Last week, Scancomm LLC filed suit against Microsoft (6:23-cv-00634) in the Western District of Texas, alleging infringement of a single patent through the provision of a mobile device (highlighting in the complaint the Surface Duo 2) “with the Skype app and/or LinkedIn app”. The day after that complaint, Scancomm sued Microsoft subsidiary LinkedIn directly (1:23-cv-03856), this time in the Northern District of Georgia, alleging infringement of the same patent through the provision of the LinkedIn app more generally. Unlike West Texas, the Northern District of Georgia requires the disclosure, upon first appearance, of all nonparties with an interest in the outcome of the case; Scancomm has nevertheless filed the same disclosure—a bare corporate disclosure indicating no parent and no significant ownership by a public corporation—in connection with each suit.

PayPal (6:23-cv-00009) is the latest defendant to be added to the litigation that Scancomm LLC—a plaintiff that appears to be connected to a familiar patent monetization figure—launched in July 2022 with a suit against Samsung, followed by a December case against ByteDance (TikTok). In the new Eastern District of Texas complaint, the plaintiff asserts a single patent generally related to “establishing a two-way communication” between users of a mobile application by scanning a “code symbol” embedded with a “digital identification code”. PayPal is accused of infringement through the provision of the PayPal and Venmo payment platforms, with features for sharing contact information and making transactions through QR codes at issue.

On July 25, Western District of Texas Chief Judge Orlando L. Garcia shook up the patent status quo by issuing a new standing order that may end District Judge Alan D. Albright’s time as the nation’s top patent judge. While plaintiffs could previously select Judge Albright by filing directly in the Waco Division, where he is the only district judge, the order now requires that all patent cases filed there be randomly assigned among a group of 12 judges from throughout the district, including Judge Albright. Filing levels have now begun to drop in West Texas as result, while Judge Albright’s new caseload has unsurprisingly started to dry up as well.

Last week, RPX reported that “Assignment Records Reveal a Pipeline of Gross Patents”. Now, one of the patent recipients covered, ScanComm LLC, has filed its first litigation, suing Samsung (2:22-cv-00281) over smartphones that support QR code scanning to obtain contact information. A single patent—generally related to establishing a two-way communication” between users of a mobile application by scanning a “code symbol” embedded with a “digital identification code”—is asserted in the new Eastern District of Texas complaint.

With the first half of 2022 in the rearview, a list of the year’s top NPEs—by number of defendants added to litigation—is coming into focus. A web of plaintiffs, tied by their association with a single patent monetization professional, appears poised to land on that list, having collectively added more than 30 defendants to litigation so far this year. Given the pipeline of patents apparently flowing into the same operation, its trajectory looks likely to continue through the second half of 2022.