IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`ALLIANCE LAUNDRY SYSTEMS LLC,
`Plaintiff/Counterdefendant,
`v.
`PAYRANGE LLC,
`Defendant/Counterclaimant
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`C.A. No. 24-733-MN
`JURY TRIAL DEMANDED
`DEFENDANT PAYRANGE LLC’S REPLY IN SUPPORT OF ITS
`MOTION TO PARTIALLY LIFT STAY
`OF COUNSEL:
`James C. Yoon
`Ryan R. Smith
`WILSON SONSINI GOODRICH & ROSATI
`Professional Corporation
`650 Page Mill Road
`Palo Alto, CA 94304
`Tel: (650) 493-9300
`Jamie Y. Otto
`WILSON SONSINI GOODRICH & ROSATI
`Professional Corporation
`953 East Third Street, Suite 100
`Los Angeles, CA 90013
`Tel: (323) 210-2900
`Dated: December 4, 2025
`12589323 / 23372.00002
`David E. Moore (#3983)
`Bindu A. Palapura (#5370)
`Andrew M. Moshos (#6685)
`POTTER ANDERSON & CORROON LLP
`Hercules Plaza, 6th Floor
`1313 N. Market Street
`Wilmington, DE 19801
`Tel: (302) 984-6000
`dmoore@potteranderson.com
`bpalapura@potteranderson.com
`amoshos@potteranderson.com
`Attorneys for Defendant PayRange LLC
`Case 1:24-cv-00733-MN Document 46 Filed 12/04/25 Page 1 of 14 PageID #: 1882
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`TABLE OF CONTENTS
`PAGE
`I. INTRODUCTION .............................................................................................................. 1
`II. ARGUMENT ...................................................................................................................... 2
`A. Maintaining the Stay Will Not Simplify the Issues for Trial, Especially for
`the Non-Instituted Patents and Early Stage Proceedings. ....................................... 2
`1. The PTAB Review Proceedings Are Unlikely to Assist this Court
`in Deciding Invalidity and Infringement Issues. ......................................... 2
`2. PayRange Has Not Made Inconsistent Arguments and Alliance’s
`Arguments Ignore the Actual Timeline of the Proceedings. ....................... 4
`B. Early Stage Does Not Tip the Scale Without Meaningful Expected
`Simplification. ......................................................................................................... 6
`C. Maintaining the Stay Unduly Prejudices PayRange. .............................................. 7
`D. The Court Should, at Minimum, Lift the Stay to Resolve Alliance’s Partial
`Motion to Dismiss ................................................................................................. 10
`III. CONCLUSION ................................................................................................................. 10
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`TABLE OF AUTHORITIES
`PAGE(S)
`CASES
`Aatrix Software, Inc. v. Green Shades Software, Inc.,
`882 F.3d 1121 (Fed. Cir. 2018)............................................................................................3
`Berkheimer v. HP Inc.,
`881 F.3d 1360 (Fed. Cir. 2018)............................................................................................3
`Cuozzo Speed Techs., LLC v. Lee,
`579 U.S. 261 (2016) .........................................................................................................2, 5
`IOENGINE, LLC v. PayPal Holdings, Inc.,
`C.A. No. 18-452-WCB, 2019 WL 3943058 (D. Del. Aug. 21, 2019) .................................4
`Kroy IP Holdings, LLC v. Groupon, Inc.,
`127 F.4th 1376 (Fed. Cir. 2025) ....................................................................................9, 10
`Microsoft Corp. v. i4i Ltd. P’ship,
`564 U.S. 91 (2011) ...............................................................................................................5
`Microsurgical Tech., Inc. v. New World Med., Inc.,
`C.A. No. 20-754-MN (D. Del. Aug. 12, 2021) ....................................................................8
`MQ Gaming, LLC v. Lego Sys., Inc.,
`C.A. No. 19-905-MN, D.I. 145 (D. Del. Feb. 18, 2021) .....................................................8
`Novartis AG v. Noven Pharms. Inc.,
`853 F.3d 1289 (Fed. Cir. 2017)............................................................................................4
`Nuance Comm’cs, Inc. v. MModal LLC,
`C.A. No. 17-1484-MN, D.I. 220 (D. Del. Apr. 1, 2019) .....................................................8
`Quest Diagnostics Investments LLC v. Lab’y Corp. of Am. Holdings,
`C.A. No. 18-1436-MN, D.I. 97 (D. Del. Jan. 14, 2020) ......................................................8
`Sarif Biomedical LLC v. Brainlab, Inc.,
`C.A. No. 13–846–LPS, 2016 WL 5422479 (D. Del. Sep. 27, 2016) ...................................5
`STATUTES
`35 U.S.C. §§ 326(e) .....................................................................................................................2, 5
`35 U.S.C. § 101 ....................................................................................................................1, 2, 3, 7
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`I. INTRODUCTION
`Alliance Laundry Systems LLC (“Alliance”)’s Opposition Brief (D.I. 45, “Opp.”) fails to
`identify any meaningful benefit to maintaining a stay as to all asserted patents. The PTAB denied
`institution of two of the four asserted patents (the ’772 and ’608 Patents), and PayRange LLC’s
`(“PayRange”) motion seeks only to lift the stay as to those non-instituted patents. No matter how
`the PTAB rules, this Court will still need to address infringement, validity, and § 101 issues for
`the ’772 and ’608 Patents. PayRange seeks to use the roughly nine-month period before the PTAB
`issues its final written decisions on the instituted patents to avoid further delaying this case—which
`has already been pending for more than eighteen months. Under this Court’s typical patent
`schedule, claim construction will occur after the PTAB issues its final written decisions; at that
`point, even Alliance would concede the stay should be lifted. Because the litigation must proceed
`regardless—and because the PTAB’s final written decisions will likely issue before this Court
`reaches claim construction—continuing the stay would only delay progress.
`As confirmed by the unrebutted declaration of PayRange’s founder and CEO, Dr. Paresh
`Patel, PayRange and its licensees are suffering ongoing, irreparable harm from Alliance’s
`infringement. D.I. 43 (“Patel Decl.”). Despite the competitive urgency, Alliance waited nearly nine
`months —close to the statutory deadline—to file PGR petitions against the ’920 and ’423 Patents.
`Alliance should not be rewarded for that strategic delay.
`If the Court is disinclined to lift the stay entirely, the Court should at least lift the stay to
`address Alliance’s anticipated renewed motion to dismiss the ’772 Patent; otherwise, fact
`discovery could be delayed for several more months.
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`II. ARGUMENT
`A. Maintaining the Stay Will Not Simplify the Issues for Trial, Especially for
`the Non-Instituted Patents and Early Stage Proceedings.
`The simplification factor favors lifting the stay, and Alliance has not identified any basis
`for a different outcome. First, the PTAB proceedings will not streamline the issues that must be
`litigated in this Court—particularly for the non-instituted patents or the early stages of the case.
`Second, Alliance’s further speculation about future “inconsistent arguments” identifies no
`recognized basis to halt the litigation. And even if the Court believed the PTAB’s final written
`decisions on the ’920 and ’423 Patents might be informative, those decisions are expected in
`August 2026—well before this Court would reach claim construction or invalidity issues under
`the Court’s default schedule and this District’s average timeline for such matters. With no
`meaningful simplification forthcoming from the PTAB, the stay is unnecessary.
`1. The PTAB Review Proceedings Are Unlikely to Assist this Court in
`Deciding Invalidity and Infringement Issues.
`The PTAB proceedings will not meaningfully simplify the issues before this Court. First,
`the PTAB already denied institution of the ’772 and the ’608 Patents. So, the case must proceed
`here regardless. Alliance argues that the PTAB’s claim construction determinations may influence
`this Court’s claim construction determinations. See Opp. 9. However, pursuant to this Court’s
`order (D.I. 37), claim construction briefing and the Markman hearing will only occur after fact
`discovery is complete.
`Second, Alliance’s § 101 challenge to the ’772 Patent must be independently resolved by
`this Court regardless of the PGR outcomes. If Alliance moves to dismiss the ’772 Patent, such a
`motion would require this Court to apply a different record, a different burden, and the
`Alice/Mayo framework—not the PTAB’s preponderance-based analysis under the AIA. See 35
`U.S.C. § 326(e); Cuozzo Speed Techs., LLC v. Lee , 579 U.S. 261, 282 (2016). Whether the
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`asserted claim of the ’772 Patent recites an inventive concept under Alice/Mayo Step Two is a
`fact-dependent inquiry that must be evaluated based on PayRange’s factual allegations and
`evidence presented in this Court. See Berkheimer v. HP Inc. , 881 F.3d 1360, 1369 (Fed. Cir.
`2018) (“Whether something is well-understood, routine, and conventional to a skilled artisan at
`the time of the patent is a factual determination.”); Aatrix Software, Inc. v. Green Shades
`Software, Inc., 882 F.3d 1121, 1125 (Fed. Cir. 2018) (“factual allegations [as] spelled out in the
`proposed second amended complaint, [...] if accepted as true, establish that the claimed
`combination contains inventive components.”) As PayRange alleges, the ’772 Patent contains
`significant advantages over prior art and is inventive. See D.I. 11, ¶¶ 25, 38, 51, 52, 64. Accepting
`PayRange’s allegation as true, this case should be advanced to the discovery stage.
`Although Alliance contends that the PTAB’s determination on the ’423 Patent may
`meaningfully assist this Court in assessing the § 101 eligibility of the ’772 Patent, the PTAB’s
`inventiveness analysis for different claims under a different standard cannot substitute for this
`Court’s independent evaluation of PayRange’s well-pleaded allegations regarding the ’772 Patent.
`See Berkheimer, 881 F.3d at 1368-69. Even if certain claims of the ’772 and ’423 Patents are
`“nearly identical,” as Alliance contends, this Court must address the distinct factual inquiries
`required at the pleadings and summary-judgment stages. Maintaining the stay only postpones a
`determination that the PTAB cannot make. And even if the Court found the PTAB’s reasoning
`persuasive, its final written decisions may arrive before this Court rules on any renewed § 101
`motion, even if the stay were lifted today. Further, if this Court denies Alliance’s anticipated
`motion to dismiss on the ’772 Patent, the Court will have ample opportunity to revisit patent
`eligibility at the summary judgment stage.
`Likewise, the PTAB’s validity assessment of the ’614 Patent (which is not asserted) does
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`not predict how it will treat the distinct claims of the ’920 or ’423 Patents. In fact, although the
`claims of the ’772 Patent are similar to the ’614 Patent, the PTAB denied institution against the
`’772 Patent. This underscores that the unasserted ’614 Patent is unlikely to provide any insight
`into the validity or eligibility of the ’772 or ’608 Patents, which are not subject to PTAB review.
`The Federal Circuit has repeatedly held that the PTAB and district courts may reach different
`conclusions even on closely related patents because the evidentiary records and burdens diverge.
`Novartis AG v. Noven Pharms. Inc., 853 F.3d 1289, 1294-95 (Fed. Cir. 2017) (“It is unsurprising
`that different records may lead to different findings and conclusions.”).
`2. PayRange Has Not Made Inconsistent Arguments and Alliance’s
`Arguments Ignore the Actual Timeline of the Proceedings.
`Alliance devotes Section V.A.1.b of its opposition to the theory that the stay should be
`maintained because PayRange might make “inconsistent arguments” before the PTAB and this
`Court. Alliance’s theory is not a basis to keep this litigation frozen.
`First, courts do not evaluate stays based on speculative concerns about hypothetical
`arguments. The proper inquiry is whether lifting the stay risks inconsistent results, not whether a
`party may tailor its advocacy to the different roles and legal standards of the PTAB and the district
`court. See, e.g., IOENGINE, LLC v. PayPal Holdings, Inc. , C.A. No. 18-452-WCB, 2019 WL
`3943058, at *10-11 (D. Del. Aug. 21, 2019) (noting that the relevant concern is avoiding
`“duplication of effort and possibly inconsistent results” between the PTAB and the district court).
`Alliance cites no authority—and we are aware of none—suggesting that variations in legal or
`technical arguments across forums can justify maintaining a stay. Were that the rule, AIA review
`could never proceed in parallel with district court litigation.
`Second, Alliance’s theory ignores the reality that PTAB and district court proceedings
`necessarily involve different burdens, different evidentiary standards, and different inquiries.
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`PTAB trials assess patentability under a preponderance standard. See 35 U.S.C. § 326(e); Cuozzo,
`579 U.S. at 279. District courts adjudicate infringement and invalidity under clear and convincing
`evidence and apply different procedural rules. Microsoft Corp. v. i4i Ltd. P’ship, 564 U.S. 91, 96
`(2011). Because the forums serve distinct purposes, litigants routinely present arguments
`calibrated to each forum. Indeed, it is “not unusual for a party to refine and revise its claim
`construction positions” over the course of litigation. See Sarif Biomedical LLC v. Brainlab, Inc. ,
`2016 WL 5422479, at *2 (D. Del. Sep. 27, 2016). Thus, this is not a basis for continuing the stay.
`Third, Alliance’s sole example of purported inconsistencies does not support its position.
`Alliance asserts that PayRange previously took a different view of the term “payment button,”
`relying on unsupported inferences drawn from a single annotation in pre-litigation correspondence,
`not any position PayRange has taken in this case. See Opp. 3, 10 (citing D.I. 18, Ex. L at 13). In
`fact, PayRange’s claim interpretation has never wavered. A payment button on its own—as
`exemplified by the Low prior art at issue in the PTAB institution decision—does not “indicate[]
`initiation of the transaction,” as claimed by the ’772 Patent. But the accused products include
`additional functionality, beyond a static payment button, to indicate initiation of the transaction
`and thus infringe.
`Moreover, such correspondence—referenced in PayRange’s Amended Answer and
`Counterclaims in connection with willfulness allegations—are not operative legal or claim-scope
`positions and have no bearing on infringement or claim construction in this Court. See D.I. 18
`(Countercls.) ¶¶ 62-63 (describing PayRange’s notice letter sent to Alliance regarding the ’772
`Patent). There is no record here to be “inconsistent” with: PayRange has not served infringement
`contentions, the parties have not identified any disputed claim terms, and the Court has not been
`asked to construe a single term. Regardless, claim construction in this Court is months away, and
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`any alleged inconsistency can be addressed in the ordinary claim construction briefing. Alliance’s
`lone example therefore does not demonstrate any inefficiency or conflict that justifies continued
`delay.
`Alliance’s IPR petition on the ’772 Patent was denied institution entirely (IPR2025-00573).
`D.I. 42-1. With no pending PTAB proceeding on the ’772 Patent, there is no “risk” to mitigate and
`no justification for continuing to hold that portion of the case in stasis. Maintaining a stay over
`arguments made about a patent for which the PTAB has already declined review cannot promote
`efficiency or prevent inconsistency; it only guarantees further delay.
`Fourth, Alliance’s concern about “inconsistent arguments” loses force when the timelines
`of this litigation and the PTAB proceedings are considered together. As mentioned in Section
`II.1.A, by the time this Court reaches claim construction, the PTAB’s record will be fully
`developed and final written decisions will have issued. At that point, this Court will be able to
`evaluate the PTAB’s analysis with all other intrinsic and extrinsic evidence.
`Finally, Alliance identifies no discovery that depends on claim construction and no real
`risk of duplication. Alliance’s citation to Bayer does not hold otherwise; it merely acknowledges
`that a court may reassess the need for further discovery after Markman. See Opp. 11. Here,
`PayRange’s proposal is aligned with the court’s oral order entered previous in this case—fact
`discovery followed by claim construction—which eliminates any concerns about supposed
`“inconsistent arguments.” Alliance does not identify how PayRange’s proposal deviates from that
`order or creates any prejudice.
`B. Early Stage Does Not Tip the Scale Without Meaningful Expected
`Simplification.
`The early stage of this case does not support maintaining the stay because, even if the
`PTAB ultimately narrows the instituted patents, the not instituted ’772 and the ’608 Patents will
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`proceed in this Court regardless. The cases Alliance cites do not suggest otherwise. SunPower,
`Princeton Digital, and Bonutti each stand for the unremarkable proposition that early-stage stays
`are appropriate when the PTAB proceedings are expected to materially simplify the asserted
`claims. Opp. 11, 12. Here, by contrast, the PTAB proceedings do not cover all the asserted patents
`and, therefore, will not significantly reduce the early-stage discovery the parties must undertake in
`this Court. This Court will be asked to address Alliance’s § 101 challenge to that patent regardless
`of the outcome in the PGRs. And the two instituted PGRs on the ’920 and ’423 Patents cannot
`eliminate the core technical, financial, and damages discovery required in this case, given that the
`’608 Patent has survived Alliance’s IPR challenge and Alliance does not challenge its patent
`eligibility under §101. Continuing the stay would just delay work that must occur regardless of the
`PTAB’s outcomes. Alliance’s cited authorities therefore provide no basis for extending a stay that
`no longer serves its original purpose.
`C. Maintaining the Stay Unduly Prejudices PayRange.
`Alliance argues that PayRange will not suffer any prejudice from maintaining the stay. In
`support, Alliance first argues that it “was diligent in filing petitions for PTAB review of the
`Asserted Patents.” Opp. 12. That is an overstatement. PayRange sent Alliance a letter alleging
`infringement of the ’772 Patent and the then-pending but allowed claims of the ’920 and ’423
`Patents. D.I. 1 ¶ 51. Alliance substantively responded to PayRange’s allegations on April 25, 2024,
`asserting that PayRange’s claims “were likely to be found invalid or unpatentable.” Id. ¶¶ 54-55
`(emphasis added). The ’920 and ’423 Patent issued on April 23 and April 30, 2024, respectively.
`Alliance could have filed PGR review petitions at that time. Instead, Alliance waited until January
`17, 2025 – nearly nine months after expressing its belief that the ’920 and ’423 Patents were
`invalid. Alliance provides no explanation for why it waited nearly nine months to file its PGR
`petitions. Had Alliance filed its PGR petitions in a timely manner, the final written decisions would
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`be imminent.
`Alliance next argues that it diligently raised its request for a stay. Opp. at 13. But the stay
`Alliance requested extended only for the period between institution of the ’920 and ’423 Patents
`and the then-pending institution decisions of the ’772 and ’608 Patents, which were eventually
`denied. Alliance did not affirmatively seek to stay this case pending final written decisions.
`Alliance’s third argument is that “a majority of the asserted claims” have been instituted in
`the two PGRs. Opp. 13. Alliance incorrectly presumes that PayRange will assert every claim
`identified the initial letter requesting licensing discussions. To the contrary, PayRange intends to
`assert a handful of claims of the not-instituted patents, rendering Alliance’s argument invalid.
`Relatedly, Alliance argues that this Court has granted stays where not all claims were
`subject to instituted PTAB proceedings. Id. The cases cited by Alliance all involve markedly
`different circumstances. See, Nuance Comm’cs, Inc. v. MModal LLC, C.A. No. 17-1484-MN, D.I.
`220 (D. Del. Apr. 1, 2019) (motion to stay was set to be heard during the claim construction
`hearing); MQ Gaming, LLC v. Lego Sys., Inc. , C.A. No. 19-905-MN, D.I. 145 (D. Del. Feb. 18,
`2021) (trial was scheduled to commence before issuance of the final written decisions); Quest
`Diagnostics Investments LLC v. Lab’y Corp. of Am. Holdings, C.A. No. 18-1436-MN, D.I. 97 (D.
`Del. Jan. 14, 2020) (the Court issued claim construction order before motion to stay);
`Microsurgical Tech., Inc. v. New World Med., Inc., C.A. No. 20-754-MN (D. Del. Aug. 12, 2021)
`(the motion to stay was heard contemporaneous with claim construction briefing after the PTAB
`instituted review of 5 of the 6 asserted patents). All these cases present a competing schedule
`between the PTAB’s result and this court’s trial or claim construction proceeding. Here, the claim
`construction hearing would occur after issuance of the final written decisions for the ’920 and ’423
`Patents.
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`Next, Alliance relies on attorney argument to dispute that it competes directly with
`PayRange. But the declaration of PayRange’s founder and CEO, Paresh Patel, stands unrebutted.
`Dr. Patel confirmed that the parties’ head-to-head competition means each month of delay permits
`Alliance to capture customers and further erode pricing across the entire laundry industry. Patel
`Decl. ¶ 2. Alliance also disputes that its head-to-head competition harms PayRange. Alliance
`argues that this is so because there are “a number of active firms in the relevant market.” Opp. 14.
`As Dr. Patel explained, PayRange’s other competitors have agreed to a royalty bearing license.
`Patel Decl. ¶ 4. Consequently, their costs are elevated since they must pay for PayRange’s patented
`technology. Id. ¶ 5. As the lone hold-out, Alliance is benefiting from lower overhead, allowing it
`to undercut the other market participants. Id. ¶¶ 5-6. This is precisely the irreparable harm that
`PayRange suffers on a monthly basis if the case does not proceed.
`Alliance’s next assertion that that it will be prejudiced if the Court lifts the stay is similarly
`unfounded. Opp. 15. Alliance incorrectly asserts that it would be forced “to expend significant
`resources litigating patents that are likely to be found invalid or ineligible before trial.” Id. This
`argument overlooks the reality that PayRange is seeking to partially lift the stay only as to the ’772
`and ’608 Patents, which are not subject to any PTAB proceedings. A continued stay would not
`obviate any work as to these patents.
`Finally, Alliance argues that even if PayRange is being prejudiced, the prejudice is not
`“undue.” Opp. 15. Alliance contends that the PTAB found the ’920 and ’423 Patents are likely
`invalid. As explained previously, PayRange is not seeking to lift the stay as to those patents.
`Alliance goes on to argue that the PTAB’s preliminary findings apply equally to the ’772 Patent.
`Not so. A finding of unpatentability in PTAB proceeding does not collaterally estop a patent holder
`from alleging infringement in district court based on other closely related patents. See, Kroy IP
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`Holdings, LLC v. Groupon, Inc., 127 F.4th 1376, 1379-81 (Fed. Cir. 2025). In other words, even
`if the ’920 and ’423 Patents are held unpatentable by the PTAB, this Court (and possibly a jury)
`must analyze validity under a more exhausting clear and convincing standard.
`D. The Court Should, at Minimum, Lift the Stay to Resolve Alliance’s Partial
`Motion to Dismiss
`Alliance’s argument about refiling its motion to dismiss underscores the need to lift the
`stay. This case has been pending nearly eighteen months. Alliance proposes to maintain the stay
`for nine more months and then, once the stay is lifted, file a partial motion to dismiss the ’772
`Patent—after which it would not proceed with fact discovery until that motion is resolved. Opp.
`18, 19. That scheduling proposal would substantially delay the case. Therefore, even if the Court
`is disinclined to lift the stay for fact discovery now, it should at minimum lift the stay so the parties
`can fully brief Alliance’s renewed motion to dismiss the ’772 Patent. The stay should be lifted in
`its entirety upon the earlier of (a) resolution of that motion and (b) issuance of final written
`decisions as to the ’920 and ’423 Patents.
`III. CONCLUSION
`Because the PTAB proceedings will not meaningfully simplify the early stages of this
`litigation—particularly for the non-instituted patents—and because continued delay would
`prejudice PayRange, the circumstances warrant lifting the stay. PayRange respectfully asks the
`Court to grant its motion and permit the case to move forward. If the Court is not inclined to fully
`lift the stay at this time, PayRange agrees with Alliance that a partial stay allowing Alliance to
`promptly refile its Rule 12(b)(6) motion to dismiss the ’772 Patent is the appropriate and efficient
`alternative.
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`Respectfully submitted,
`OF COUNSEL:
`James C. Yoon
`Ryan R. Smith
`WILSON SONSINI GOODRICH & ROSATI
`Professional Corporation
`650 Page Mill Road
`Palo Alto, CA 94304
`Tel: (650) 493-9300
`Jamie Y. Otto
`WILSON SONSINI GOODRICH & ROSATI
`Professional Corporation
`953 East Third Street, Suite 100
`Los Angeles, CA 90013
`Tel: (323) 210-2900
`Dated: December 4, 2025
`12589323 / 23372.00002
`POTTER ANDERSON & CORROON LLP
`By: /s/ David E. Moore
`David E. Moore (#3983)
`Bindu A. Palapura (#5370)
`Andrew M. Moshos (#6685)
`Hercules Plaza, 6th Floor
`1313 N. Market Street
`Wilmington, DE 19801
`Tel: (302) 984-6000
`dmoore@potteranderson.com
`bpalapura@potteranderson.com
`amoshos@potteranderson.com
`Attorneys for Defendant PayRange LLC
`12589323v.1
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