Identitii Ltd v. JPMorgan Chase & Co

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Identitii Limited (Australia)
  • Defendant: JPMorgan Chase & Co. (Delaware) and JPMorgan Chase Bank, N.A.
  • Plaintiff’s Counsel: Ashby & Geddes
• Case Identification: 1:23-cv-01095, D. Del., 01/12/2024
• Venue Allegations: Venue is alleged to be proper as Defendant JPMorgan Chase & Co. is a Delaware corporation, and Defendant JPMorgan Chase Bank, N.A. maintains multiple regular and established places of business within the District of Delaware.
• Core Dispute: Plaintiff alleges that Defendant’s Onyx/Liink blockchain-based financial services platform infringes a patent related to a system and method for processing financial transactions by using a token and a distributed ledger to enrich payment data.
• Technical Context: The technology operates in the financial technology (FinTech) sector, aiming to solve data transmission deficiencies in legacy payment networks like SWIFT by creating a secure information overlay using blockchain.
• Key Procedural History: The complaint alleges that Plaintiff confidentially disclosed its patent-pending technology to Defendant between 2015 and 2016. It further alleges that Defendant was notified of its infringement of the issued patent in September 2021, more than two years before the filing of the amended complaint.

Case Timeline

Date	Event
2015-08-14	’413 Patent Priority Date (Australian Provisional Application)
2015-09-XX	Plaintiff alleges it began confidentially disclosing technology to Defendant
2016-08-12	Plaintiff's PCT Application Filed
2020-XX-XX	Defendant’s Onyx platform was formed
2021-04-20	U.S. Patent No. 10,984,413 Issued
2021-09-XX	Plaintiff allegedly notified Defendant of infringement
2024-01-12	First Amended Complaint Filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 10,984,413 - "Computer Implemented Method for Processing a Financial Transaction and a System Therefor"

• Issued: April 20, 2021

The Invention Explained

• Problem Addressed: The patent’s background section describes the difficulty of processing financial transactions through legacy systems, such as SWIFT, which support only fixed-width messages with limited data (’413 Patent, col. 1:39-51; Compl. ¶21). This makes it difficult to transmit the rich data needed for modern regulatory compliance (e.g., Anti-Money Laundering, Know Your Customer), often requiring time-consuming and inefficient out-of-band communication between financial institutions (’413 Patent, col. 1:44-51; Compl. ¶22).
• The Patented Solution: The invention proposes an overlay system that uses a blockchain as a secure, distributed ledger to store an "enriched data record" containing detailed transaction information (’413 Patent, Abstract). A unique "token" is generated, which acts as a pointer to this enriched record on the blockchain (’413 Patent, col. 2:12-15). This token can be transmitted through existing payment networks, allowing authorized parties to use it to securely access the comprehensive and immutable transaction data stored on the blockchain, thereby enhancing the legacy system without replacing it (’413 Patent, col. 26:46-50, Fig. 14).
• Technical Importance: The described technology provides a method for modernizing global payment systems by adding a layer of data integrity and accessibility, which could help financial institutions meet increasingly complex compliance obligations more efficiently (Compl. ¶30, ¶35).

Key Claims at a Glance

• The complaint asserts independent system claim 15 of the ’413 Patent (Compl. ¶59).
• The essential elements of independent claim 15 are:
  • A system comprising a "first intermediary server", a "token server", a "messaging bus", and a "blockchain" (distributed ledger), all operably connected to a network.
  • The "first intermediary server" is configured to transmit documents to a document store, generate an "enriched data record" from those documents, add the record to the blockchain, and request a token from the token server.
  • The "token server" is configured to generate the token, add it to the blockchain in association with the enriched data record, and transmit the token back to the first intermediary server.
• The complaint reserves the right to assert other claims, but its substantive allegations focus on claim 15 (Compl. ¶48).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are Defendant’s Onyx products and services, including the "Liink by J.P. Morgan" platform (the "Liink System") (Compl. ¶48).

Functionality and Market Context

• The Liink System is described as a "peer-to-peer network for secure, privacy-preserving information exchange" and a "bank-led blockchain platform" (Compl. ¶39, ¶51). It is built on a "permissioned blockchain based on the Quorum protocol" and provides customers with "access to a blockchain network [and] hosting infrastructure" (Compl. ¶52). The complaint includes a detailed architectural diagram of the Liink System, which depicts components such as a "DApp (Liink)," "Quorum Nodes," "Transaction Managers," "Enclaves," a "Token server," and a "Blockchain (distributed ledger)" (Compl. ¶53, p. 26). This diagram shows the system architecture for two interacting parties, Party A and Party B. (Compl. ¶53, p. 26).
• The complaint alleges that Defendant markets the Liink System as a novel architecture that "re-architect[s] the way that money, information and assets are moving around the world" by leveraging blockchain and tokenization (Compl. ¶39, ¶42).

IV. Analysis of Infringement Allegations

Claim Chart Summary: The complaint provides a narrative mapping of the elements of claim 15 to the Liink System. A diagram from the complaint illustrates the accused architecture, including a "DApp (Liink)," "Quorum Node," "Transaction Manager," and "Token server" (Compl. ¶61, p. 30).

Claim Element (from Independent Claim 15)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a first intermediary server in a centralised financial system...	The accused system includes a node for a participating bank, comprising a "DApp (Liink)" and a "Quorum Node," which collectively constitute the first intermediary server.	¶61	col. 10:58-65
a token server operably connected to the network;	The accused system generates a token using a token server, which is alleged to be an "enclave and/or a transaction manager" connected to the network.	¶64	col. 13:8-14
a messaging bus in the centralised financial system...	The components of the accused system are communicatively coupled via a network to transfer messages, which is alleged to be the messaging bus.	¶65	col. 11:30-38
a blockchain operably connected to the network, the blockchain being a distributed ledger;	The accused system includes a blockchain, which is described as a "secure, private, permissioned, blockchain-based network" and a distributed ledger.	¶66, ¶52	col. 12:65-13:8
[first intermediary server configured to:] generate an enriched data record from the one or more documents and add the enriched data record into the blockchain;	The accused first intermediary server allegedly generates a "transaction payload" which is the enriched data record, and adds this record to the private state of the Quorum blockchain.	¶68, ¶70	col. 12:40-44
[first intermediary server configured to:] request generation of a token...to the token server, via the messaging bus;	The Liink DApp and node are allegedly configured to request that the enclave and/or transaction manager generate a token via the messaging bus.	¶71	col. 13:8-14
[token server configured to:] generate the token and add the token into the blockchain in association with the enriched data record;	The enclave and/or transaction manager allegedly adds the token to the Quorum blockchain in association with the enriched data record. A provided visual shows a "Payment Message" with an associated token ID.	¶74, ¶72, p. 35	col. 13:8-14
[token server configured to:] transmit the token to the first intermediary server, via the messaging bus.	The accused token server allegedly transmits the generated token to the DApp and node via the messaging bus.	¶75	col. 2:7-12

Identified Points of Contention

• Scope Questions: A primary question will be whether the distributed software components of the Liink System (e.g., a "DApp" plus a "Quorum Node") meet the claim limitation of a "first intermediary server," which the patent specification describes in the context of entire financial institutions, such as banks or brokerages ('413 Patent, col. 10:58-65). Similarly, the mapping of the "token server" to an "enclave and/or a transaction manager" may be contested.
• Technical Questions: The complaint describes the accused system as a "peer-to-peer network" and a "distributed ledger" (Compl. ¶51, ¶66), which raises the question of whether this architecture exists within a "centralised financial system" as required by the claim. The interpretation of "centralised" versus "distributed" will be a key issue.

V. Key Claim Terms for Construction

• The Term: "first intermediary server"

• Context and Importance: The infringement theory depends on mapping this term to a combination of Defendant's software components (a DApp and a Quorum node) (Compl. ¶61). Practitioners may focus on this term because its construction could determine whether the accused system's architecture falls within the claim's scope.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent is for a "computer implemented method," suggesting the claims should be read with a focus on functional computer systems rather than business entities ('413 Patent, Title). The claim itself defines the server structurally as being connected to a network and document store, and functionally by what it is "configured to" do.
  • Evidence for a Narrower Interpretation: The specification repeatedly provides examples of intermediary servers as "financial institutions" such as "banks, investment banks, brokerages, investment companies etc." ('413 Patent, col. 10:58-65). The figures also depict the FIRST INTERMEDIARY SERVER as a single, discrete architectural block (e.g., ’413 Patent, Fig. 1).

• The Term: "centralised financial system"

• Context and Importance: This term appears in multiple limitations of the asserted claim. Its construction is critical because the complaint describes the accused Liink System as a "peer-to-peer" and "distributed" network (Compl. ¶51, ¶66), creating a potential definitional conflict.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent teaches an overlay for existing financial networks. An interpreter could argue that the entire ecosystem, which consists of established financial institutions (centralized entities) using a permissioned blockchain, constitutes a "centralised financial system" in contrast to a public, permissionless cryptocurrency network.
  • Evidence for a Narrower Interpretation: The plain meaning of "centralised" is arguably the opposite of "distributed." An accused "distributed ledger" operating in a "peer-to-peer network" may be argued to fall outside the literal scope of a "centralised... system."

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendant induces infringement by providing customers with instructions, websites, videos, and other support materials that instruct and encourage them to use the Liink System in an infringing manner (Compl. ¶76-77).
• Willful Infringement: The willfulness allegation is based on alleged pre-suit knowledge of the patent. The complaint states that Plaintiff notified Defendant of its infringement in September 2021 and that Defendant continued its allegedly infringing activities despite this notice (Compl. ¶78, ¶81). The complaint also alleges a pre-patent history of confidential disclosures of the technology to Defendant, suggesting long-standing awareness (Compl. ¶13).

VII. Analyst’s Conclusion: Key Questions for the Case

• A core issue will be one of architectural mapping: can the distributed, software-defined components of the accused Liink System (e.g., "DApp", "Quorum Node", "Enclave") be construed to meet the limitations of the more monolithic hardware components recited in Claim 15 (e.g., "first intermediary server", "token server"), particularly when the patent specification often equates such servers with entire financial institutions?
• A second key issue will be one of definitional scope: the case may turn on whether the accused "peer-to-peer" and "distributed ledger" technology can be considered to operate "in a centralised financial system" as required by the claims. The resolution of this apparent tension between "distributed" technology and a "centralised" system will be critical.
• A third area of focus will be evidentiary: the court will require evidence to determine if the accused system’s "transaction payload" and "messaging ID" function in the specific manner required by the claims—namely, that an "enriched data record" is generated from documents and then added to the blockchain, and that a "token" is generated and associated with that specific record.