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`EXHIBIT A
`EXHIBIT A
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`CONFIDENTIAL – SUBJECT TO FRE 408
`
`Justin J. Lesko, Esq.
`Registered Patent Attorney
`Admitted in Illinois
`JustinLesko@PatentIt.com
`Direct: (773) 484-3285
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`March 14, 2024
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`VIA PRIORITY MAIL
`
`Samantha Hannan
`General Counsel
`Alliance Laundry Systems, LLC
`PO Box 990
`Shepard Street
`Ripon, WI 54971 USA
`
`
`
`Re:
`
`Infringement of the PayRange Inc. Patent Portfolio
`
`
`Dear Ms. Hannan:
`This office represents PayRange Inc. (“PayRange”) with respect to its more than 60
`patents and pending applications (“PayRange IP”) covering commercially significant
`developments in the field of mobile payment systems for unattended retail machines. The
`purpose of this letter is to provide Alliance Laundry Systems, LLC (hereinafter, “Alliance”),
`with an explanation of the scope of PayRange’s patent portfolio, to place Alliance on notice that
`it infringes numerous issued and allowed claims of PayRange’s IP in connection with its Speed
`Queen and Huebsch mobile apps and payment systems, and to begin the process of discussing
`the merits of the matter.
`This office and our client together accept the burden of demonstrating to Alliance the
`merits of PayRange’s infringement assertions and the value in PayRange’s IP. We take that
`obligation very seriously, and we are committed to working in good faith with Alliance to
`efficiently address the matter. Accordingly, we have provided detailed information with this
`notice letter supporting PayRange’s assertions, and we agree to respond promptly to any
`questions or defenses that Alliance raises.
`In return, we expect that Alliance will also address the matter promptly and in good faith.
`If Alliance has meritorious defenses, it will not need a license under PayRange’s IP. If, on the
`other hand, PayRange’s infringement assertions have merit (as we believe), then PayRange
`requires Alliance to work with us to address appropriate terms for a license or other business
`resolution.
`Alliance is advised that PayRange is actively enforcing and licensing its patents against
`infringers in the industry, as further explained in Section II below. PayRange is also actively
`filing additional patent applications. As a result of those activities, and as additional agreements
`are signed and additional patents issue, the value of PayRange’s portfolio will increase, as will
`its corresponding license fees. Therefore, if Alliance has any interest in resolving this matter
`
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`
`
`Scottsdale Office P: 480.535.6656 | F: 480.535.6628 | A: 7689 E. Paradise Lane, Suite 2, Scottsdale, AZ 85260
` Chicago Office P: 312.752.4357 | F: 312.896.5633 | A: 332 S. Michigan Avenue, Suite 900, Chicago, IL 60604
`PATENT IT!®
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`amicably, we encourage you to respond as soon as possible to obtain the best possible license fee
`and terms. Moreover, while we will attempt to keep Alliance informed on a rolling basis, we
`encourage Alliance to itself continue to monitor the public court and USPTO proceedings
`relating to PayRange’s patent enforcement and prosecution activities.
`We request that Alliance promptly acknowledge receipt of this letter and confirm that it
`will work with PayRange in good faith to address the merits of the infringement assertions.
`In the meantime, we provide below an explanation of the scope of PayRange’s patent
`portfolio and PayRange’s enforcement of its patent rights.1
`
`I.
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`PAYRANGE’S PATENTED TECHNOLOGY
`The PayRange IP includes a growing portfolio of more than 60 patents and pending
`applications worldwide. We have attached to this letter, as Exhibit A, a current list of the
`PayRange patents and applications. The patents asserted herein are 100% owned by PayRange.
`Accordingly, PayRange has full authority to resolve this matter through a license agreement or
`other business resolution.
`In late 2013, PayRange filed its first patent applications. Since that time, PayRange has
`filed dozens of additional patent applications, including continuation and continuation-in-part
`applications that claim priority to the original filings in 2013, as well as entirely new patent
`families directed to other important technologies developed by PayRange.
`For brevity, we focus our discussion in this letter on (1) issued patents and allowed
`United States patent applications with claims that are infringed by Alliance, and (2) patents in the
`laundry/vending mobile payment space with claims confirmed during post-grant review
`proceedings at the USPTO that may be infringed by Alliance. The patents that that we highlight
`in this letter all belong to the original patent family, which PayRange refers to as the “BluKey”
`patents and applications.
`1. PayRange claims infringed by Alliance
`Based on a review of the publicly available materials describing Alliance’s laundry and
`mobile payment systems, we have determined that Alliance infringes multiple claims of
`PayRange’s issued patents and pending and allowed patent applications in connection with the
`“Speed Queen” and “Huebsch” mobile applications and payment systems, either directly,
`through contributory infringement, or by inducement. Specifically, we have determined that
`Alliance infringes at least the following claims:
`• Claim 11 of U.S. Patent No. 11,481,772;
`• Pending and allowed claims 1-6, 8, 9, 12-20 of U.S. Patent Application No.
`18/197,070; and
`
`
`1 All of PayRange’s infringement charts, exhibits, and references identified in this letter and in Appendix 1 are
`available for download on our secure server at the following link:
`https://patentit.box.com/s/akvcaxa2gbs3qc7vwaprkilnmkz7kzch (Password: “ALL8327V”)
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`www.PatentIt.com | info@patentit.com
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`PATENT IT!®
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`• Pending and allowed claims 1-6, 8, 9, 12-20 of U.S. Patent Application No.
`18/197,071.
`PayRange provides as Exhibits B, C and D detailed claim infringement charts
`demonstrating Alliance’s infringement of the above-listed claims on an element-by-element
`basis. For the pending and allowed claims, this letter serves as notice for provisional damages
`under 35 U.S.C. § 154(d). Under this statute, Alliance is responsible for provisional damages if
`it infringes PayRange’s published claims that issue as a patent without substantive change.
`Accordingly, Alliance is already accruing damages by infringing the above-listed allowed claims
`of the ’070 and ’071 applications, which are in their final form, will not substantively be
`changed, and will soon issue.
`Again, please refer to the detailed claim infringement charts and exhibits listed on Exhibit
`1 and included on the file share folder identified in footnote 1. However, to help Alliance review
`this matter efficiently, we also provide below a brief summary of Alliance’s infringement of
`claim 11 of U.S. Patent No. 11,481,772, claim 15 of the allowed ’070 application, and claim 15
`of the allowed ’071 application.
`First, we refer to the preambles of the identified claims. The preamble of Claim 11 of the
`’772 patent recites “[a] method of presenting representations of payment accepting unit events”
`that takes place at a mobile device. Alliance makes, uses, sells, and offers for sale both the
`“Speed Queen” and the “Huebsch” applications on the Google Play Store and the Apple App
`store as shown in Figures 1-4 below:
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`Figure 1. The Speed Queen app on the Google
`Play store, showing over 100,000 Downloads.
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`Figure 2. The Huebsch app on the Google Play
`store, showing over 100,000 Downloads.
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`Case 1:24-cv-00733-MN Document 18-1 Filed 10/04/24 Page 5 of 456 PageID #: 976
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`Figure 4. The Huebsch app on the Apple app store.
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`Figure 3. The Speed Queen app on the Apple app
`store.
`By itself using those apps on mobile devices to carry out the method recited in claim 11, Alliance
`directly infringes claim 11 of the ‘772 patent under 35 U.S.C. § 271(a). Alliance also induces
`infringement of the ’772 patent under 35 U.S.C. § 271(b) by actively encouraging infringement
`by its business partners and customers. Specifically, Alliance intends to cause its business
`partners and customers to infringe by actively encouraging its business partners and customers to
`use the Speed Queen app and Huebsch app in a manner that meets all of the elements of claim 11
`of the ’772 Patent. Alliance also contributes to infringement of the ’772 patent under 35 U.S.C.
`§ 271(c) because the Speed Queen app and Huebsch app are each a component of a patented
`machine or an apparatus used in practicing a patented process, constituting a material part of
`PayRange’s invention, with Alliance knowing the same to be especially made or especially
`adapted for use in infringement of claim 11 of the ’772 Patent.
`Claim 15 the ‘070 application and Claim 15 of the ‘071 application recite, as a preamble,
`“A non-transitory computer readable storage medium storing one or more programs, the one or
`more programs comprising instructions, which, when executed by a mobile device with one or
`more processors, one or more output devices including a display, and one or more radio
`transceivers, cause the mobile device to perform operations.” That preamble refers to a stored
`mobile app that can be used on a mobile device. Alliance makes, uses, sells, and offers for sale
`both the Speed Queen app and the Huebsch app on the Google Play Store and the Apple App
`store, and thereby directly infringes allowed claim 15 of both the ‘070 and ‘071 application.
`The next element of ’772 patent claim 11 recites: “displaying a user interface of the
`mobile payment application on the display of the mobile device, the user interface being
`configured to display a visual indication of the one or more payment accepting units and accept
`user input to (i) receive selection by a user of the mobile device of an available payment
`accepting unit of the one or more payment accepting units….” Similarly, the next two elements
`of claim 15 the ‘070 application and claim 15 of the ‘071 application refer to the mobile
`application “identifying one or more payment accepting units that are available to accept
`payment from a mobile payment application executing on the mobile device” based on an
`identifier, and displaying a user interface that is configured to both display a visual indication of
`the available payment accepting units and receive a selection of one of those units. Consistent
`with those claim elements, both the Speed Queen and the Huebsch apps display payment
`accepting washers/dryers, display their numerical identifiers, and receive a selection of a washer
`or dryer, as shown in Figures 5 and 6 below:
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`Figure 5. The Speed Queen app displays payment
`Figure 6. The Huebsch app displays payment
`accepting washers/dryers, displays their numerical
`accepting washers/dryers, displays their numerical
`identifiers, and receives a selection of a washer or
`identifiers, and receives a selection of a washer or
`dryer.
`dryer.
`The next two elements of ’772 patent claim 11, claim 15 the ‘070 application, and claim
`15 of the ‘071 application all refer to establishing a wireless communication path with the
`selected unit and enabling user interaction with the user interface of the mobile payment
`application to complete a transaction with the unit. The second element of ’772 patent claim 11
`also recites that the user interface is configured to “trigger payment by the mobile payment
`application for a transaction initiated by the user of the mobile device with the available payment
`accepting unit of the one or more payment accepting units.” Claim 15 of the ‘071 application
`further specifies that “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.” Both the Speed Queen and the Huebsch apps meet all of
`these claim elements.
`Specifically, both apps establish a wireless (e.g., cellular) communication path with a
`selected washer or dryer via cloud servers and display a visual representation of the washer or
`dryer (i.e., “Washer 0051” or “Washer 0101”), an indication of a balance (such as the balance
`due), and a user option to “Pay,” as shown below in Figures 7 and 8:
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`Case 1:24-cv-00733-MN Document 18-1 Filed 10/04/24 Page 7 of 456 PageID #: 978
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`Figure 7. The Speed Queen app displays a visual
`Figure 8. The Huebsch app displays a visual
`representation of the washer or dryer (i.e., “Washer
`representation of the washer or dryer (i.e., “Washer
`0051”), an indication of the balance due, and a user
`0101”), an indication of the balance due, and a user
`option to “Pay.”
`option to “Pay.”
`The next two elements of ’772 patent claim 11, claim 15 the ‘070 application, and claim
`15 of the ‘071 application all refer to exchanging information with a payment accepting unit via
`a radio transceiver and then displaying an updated user interface on the mobile device. Both the
`Speed Queen and the Huebsch apps display an updated user interface, such as an “in use” screen,
`when the “Pay” button is selected, which also causes the mobile phone to exchange information
`with the washer or dryer to start it.
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`Figure 9. The Speed Queen app displays an “in
`use” screen after information is exchanged with the
`washer or dryer when the “Pay” button is selected.
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`Figure 10. The Huebsch app displays an “in use”
`screen after information is exchanged with the
`washer or dryer when the “Pay” button is selected.
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`The above discussion covers all the elements of claim 15 the ‘070 application and claim
`15 of the ‘071 application.
`Claim 11 of the ’772 patent additionally recites: “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; an indication of a prepared balance; and
`an affordance that when slid, indicates the initiation of the transaction; wherein the affordance is
`slid in response to receiving a user input of swipe on the affordance displayed on the display of
`the mobile device.” Alliance infringes that element, at least under the doctrine of equivalents,
`because the Speed Queen app and Huebsch app display the “Pay” button shown in Figures 7 and
`8 that indicates the initiation of the transaction when pressed. That button performs substantially
`the same function in substantially the same way to produce substantially the same result as the
`affordance recited in claim 11. Crown Packaging Tech., Inc. v. Rexam Beverage Can Co., 559
`F.3d 1308, 1312 (Fed. Cir. 2009). In addition, the differences between the pressed button and a
`swiped affordance would be regarded by a POSITA to be insubstantial. Catalina Marketing
`International, Inc. v. Coolsavings.com, Inc., 289 F.3d 801, 813 (Fed. Cir. 2002).
`We strongly recommend that Alliance carefully review all the claims shown in the
`included infringement charts. In short, we believe the features covered by PayRange’s patents to
`be extremely valuable. Based on Alliance’s mass adoption of these same features in its products,
`and its focus on the technology in its advertising campaigns, we believe that Alliance ultimately
`agrees with that assessment. From the charts, Alliance should also be able to readily recognize
`that similar infringing systems are also employed by the direct competitors of Alliance, including
`Kiosoft (which, as explained below, accepted a license after contested litigation with PayRange)
`and CSC (currently in litigation with PayRange).
`To be clear, we are prepared to immediately address in detail and in good faith any
`questions that Alliance raises regarding the infringement assertions, including PayRange’s
`infringement charts, via a telephone call or online meeting. We strongly encourage Alliance to
`take advantage of the opportunity to meet with us, as it will materially simplify and advance its
`consideration of the infringement charges and available license fees.
`2. Additional PayRange laundry mobile payment patents
`To further assist Alliance in its review of this matter, we also provide a brief summary of
`some of the key features of the claims of other PayRange patents in the laundry/vending mobile
`payment space that have been confirmed during post-grant review proceedings at the USPTO.
`The discussion below is not intended to be an exhaustive discussion of PayRange’s patents, nor
`should any of the descriptions below be considered a formal construction of PayRange’s claims.
`Instead, Alliance should independently review and consider at least the following
`additional patents and claims that are infringed by others in the industry and might be infringed
`by Alliance:
`• U.S. Patent No. 9,659,296, Claims 1-23; and U.S. Patent No. 10,891,614, Claims 7, 11-
`13, 16 and 17:
`o These claims include some elements in common with the ‘070 and ‘071 applications
`that are infringed by Alliance, and they further specify that the mobile payment
`application is “configured to identify one or more vending machines in proximity to
`
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`the mobile device that are available to accept payment from the mobile payment
`application, the identifying including detecting predefined radio messages broadcast
`by the one or more vending machines.”
`o To the extent that Alliance uses or has used predefined radio messages, such as
`Bluetooth, WIFI, or NFC, to identify machines in its payment applications, Alliance
`potentially infringes one or more of these claims.
`• U.S. Patent No. 10,719,833, Claims 2-27; U.S. Patent No. 10,438,208, Claims 1-20; and
`U.S. Patent No. 11,488,174, Claims 1-20:
`o These claims refer to an application on a mobile that preemptively obtains
`authorization to make funds available as part of a cashless transaction because, for
`example, (1) the mobile phone has identified a retail machine based on a transmission
`received from it (i.e., ’833 patent claim 21), (2) the mobile device has entered an
`authorization zone associated with the automated retail machine (i.e., ’208 patent
`claim 17), or (3) the retail machine has requested the preemptive authorization (i.e.,
`’174 patent claim 19).
`o To the extent that Alliance provides or has provided an application that obtains funds
`preauthorization using these methods, Alliance potentially infringes one or more of
`these claims.
`• U.S. Patent No. 10,891,608, Claims 1-20:
`o These claims refers to a payment module that converts a coin-operated machine into a
`machine that can receive cashless transactions by storing the number of electrical
`pulses corresponding to a coin operation and mimicking those pulses in response to a
`cashless payment.
`o To the extent that Alliance provides or has provided such payment modules for
`converting coin-operated machines, Alliance potentially infringes one or more of
`these claims.
`Again, we are prepared to address in detail any questions that Alliance raises regarding
`the above patents or any other PayRange patents.
`
`II. PAYRANGE’S ENFORCEMENT OF ITS PATENTS
`For the past four years, PayRange has engaged in a substantial enforcement program
`against several major companies in the laundry mobile payment industry that infringed the
`PayRange IP but refused to negotiate a license. As a result of those efforts, PayRange recently
`signed a license agreement with TechTrex, Inc. and KioSoft Technologies LLC.
`The KioSoft license to the PayRange technology is significant in that the license fee
`could exceed $62 million over a 10-year period based on outcomes, with a base license of $40
`million. See, e.g., https://www.prnewswire.com/news-releases/payrange-settles-patent-dispute-
`with-kiosoft-securing-62-million-licensing-deal-302048913.html. Furthermore, for many years,
`KioSoft refused a license to the PayRange patent portfolio and fought vigorously to try to
`invalidate PayRange’s patents in Court and in post-grant proceedings filed at the USPTO.
`
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`KioSoft only accepted a license after PayRange proved the merits of its patents with significant
`victories at the USPTO.
`Following the settlement with KioSoft, Charles Lee, its president stated in a press release:
`“While we had challenged the PayRange patents vigorously, the Patent Trial and Appeal Board
`(PTAB) upheld the PayRange patents and, although we disagreed with the result, we must now
`accept that PayRange has valid claims. We respect the technologies that have helped the self-
`service industry thrive; and we look forward to continuing to lead innovation and development
`by providing best-in-class service to our customers with this fully licensed technology, without
`any further legal distractions.” See, e.g., https://www.prnewswire.com/news-releases/payrange-
`settles-patent-dispute-with-kiosoft-securing-62-million-licensing-deal-302048913.html.
`PayRange has also filed litigation against CSC Service Works, the largest US operator of
`laundry machines in multi-family housing and college dorms, including a new suit asserting
`additional infringed patents that was filed on March 5, 2024. PayRange is seeking damages in
`that lawsuit exceeding $108 million, and a finding of willful infringement can treble the
`damages.
`e.g.,
`https://www.prnewswire.com/news-releases/payrange-files-patent-
`See,
`infringement-lawsuit-against-csc-serviceworks-302081204.html.
`Clearly, PayRange is committed to licensing infringers in the laundry mobile payment
`industry, including Alliance. Like Alliance, PayRange has written letters, or is in the process of
`writing letters, to many other companies in an attempt to informally resolve the infringement
`assertions without the need for the significant time and expense of patent litigation. PayRange
`prefers that amicable path, as it is the most efficient and cost-effective way to address the matter.
`Given the well-developed public record detailed below regarding PayRange’s prosecution and
`enforcement efforts, Alliance should be able to promptly and efficiently determine how it wishes
`to resolve this matter.
`However, Alliance should know that PayRange will continue to file lawsuits as necessary
`against those infringers that refuse a license without presenting any meritorious defenses,
`including by seeking treble damages for willful infringement against infringers with knowledge
`of PayRange’s patents that refuse to negotiate a license. In that regard, to date, PayRange has
`filed the following lawsuits against accused infringers:
`1. PayRange Inc. v. Kiosoft Technologies, LLC et al, Case No. 1-20-cv-20970, Southern
`District of Florida (Finding of non-infringement for U.S. Patent Nos. 9,134,994 and
`9,659,296, Federal Circuit appeal dismissed following Kiosoft settlement).
`2. PayRange Inc. v. Kiosoft Technologies, LLC et al, Case No. 1-20-cv- 24342, Southern
`District of Florida (Settled).
`3. PayRange Inc. v. CSC ServiceWorks, Inc. et al, Case No. 1-22-cv-00502, District of
`Delaware (Voluntarily dismissed without prejudice).
`4. PayRange Inc. v. CSC ServiceWorks, Inc. et al, Case No. 1-23-cv-00278, District of
`Delaware (Pending).
`5. PayRange Inc. v. CSC ServiceWorks, Inc., Case No. 1-24-cv-00279, District of Delaware
`(Pending).
`
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`PayRange has also successfully defended multiple post-grant challenges to its patents at
`the USPTO. Indeed, to date, none of PayRange’s patents have been subject to a final
`determination by the Board that all claims are invalid: in each case, the Board has confirmed
`some or all of the patent claims in its final decision (or its decision denying institution). We
`provide below a complete list of the PayRange post-grant proceedings and status:
`1. CBM2020-00026 against U.S. Patent No. 9,659,296, Kiosoft Technologies LLC et al. v.
`PayRange Inc et al. – Institution Denied (03/22/2021).
`2. IPR2021-00086 against U.S. Patent No. 9,659,296, Kiosoft Technologies LLC et al. v.
`PayRange Inc et al. – Institution Denied (03/22/2021).
`3. PGR2021-00077 against U.S. Patent No. 10,719,833, Kiosoft Technologies LLC et al. v.
`PayRange Inc. – Final Written Decision, Claims 2-27 Confirmed (10/26/2022).
`4. PGR2021-00084 against U.S. Patent No. 10,891,608, Kiosoft Technologies LLC et al. v.
`PayRange Inc. – Institution Denied (12/16/2021).
`5. PGR2021-00093 against U.S. Patent No. 10,891,614, Kiosoft Technologies LLC et al. v.
`PayRange Inc. – Final Written Decision, Claims 7, 11-13, 16, and 16 Confirmed
`(12/14/2022).
`6. PGR2022-00035 against U.S. Patent No. 11,074,580, Kiosoft Technologies LLC et al. v.
`PayRange Inc. – Institution Denied (12/06/2022).
`7. IPR2023-01187 against U.S. Patent No. 10,438,208, CSC Serviceworks Inc v. PayRange
`Inc. – Institution Denied (01/18/2024).
`8. IPR2023-01188 against U.S. Patent No. 10,891,608, CSC Serviceworks Inc v. PayRange
`Inc. – Institution Denied (01/24/2024).
`9. PGR 2023-00042 against U.S. Patent No. 11,481,772, Kiosoft Technologies LLC et al. v.
`PayRange Inc. – Settled, before Decision on Institution (02/06/2024).
`10. PGR 2023-00045 against U.S. Patent No. 11,488,174, Kiosoft Technologies LLC et al. v.
`PayRange Inc. – Settled, before Decision on Institution (02/06/2024).
`11. PGR 2023-00050 against U.S. Patent No. 11,501,296, Kiosoft Technologies LLC et al. v.
`PayRange Inc. – Settled, before Decision on Institution (02/06/2024).
`12. IPR2023-01186 against U.S. Patent No. 8,856,045, CSC Serviceworks Inc v. PayRange
`Inc. – Pending, Instituted (01/19/2024).
`13. IPR2023-01449 against U.S. Patent No. 11,481,772, CSC Serviceworks Inc v. PayRange
`Inc. – Pending, awaiting Decision on Institution.
`We encourage Alliance to follow the dockets in the pending litigations and post-grant
`review proceedings at the USPTO. We expect PayRange to continue to succeed in both forums.
`
`III. PAYRANGE’S ONGOING PATENT PROSECUTION
`PayRange is diligently continuing its prosecution efforts to expand its patent portfolio.
`PayRange is carefully analyzing its issued and pending claims to perfect claim language, cite the
`most pertinent references and information, and to prepare new patent applications for the
`
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`multitude of commercially significant inventions disclosed and described in its specification, but
`not yet claimed in its existing patents and applications.
`Alliance should expect additional claims and patents to issue to PayRange in the near
`future. We suggest that Alliance carefully follow the public record in the Patent Office relating to
`the PayRange IP. As new patents continue to issue, the cost for a license will increase
`accordingly. Similarly, with each new favorable decision from the PTAB, the cost for a license
`will increase.
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`IV. FORWARD CITATIONS OF THE PATENTED TECHNOLOGY
`PayRange's patents and applications have been extensively cited by examiners (at
`present, over 100 times), including as the basis for rejecting claims in third-party patent
`applications. For example, PayRange’s patents and publications have been cited by examiners in
`applications filed by Apple Inc.*, Bank of America Corporation*, Capital One Services LLC,
`Dropbox, Inc., Haier US Appliance Solutions, Inc.*, Mastercard International Incorporated*,
`Nike, Inc., Samsung Electronics Co., Ltd., Square, Inc.*, Visa International*, and Wells Fargo
`Bank, N.A., among others (companies marked with an asterisk faced a rejection based on a
`PayRange patent or publication).
`The USPTO’s frequent (and ongoing) citation of PayRange’s patents and applications in
`the prosecution of third-party applications provides further evidence of the pioneering nature,
`novelty, and merit of PayRange’s portfolio. Specifically, the USPTO recognizes that PayRange’s
`commercially significant advancements preempt the developments of some of the world’s largest
`technology companies.
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`V. CONCLUSION
`We have provided Alliance with the documents and materials necessary to review this
`matter and understand PayRange’s assertions. We request that Alliance respond promptly with
`an indication that it will address in good faith PayRange’s infringement charges.
`As noted repeatedly in this letter, we are available to discuss via an online or in-person
`meeting the basis for PayRange’s infringement assertions and to consider any questions or
`defenses that Alliance wishes to raise. Our technical team is available to discuss the claim
`infringement charts and to address any technical questions Alliance may have. We invite
`Alliance to present any defenses, which we will fully consider.
`Furthermore, we believe that an early conversation regarding the cost of a license would
`be very beneficial to Alliance. We can assure Alliance that PayRange’s licensing terms are
`reasonable. In addition, if Alliance would like to have commercial discussions regarding a
`business resolution, we can make PayRange’s management team available.
`We further note that by providing the Speed Queen and the Huebsch apps and payment
`systems to its customers, Alliance is actively inducing those customers to directly infringe
`PayRange’s patents. By negotiating a license with PayRange, Alliance can resolve some of its
`customer’s direct liability to PayRange and fulfill any potential indemnity obligations that
`Alliance has for those customers, which may be substantial.
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`www.PatentIt.com | info@patentit.com
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`PATENT IT!®
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`We look forward to hearing from you, and to working with Alliance to address the
`matters raised in this letter. However, if we do not hear promptly from Alliance, we will assume
`it has no desire to resolve the matter informally.
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`Please feel free to contact me directly by phone (773-484-3285) or by email
`(JustinLesko@PatentIt.com). Thank you.
`
`Very truly yours,
`Justin Lesko
`Justin Lesko
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`March 14, 2024
`Page 12
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`PATENT IT!®
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`APPENDIX 1
`TABLE OF EXHIBITS AND REFERENCES
`
`List of PayRange Patents and Pending Applications
`Alliance Claim Infringement Chart for U.S. Patent No. 11,481,772
`Alliance Claim Infringement Chart for U.S. Patent Application No.
`18/197,070
`Alliance Claim Infringement Chart for U.S. Patent Application No.
`18/197,070
`Speed Queen App on the Google Play Store
`Reference 1
`Speed Queen App on the Apple App Store
`Reference 2
`Reference 3 Huebsch App on the Google Play Store
`Reference 4 Huebsch App on the Apple App Store
`Reference 5 YouTube - How to do Laundry with SpeedQueen
`Reference 6 YouTube - Huebsch App Delivers Convenience and Ease of Use
`Reference 7
`Customer App – Huebsch website
`Reference 8
`iPhone 15 Pro and 15 Pro Max - Technica