Federal Circuit Recordings
PerDiemCo LLC v. NexTraq LLC
Appeal No. 25-1215
Summary
In PerDiemCo LLC v. NexTraq LLC, PerDiem accused NexTraq’s fleet-management products and services of infringing patents covering electronic logging and computerized vehicle-tracking technology. The appeal concerned eighteen claims across five patents, including enterprise-centric claims that use multiple levels of administrative privileges to control access to vehicle-event information and device-centric claims that synchronize electronic logging with vehicle power-up. The district court dismissed the claims under Rule 12(b)(6) as patent-ineligible under 35 U.S.C. § 101, treating claim 1 of the ’662 patent and claim 1 of the ’689 patent as representative of all five patents even after concluding that NexTraq had not adequately established representativeness. On appeal, AddyHart argued that the court improperly conducted its own representative-claim analysis without giving PerDiem an opportunity to respond, overlooked material differences among the asserted claims, and failed to credit PerDiem’s well-pleaded allegations that the claimed systems improved the security, flexibility, and accuracy of computerized vehicle tracking. The Federal Circuit heard oral argument and affirmed the district court’s judgment without a written opinion under Federal Circuit Rule 36.
Decisions
PerDiemCo LLC v. NexTraq LLC, No. 1:23-cv-03722-MHC, slip op. (N.D. Ga. Sept. 26, 2024).
PerDiemCo LLC v. NexTraq LLC, No. 1:23-cv-03722-MHC (N.D. Ga. Oct. 23, 2024) (final judgment).
PerDiemCo LLC v. NexTraq LLC, No. 2025-1215 (Fed. Cir. May 15, 2026) (per curiam) (nonprecedential) (affirming pursuant to Federal Circuit Rule 36).
PerDiemCo LLC v. NexTraq LLC
Appeal No. 24-1621
Summary
In PerDiemCo LLC v. NexTraq LLC, PerDiem accused NexTraq’s fleet-management products and services of infringing thirty claims across seven patents directed to computerized location-tracking systems. The asserted technology used tiered administrative privileges and access controls to allow different groups—such as companies managing vehicle fleets—to define their own geofences and events, determine who would receive resulting alerts, and protect the privacy of location and event information. The district court dismissed the complaint under Rule 12(b)(6), holding the claims patent-ineligible under 35 U.S.C. § 101 after treating the claims of the ’941 patent as representative of all asserted claims. On appeal, AddyHart argued that the court improperly reduced the claims to the abstract idea of collecting, analyzing, and distributing geolocation information, failed to credit PerDiem’s allegations that the claimed architecture improved the flexibility, security, and efficiency of prior location-aware networks, and disregarded relevant prosecution history and a prior ruling involving related patents. PerDiem also argued that, after finding NexTraq had not established representativeness, the court improperly conducted its own representative-claim analysis without giving PerDiem notice or an opportunity to respond. The Federal Circuit affirmed without a written opinion under Federal Circuit Rule 36.
Decisions
PerDiemCo LLC v. NexTraq LLC, No. 1:23-cv-00193-MHC, slip op. (N.D. Ga. Mar. 13, 2024).
PerDiemCo LLC v. NexTraq LLC, No. 1:23-cv-00193-MHC (N.D. Ga. Mar. 13, 2024) (final judgment).
PerDiemCo LLC v. NexTraq LLC, No. 2024-1621, judgment at 2 (Fed. Cir. May 15, 2026) (per curiam) (nonprecedential) (affirming under Fed. Cir. R. 36).
Mozido, Inc. v. Apple Inc.
Appeal No. 24-1742.
Summary
In Mozido, Inc. v. Apple Inc., Apple challenged claims of Mozido’s U.S. Patent No. 9,189,785, which covers processing debit payments using information embedded in a scannable code, such as a QR code. The Patent Trial and Appeal Board found claims 1–4, 6–11, 13–18, 20, and 21 obvious over the asserted prior art but upheld claims 5, 12, and 19. On appeal, Mozido argued that the challenged claims require the scannable code to contain three distinct pieces of debit-network information: the user’s preferred network, the provider’s preferred network, and the network ultimately selected to process the transaction. According to Mozido, the Board improperly relied on the same prior-art disclosure to satisfy both the user-preferred-network and selected-network limitations, even though the claim language, specification, and prosecution history required the selected network to be separately embedded in the code. Mozido also argued that the Board violated the Administrative Procedure Act by refusing to consider this argument as improperly raised in sur-reply, even though Mozido had presented it throughout the IPR proceeding. The Federal Circuit affirmed the Board’s decision without a written opinion under Federal Circuit Rule 36.
Decisions
Apple Inc. v. Mozido, Inc., IPR2022-01150, Paper 24, at 48–49 (P.T.A.B. Jan. 2, 2024) (final written decision).
Mozido, Inc. v. Apple Inc., No. 2024-1742, judgment at 2 (Fed. Cir. Feb. 11, 2026) (per curiam) (nonprecedential) (affirming pursuant to Federal Circuit Rule 36).
Mozido, Inc. v. Apple Inc.
Appeal No. 24-1741
Summary
In Mozido, Inc. v. Apple Inc., Apple challenged all thirteen claims of Mozido’s U.S. Patent No. 10,223,692, which covers a mobile-wallet interface that allows a user to select a temporary payment card, displays the time remaining to use that card, and gradually moves the card image back toward its original position as the payable time expires. The Patent Trial and Appeal Board held all thirteen claims obvious based on combinations that relied on Tedesco, a reference concerning graphical scheduling aids for developmentally disabled individuals, together with references involving virtual wallets and temporary payment cards. On appeal, Mozido argued that Tedesco was not analogous art because its problem—helping developmentally disabled individuals and their caregivers manage transitions between daily activities—was not reasonably pertinent to the patent’s problem of making it easier and more intuitive to select and reset temporary payment cards. Mozido also argued that the Board improperly formulated its own problem statement based on the invention’s solution, failed to consider Mozido’s reasonable-pertinence evidence and arguments, and shifted Apple’s burden of proving analogous art to Mozido. The Federal Circuit affirmed the Board’s decision without a written opinion under Federal Circuit Rule 36.
Decisions
Apple Inc. v. Mozido Corfire-Korea, Ltd., IPR2022-01149, Paper 24 (P.T.A.B. Dec. 27, 2023) (final written decision).
Mozido, Inc. v. Apple Inc., No. 2024-1741, judgment at 2 (Fed. Cir. Dec. 8, 2025) (per curiam) (nonprecedential) (affirming pursuant to Federal Circuit Rule 36).
Google LLC v. Sonos, Inc.
Appeal No. 24-1097
Summary
In Google LLC v. Sonos, Inc., Sonos appealed rulings concerning patents covering two types of smart-speaker technology: “zone scenes,” which allow users to create, save, and invoke overlapping groups of speakers for synchronized playback, and “direct control,” which allows a smartphone or similar device to transfer responsibility for playing a cloud-based media queue to a selected speaker. After a jury found that Google infringed a zone-scene patent and awarded Sonos approximately $32.5 million, the district court set aside the result, holding the zone-scene patents invalid for lack of written-description support and unenforceable under prosecution laches because Sonos did not pursue claims expressly covering overlapping speaker groups until 2019. Sonos argued on appeal that its 2006 and 2007 applications already disclosed overlapping zone scenes, that its ordinary continuation practice did not constitute unreasonable delay, and that Google had not shown prejudice. The Federal Circuit agreed, holding that the earlier specification adequately described overlapping zone scenes and that Google failed to establish the prejudice required for prosecution laches. The court therefore reversed the invalidity and unenforceability rulings concerning the zone-scene patents, but affirmed the separate ruling that claims of Sonos’s direct-control patent were obvious over Google’s earlier YouTube Remote system and related patent.
Decisions
Sonos, Inc. v. Google LLC, No. 20-cv-06754-WHA, 2023 WL 2962400 (N.D. Cal. Apr. 13, 2023) (granting summary judgment of invalidity as to the direct-control patent).
Sonos, Inc. v. Google LLC, Nos. 20-cv-06754-WHA, 21-cv-07559-WHA, 2023 WL 6542320, at *30 (N.D. Cal. Oct. 6, 2023) (holding the zone-scene patents invalid and unenforceable).
Google LLC v. Sonos, Inc., No. 2024-1097, slip op. at 19 (Fed. Cir. Aug. 28, 2025) (nonprecedential) (reversing in part and affirming in part).
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Swarm Technology LLC v. Amazon.com, Inc. +
Appeal No. 23-2323
Summary
In Swarm Technology LLC v. Amazon.com, Inc., Swarm and Amazon appealed two Patent Trial and Appeal Board decisions concerning related patents directed to parallel-processing computer systems in which co-processors retrieve and complete tasks from a shared task pool. The Board held claims 1–12 of Swarm’s U.S. Patent No. 9,852,004 unpatentable as obvious and denied Swarm’s contingent motion to add substitute claims, but separately concluded that Amazon had not shown any challenged claims of U.S. Patent No. 10,592,275 unpatentable. On appeal, AddyHart argued for Swarm that the prior art did not disclose agents configured to search the task pool for appropriate tasks and that the Board improperly rejected Swarm’s proposed substitute claims for lack of patent eligibility and written-description support. Amazon cross-appealed, challenging the Board’s construction of “proactively” in the ’275 patent. The Federal Circuit affirmed both decisions, holding that substantial evidence supported the obviousness determination for the ’004 patent and the denial of Swarm’s motion to amend for lack of written-description support, while also upholding the Board’s construction of “proactively” and its determination that Amazon had not proved the ’275 patent claims unpatentable. Meredith Addy presented oral argument for Swarm.
Decisions
Amazon.com, Inc. v. Swarm Technology LLC, IPR2022-00283, Paper 43 (P.T.A.B. June 20, 2023) (final written decision).
Amazon.com, Inc. v. Swarm Technology LLC, IPR2022-00633, Paper 36 (P.T.A.B. Aug. 28, 2023) (final written decision).
Swarm Technology LLC v. Amazon.com, Inc., Nos. 2023-2323, 2024-1095, slip op. at 18 (Fed. Cir. June 30, 2025) (nonprecedential).
Fintiv, Inc. v. Apple Inc. +
Appeal No. 23-2208
Summary
In Fintiv, Inc. v. Apple Inc., Fintiv accused Apple’s Wallet and Apple Pay products of infringing U.S. Patent No. 8,843,125, which covers systems for provisioning and managing payment cards and corresponding “widgets” in a mobile-wallet application. The district court granted summary judgment of noninfringement after concluding that Fintiv had failed to identify specific software or source code constituting the claimed widget. On appeal, AddyHart argued that source code was not the only permissible evidence of infringement and that Fintiv’s expert testimony, product testing, screenshots, Apple documents, and other circumstantial evidence created a genuine factual dispute as to whether Apple’s products contained the claimed widget software. The Federal Circuit reversed, holding that Fintiv had presented sufficient evidence for a reasonable jury to find that software underlying the Apple Wallet interface allowed users to interact with virtual payment cards and therefore satisfied the district court’s broad construction of “widget.” The court remanded the case for further proceedings, while leaving the district court to consider whether the alleged widget satisfied the remaining claim limitations and Apple’s other noninfringement arguments. Meredith Addy presented oral argument for Fintiv.
Decisions
Fintiv, Inc. v. Apple Inc., No. 1:21-cv-00896-ADA, 2023 WL 4237356, at *5 (W.D. Tex. June 21, 2023) (granting summary judgment of noninfringement).
Fintiv, Inc. v. Apple Inc., No. 1:21-cv-00896-ADA (W.D. Tex. June 29, 2023) (final judgment).
Fintiv, Inc. v. Apple Inc., No. 2023-2208, slip op. at 13 (Fed. Cir. May 16, 2025) (nonprecedential) (reversing and remanding).
Fintiv, Inc. v. Apple Inc. +
Appeal No. 24-1345
Summary
In Fintiv, Inc. v. Apple Inc., Fintiv appealed a Patent Trial and Appeal Board decision holding claims 1–3 of U.S. Patent No. 9,892,386 unpatentable as obvious. The patent covers a mobile monetary-transaction system that allows subscribers, including individuals without conventional bank accounts, to deposit, withdraw, and transfer funds through mobile-wallet applications. On appeal, AddyHart argued that the Board interpreted “auditing financial transactions” more broadly than the record supported, improperly treated the use of a transaction identifier to execute a payment as an audit of the transaction, and incorrectly found that the prior art disclosed depositing funds into a subscriber’s own account by assuming the sender and recipient could be the same person in the same transaction. The Federal Circuit did not reach those patentability arguments. In a related appeal decided the same day, the court held claims 1–3 of the ’386 patent invalid as indefinite; because that ruling eliminated any live dispute over whether the same claims were also unpatentable as obvious, the court dismissed this appeal as moot. Meredith Addy presented oral argument for Fintiv.
Decisions
Apple Inc. v. Fintiv, Inc., IPR2022-00976, Paper 27 (P.T.A.B. Nov. 8, 2023) (final written decision determining claims 1–3 unpatentable).
Fintiv, Inc. v. Apple Inc., No. 2024-1345, slip op. at 2 (Fed. Cir. Apr. 30, 2025) (nonprecedential) (dismissing the appeal as moot).
Fintiv, Inc. v. PayPal Holdings, Inc. +
Appeal No. 23-2312
Summary
In Fintiv, Inc. v. PayPal Holdings, Inc., Fintiv accused PayPal of infringing four patents covering cloud-based mobile-wallet and monetary-transaction systems. The district court held that the claim terms “payment handler” and “payment handler service” were means-plus-function limitations governed by 35 U.S.C. § 112 ¶ 6 and that the asserted claims were indefinite because the specifications did not disclose sufficient corresponding structure. On appeal, AddyHart argued that “payment handler” identified a recognized class of software structures, particularly when read alongside the patents’ descriptions of API wrapping, payment processing, and data flows, and that PayPal had not overcome the presumption against means-plus-function treatment. Fintiv alternatively argued that the specifications disclosed a sufficient two-step algorithm in which the payment handler wraps the APIs of different payment processors and exposes a common API for interacting with them. The Federal Circuit affirmed in a precedential opinion, holding that “handler” functioned as a nonce term comparable to “module,” that the word “payment” merely described the handler’s function, and that the purported two-step algorithm restated the claimed results without adequately explaining how the functions were performed. Meredith Addy presented oral argument for Fintiv.
Decisions
Fintiv, Inc. v. PayPal Holdings, Inc., No. 6:23-cv-00490-ADA, 2023 WL 5423082, at *10 (W.D. Tex. July 21, 2023) (holding the payment-handler limitations indefinite).
Fintiv, Inc. v. PayPal Holdings, Inc., No. 6:23-cv-00490-ADA (W.D. Tex. July 28, 2023) (final judgment).
Fintiv, Inc. v. PayPal Holdings, Inc., 134 F.4th 1377 (Fed. Cir. 2025) (affirming).
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