transceiver of the mobile device; and
`receiving, from the electronic payment device, electronic payment
`device information, wherein the electronic payment device
`information at least includes an identifier corresponding to
`the electronic payment device.
`
`Id. at 2:35-49.
`
`52.
`
`On August 18, 2023, the USPTO issued a post-grant review certificate confirming
`
`the patentability of claims 2-27 of the ’833 Patent. See Exhibit 4. On information and belief,
`
`CSC was a real party in interest or a privy of KioSoft based at least on its commercial
`
`relationship, including indemnification obligations, and a common litigation strategy. For
`
`example, KioSoft’s president admitted to such a commercial relationship during a hearing in
`
`PayRange v. KioSoft, Case No. 1:20-cv-20910 (S.D. Florida, July 27, 2021). Accordingly, CSC
`
`is estopped from relitigating invalidity grounds which were raised or could have been raised. See
`
`35 U.S.C. § 325(e)(2).
`
`53.
`
`Upon information and belief, CSC has and is infringing at least claims 2-27 of the
`
`’833 Patent in this District and elsewhere in the United States, by, among other things, directly or
`
`through intermediaries, making, using, selling and/or offering for infringing products with
`
`mobile payment functionalities, covered by one or more claims of the ’833 Patent. CSC is
`
`directly infringing, literally infringing, and/or infringing the ’833 Patent under the doctrine of
`
`equivalents. CSC is thus liable for infringement of the ’833 Patent pursuant to 35 U.S.C.
`
`§ 271(a).
`
`54.
`
`CSC infringes at least the above-identified claims of the ’833 Patent by including
`
`a mobile device with a transceiver corresponding to a short-range communication mode, and a
`
`second transceiver, distinct from the first transceiver, corresponding to a long-range
`
`-19-
`
`

`

`Case 1:24-cv-00279-MN Document 1 Filed 03/04/24 Page 20 of 30 PageID #: 278
`
`communication mode distinct from the short-range communication mode; one or more
`
`processors; and memory storing one or more programs to be executed by the one or more
`
`processors, the one or more programs comprising instructions for, prior to user selection of any
`
`items or services provided by an automatic retail machine: (a) identifying the automatic retail
`
`machine based at least in part on a transmission received from an electronic payment device of
`
`the automatic retail machine; (b) in response to identifying the automatic retail machine,
`
`obtaining, from the electronic payment device, a request, via a communications unit of the
`
`mobile device, to preemptively obtain authorization to make funds available for a cashless
`
`transaction with the automatic retail machine; (c) sending, to a server, the request via the
`
`communications unit of the mobile device; (d) in response to sending the request to the server,
`
`obtaining from the server an authorization grant of an amount of funds for use in conjunction
`
`with the cashless transaction with the automatic retail machine; (e) detecting, by an application
`
`executing on the mobile device, a trigger condition to perform the cashless transaction with the
`
`automatic retail machine; and (f) in response to detecting the trigger condition, and sending to
`
`the electronic payment device the authorization grant to enable completion of the cashless
`
`transaction at the automatic retail machine.
`
`55.
`
`Upon information and belief, CSC will continue to directly infringe the ’833
`
`Patent unless enjoined.
`
`56.
`
`To the extent CSC Go as installed on a smartphone, do not directly infringe at
`
`least claim 1 of the ’833 Patent, CSC contributes to infringement of the same under 35 U.S.C. §
`
`271(c) inasmuch as infringing products offered for sale and sold by CSC are components of a
`
`patented machine or an apparatus used in practicing a patented process, constituting a material
`
`-20-
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`

`

`Case 1:24-cv-00279-MN Document 1 Filed 03/04/24 Page 21 of 30 PageID #: 279
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`part of PayRange’s invention, knowing the same to be especially made or especially adapted for
`
`use in infringement of the ’833 Patent.
`
`57.
`
`CSC Go as installed on a smartphone directly infringe the ’833 Patent and are
`
`being provided by CSC to install in their community laundry rooms, in-home units, or
`
`commercial site. Upon information and belief, CSC will continue to contribute to infringement
`
`of the ’833 Patent unless enjoined.
`
`58.
`
`CSC actively encourages their business partners and/or customers to use CSC Go
`
`as installed on a smartphone in an infringing manner. Despite knowing of PayRange’s patented
`
`technology, CSC actively induced its business partners and/or customers to use CSC Go in an
`
`infringing manner. CSC encouraged this infringement with a specific intent to cause its business
`
`partners and customers to infringe. CSC’s acts thus constitute active inducement of patent
`
`infringement in violation of 35 U.S.C. § 271(b).
`
`59.
`
`Upon information and belief, CSC will continue to induce infringement of the
`
`’833 Patent unless enjoined.
`
`60.
`
`CSC’s direct infringement, contributory infringement, and inducement of
`
`infringement have irreparably harmed PayRange. For example, but for CSC’s infringement,
`
`PayRange would have installed its competing solution. PayRange’s business and its valuation is
`
`enhanced with each machine added to its payment network, which in turns adds more users to
`
`the network. The full value of each installation may not be amenable to calculation due in part to
`
`the network effect of devices and users. Additionally, the continued infringement harms
`
`PayRange’s reputation in the marketplace by discouraging other potential customers from
`
`entering into agreements for PayRange’s so