`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`ALLIANCE LAUNDRY SYSTEMS LLC,
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`Plaintiff,
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`v.
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`PAYRANGE INC.,
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`Defendant.
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`)
`
`C. A. No.: 24-733-MN
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`JURY TRIAL DEMANDED
`
`ALLIANCE LAUNDRY SYSTEMS LLC’S
`PARTIAL MOTION TO DISMISS PAYRANGE’S AMENDED COUNTERCLAIMS
`
`Pursuant to Federal Rule of Civil Procedure 12(b)(6), Plaintiff Alliance Laundry Systems,
`
`LLC (“Alliance”) hereby moves to dismiss Counterclaim Counts I-III of Defendant PayRange
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`Inc.’s Amended Answer and Counterclaims (D.I. 18) because the asserted claims of U.S. Patent
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`Nos. 11,972,423 (“the ’423 Patent”), 11,966,920 (“the ’920 Patent”), and 11,481,772 (“the ’772
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`Patent”) fail to claim eligible subject matter pursuant to 35 U.S.C. § 101. The reasons supporting
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`this motion are more fully set forth in Alliance’s Opening Brief in Support of its Partial Motion to
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`Dismiss, the Declaration of Sarah E. Waidelich, and other pleadings filed in support of this motion.
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`Alliance is not moving to dismiss Counterclaim Count IV at this time, although Alliance
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`maintains that the asserted claims of U.S. Patent No. 10,891,608 also fail to claim eligible subject
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`matter pursuant to Section 101. Alliance reserves all rights to challenge the claims of this patent
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`at an appropriate time.
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`Alliance is not filing an Answer to Count IV at the time of filing this Motion because the
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`Motion tolls the period for answering the entirety of the Counterclaims. Case law supporting this
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`course of action is referenced in Footnote 4 in Alliance’s Opening Brief in Support of its Partial
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`Motion to Dismiss.
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`
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`Case 1:24-cv-00733-MN Document 21 Filed 10/25/24 Page 2 of 2 PageID #: 1472
`
`YOUNG CONAWAY STARGATT & TAYLOR, LLP
`
`/s/ Melanie K. Sharp
`____________________________________________
`Melanie K. Sharp (No. 2501)
`James L. Higgins (No. 5021)
`Stephanie N. Vangellow (No. 7277)
`1000 North King Street
`Wilmington, DE 19801
`(302) 571-6600
`msharp@ycst.com
`jhiggins@ycst.com
`svangellow@ycst.com
`
`HONIGMAN LLP
`Sarah E. Waidelich
`315 East Eisenhower Parkway, Suite 100
`Ann Arbor, MI 48108
`(734) 418-4200
`
`Scott Barnett
`39400 Woodward Avenue, Suite 101
`Bloomfield Hills, MI 48304
`(248) 566-8496
`
`Jenna E. Saunders
`155 North Wacker Drive, Suite 3100
`Chicago, IL 60606
`(312) 701-9322
`
`Dated: October 25, 2024
`
`Attorneys for Plaintiff Alliance Laundry Systems, LLC
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`2
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