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`Case 6:24-cv-00340-AM-DTG Document 1-6 Filed 06/24/24 Page 1 of 136
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`EXHIBIT 6
`EXHIBIT 6
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`CONFIDENTIAL – SUBJECT TO FRE 408
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`March 20, 2024
`
`Justin J. Lesko, Esq.
`Registered Patent Attorney
`Admitted in Illinois
`JustinLesko@PatentIt.com
`Direct: (773) 484-3285
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`VIA PRIORITY MAIL AND EMAIL
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`
`Yair Nechmad
`Chief Executive Officer
`Nayax Ltd.
`Executive Plaza 1, 11350 Mccormick Road,
`Hunt Valley, Maryland 21031
`Email: yair@nayax.com
`
`
`Re:
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`Infringement of the PayRange Inc. Patent Portfolio
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`
`Dear Mr. Nechmad:
`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 Nayax Ltd. (hereinafter, “Nayax”), with an explanation of the scope of PayRange’s patent
`portfolio, to place Nayax on notice that it infringes numerous issued and allowed claims of
`PayRange’s IP in connection with its Monyx Wallet mobile app 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 Nayax 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 Nayax 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 Nayax
`raises.
`In return, we expect that Nayax will also address the matter promptly and in good faith. If
`Nayax 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
`Nayax to work with us to address appropriate terms for a license or other business resolution.
`Nayax 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 Nayax has any interest in resolving this matter 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 Nayax informed on a rolling basis, we encourage Nayax
`
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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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`to itself continue to monitor the public court and USPTO proceedings relating to PayRange’s
`patent enforcement and prosecution activities.
`We request that Nayax 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 Nayax, and (2) patents in the
`vending/laundry mobile payment space with claims confirmed during post-grant review
`proceedings at the USPTO that may be infringed by Nayax. 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 Nayax
`Based on a review of the publicly available materials describing Nayax’s vending and
`laundry mobile payment systems, we have determined that Nayax infringes multiple claims of
`PayRange’s issued patents and pending and allowed patent applications in connection with the
`“Monyx Wallet” mobile application and payment system, either directly, through contributory
`infringement, or by inducement. Specifically, we have determined that Nayax infringes at least
`the following claims:
`• Claim 11 of U.S. Patent No. 11,481,772;
`• Pending and allowed claims 1-6, 8, 9, 11-20 of U.S. Patent Application No. 18/197,070;
`and
`• Pending and allowed claims 1-6, 8, 9, 12-20 of U.S. Patent Application No. 18/197,071.
`
`
`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/9655b2hww4mvs865snrpyin7trrvy949 (Password: “NAY2303R”)
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`www.PatentIt.com | info@patentit.com
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`PATENT IT!®
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`PayRange provides as Exhibits B, C and D detailed claim infringement charts
`demonstrating Nayax’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, Nayax is responsible for provisional damages if it infringes
`PayRange’s published claims that issue as a patent without substantive change. Accordingly,
`Nayax 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 in Appendix
`1 and included on the file share folder identified in footnote 1. However, to help Nayax review
`this matter efficiently, we also provide below a brief summary of Nayax’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. Nayax makes, uses, sells, and offers for sale the “Monyx
`Wallet” app on the Google Play Store and the Apple App store as shown in Figures 1 and 2 below:
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`Figure 1. The Monyx Wallet app on the
`Google Play store, showing over 100,000
`Downloads.
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`Figure 2. The Monyx Wallet app on the Apple
`app store .
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`By itself using those apps on mobile devices to carry out the method recited in claim 11, Nayax
`directly infringes claim 11 of the ‘772 patent under 35 U.S.C. § 271(a). Nayax 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, Nayax intends to cause its business partners and
`customers to infringe by actively encouraging its business partners and customers to use the
`Monyx Wallet app in a manner that meets all of the elements of claim 11 of the ’772 Patent. Nayax
`also contributes to infringement of the ’772 patent under 35 U.S.C. § 271(c) because the Monyx
`Wallet app is a component of a patented machine or an apparatus used in practicing a patented
`process, constituting a material part of PayRange’s invention, with Nayax 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
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`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. Nayax makes, uses, sells, and offers for sale both
`the Monyx Wallet 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, the Monyx Wallet
`app displays payment accepting vending machines, displays their numerical identifiers, and
`receives a selection of a vending machine, as shown in Figures 3 and 4 below:
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`Figure 3. The Monyx Wallet app displays
`payment accepting vending machines, displays
`their numerical identifiers, and receives a
`selection of a vending machine.
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`
`Figure 4. Vending machine number 69312048
`has been selected.
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`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.” The Monyx Wallet app meets all of these claim elements.
`Specifically, the Monyx Wallet app establishes a wireless (e.g., cellular) communication
`path with a vending machine via cloud servers and displays a visual representation of the vending
`machine (i.e., “69312048 - Snacks”), an indication of a balance (such as the Monyx card balance),
`and a user option to “Pay,” as shown below in Figure 5:
`
`
`Figure 5. The Monyx Wallet app establishes a wireless (e.g., cellular)
`communication path with a vending machine via cloud servers and
`displays a visual representation of the vending machine (i.e., “69312048
`- Snacks”), an indication of a balance (such as the Monyx card balance),
`and a user 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. The
`Monyx Wallet app displays an updated user interface when the “Pay” button is selected, which
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`also causes the mobile phone to exchange information with the vending machine. Specifically,
`the updated user interface shows either “Choose a product” (so that the user can choose the
`product at the vending machine) as shown in Figure 6 below or a list of products from the
`vending machine that can be selected and purchased as shown in Figure 7 below.
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`Figure 6. The Monyx Wallet app displays a
`“Choose a product” screen after information is
`exchanged with the vending machine when the
`“Pay” button is selected.
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`Figure 7. The Monyx Wallet app displays a
`list of products that can be purchased from the
`vending machine after information is
`exchanged with the vending machine when the
`“Pay” button is selected.
`The updated user interface also shows a receipt when the transaction is complete as
`shown in Figure 8 below.
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`Figure 8. Monyx Wallet dislpays a receipt for the transaction.
`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.” Nayax infringes that element, at least under the doctrine of equivalents, because
`the Monyx Wallet app displays the “Pay” button shown in Figure 5 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 Nayax 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 Nayax’s mass adoption of these same features in its products, and
`its focus on the technology in its advertising campaigns, we believe that Nayax ultimately agrees
`with that assessment. From the charts, Nayax should also be able to readily recognize that similar
`infringing systems are also employed by the direct competitors of Nayax, 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 Nayax raises regarding the infringement assertions, including PayRange’s
`
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`www.PatentIt.com | info@patentit.com
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`infringement charts, via a telephone call or online meeting. We strongly encourage Nayax 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 vending/laundry mobile payment patents
`To further assist Nayax 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 vending/laundry 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, Nayax 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 Nayax:
`• 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 Nayax, and they further specify that the mobile payment
`application is “configured to identify one or more vending machines in proximity to
`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 Nayax uses or has used predefined radio messages, such as Bluetooth,
`WIFI, or NFC, to identify machines in its payment applications, Nayax 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 Nayax provides or has provided an application that obtains funds
`preauthorization using these methods, Nayax 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.
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`o To the extent that Nayax provides or has provided such payment modules for
`converting coin-operated machines, Nayax potentially infringes one or more of these
`claims.
`Again, we are prepared to address in detail any questions that Nayax 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.
`e.g.,
`https://www.prnewswire.com/news-releases/payrange-settles-patent-dispute-with-
`See,
`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. 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. See,
`e.g.,
`https://www.prnewswire.com/news-releases/payrange-files-patent-infringement-lawsuit-
`against-csc-serviceworks-302081204.html.
`Clearly, PayRange is committed to licensing infringers in the vending/laundry mobile
`payment industry, including Nayax. PayRange has written letters, or is in the process of writing
`letters, to many other companies in this industry 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, Nayax should be able to promptly and efficiently determine
`how it wishes to resolve this matter.
`
`
`
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`However, Nayax 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).
`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).
`
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`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 Nayax 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 multitude
`of commercially significant inventions disclosed and described in its specification, but not yet
`claimed in its existing patents and applications.
`Nayax should expect additional claims and patents to issue to PayRange in the near future.
`We suggest that Nayax 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.
`
`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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`www.PatentIt.com | info@patentit.com
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`PATENT IT!®
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`

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`March 20, 2024
`Page 12
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`V. CONCLUSION
`We have provided Nayax with the documents and materials necessary to review this matter
`and understand PayRange’s assertions. We request that Nayax 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 Nayax wishes to raise. Our technical team is available to discuss the claim
`infringement charts and to address any technical questions Nayax may have. We invite Nayax 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 Nayax. We can assure Nayax that PayRange’s licensing terms are reasonable.
`In addition, if Nayax 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 Monyx Wallet app and payment systems to its
`customers, Nayax is actively inducing those customers to directly infringe PayRange’s patents.
`By negotiating a license with PayRange, Nayax can resolve some of its customer’s direct liability
`to PayRange and fulfill any potential indemnity obligations that Nayax has for those customers,
`which may be substantial.
`We look forward to hearing from you, and to working with Nayax to address the matters
`raised in this letter. However, if we do not hear promptly from Nayax, we will assume it has no
`desire to resolve the matter informally.
`
`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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`www.PatentIt.com | info@patentit.com
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`PATENT IT!®
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`

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`APPENDIX 1
`TABLE OF EXHIBITS AND REFERENCES
`
`List of PayRange Patents and Pending Applications
`Exhibit A
`Nayax Claim Infringement Chart for U.S. Patent No. 11,481,772
`Exhibit B
`Nayax Claim Infringement Chart for U.S. Patent Application No. 18/197,070
`Exhibit C
`Nayax Claim Infringement Chart for U.S. Patent Application No. 18/197,070
`Exhibit D
`Reference 1 Users - Monyx
`Reference 2
`FAQ - Monyx
`Reference 3 Nayax YouTube - Touch-Free Selection wiht Monyx Wallet from Nayax for
`MDB 4_3
`Reference 4 Nayax YouTube - How to Add a Loyalty Program to Your Unattended
`Business
`Reference 5 Monyx Wallet App on the Google Play Store
`Reference 6 Monyx Wallet App on the Apple App Store
`Reference 7
`iPhone 15 Pro and 15 Pro Max - Technical Specifications - Apple
`Reference 8
`Samsung Galaxy S24 Technical Specifications
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`March 20, 2024
`Page 13
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`www.PatentIt.com | info@patentit.com
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`PATENT IT!®
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`

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`PayRange, Inc. Issued Patents
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`EXHIBIT A
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`10/25/2022
`
`Issue Date Title
`5/23/2023 Controlled dispensing