Cedar Lane Tech Inc v. Horace Mann Educators Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cedar Lane Technologies Inc. (Canada)
  • Defendant: Horace Mann Educators Corporation (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 1:25-cv-14404, N.D. Ill., 11/25/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Illinois because Defendant maintains an established place of business in the district and has allegedly committed acts of patent infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s unidentified products and services infringe a patent related to electronic trading systems that generate conditional offers based on a participant's trading history.
• Technical Context: The patent addresses electronic trading platforms, aiming to enable semi-anonymous, informed pricing by allowing liquidity providers to make offers based on a counterparty's historical trading profile.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 8,577,782 - "Trading with conditional offers for semi-anonymous participants"

• Patent Identification: U.S. Patent No. 8,577,782, "Trading with conditional offers for semi-anonymous participants," issued November 5, 2013 (’782 Patent).

The Invention Explained

• Problem Addressed: Modern electronic trading systems have increased anonymity, which prevents buyers and sellers from setting prices based on knowledge of the other transacting party (’782 Patent, col. 1:11-15). This lack of information can be disadvantageous, as a party's trading history may be relevant to pricing a transaction (’782 Patent, col. 1:55-63).
• The Patented Solution: The invention describes a system where a trading participant, or "taker," is associated with an identifier that links to their trading history (’782 Patent, Abstract). A "liquidity provider" can access a profile generated from this history—without necessarily knowing the taker's real-world identity—and generate a conditional trade offer specifically for that taker (’782 Patent, col. 3:1-4). As illustrated in Figure 1, the system architecture involves a liquidity taker (14), an exchange (16), and a liquidity provider (12) that uses a profile analyzer (24) and offer generator (26) to create these history-based offers (’782 Patent, Fig. 1).
• Technical Importance: This approach seeks to reintroduce participant-specific information into anonymous electronic markets, potentially allowing for more efficient pricing and risk management for market makers (’782 Patent, col. 6:45-56).

Key Claims at a Glance

The complaint asserts infringement of unspecified "exemplary claims" (Compl. ¶11). Independent claim 1 is representative:

• associating one of a plurality of trading entities with an identifier using a processor;
• acquiring trade history information including a history of trading transactions associated with said identifier; and
• receiving an offer to buy or to sell a trading item from a liquidity provider based on a profile generated from said trade history information, the profile containing information that indicates whether said trading transactions would generate a profit;
• said offer being only made to said trading entity associated with said identifier;
• said offer being processed through an exchange that processes trading transactions for items having a bid/offer spread.

III. The Accused Instrumentality

Product Identification

The complaint accuses "Exemplary Defendant Products" but does not name them in the body of the complaint (Compl. ¶11). It states these products are identified in charts contained within Exhibit 2, which was not provided with the complaint (Compl. ¶16).

Functionality and Market Context

The complaint alleges that the "Exemplary Defendant Products practice the technology claimed by the '782 Patent" (Compl. ¶16). Defendant Horace Mann Educators Corporation is described as a corporation with a place of business in Illinois (Compl. ¶3). The complaint does not provide any specific details regarding the functionality or market positioning of the accused products. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references, but does not include, claim chart exhibits detailing its infringement theory (Compl. ¶¶ 16-17). The narrative allegations state that the "Exemplary Defendant Products" practice the claimed technology and satisfy all elements of the "Exemplary '782 Patent Claims" (Compl. ¶16). A detailed element-by-element analysis is not possible based on the complaint's text.

Identified Points of Contention

Based on the patent's focus and the defendant's apparent business as a financial services provider for educators, the infringement analysis raises several questions.

• Scope Questions: A central question may be whether the defendant's financial products or services (e.g., insurance policies, retirement accounts) constitute "trading items" that are processed on an "exchange" with a "bid/offer spread" as those terms are used in the patent (’782 Patent, col. 11:4-6). The patent's specification appears to contemplate securities and futures trading (’782 Patent, col. 2:41-43, col. 6:17-21).
• Technical Questions: The complaint provides no detail on how the accused products allegedly generate a "profile containing information that indicates whether said trading transactions would generate a profit" as required by claim 1 (’782 Patent, col. 11:1-3). A key factual dispute may concern whether any analysis performed by the defendant's systems meets this specific functional requirement.

V. Key Claim Terms for Construction

The Term: "trading entity"

Context and Importance

The definition of this term is critical for determining whether the defendant's customers or the defendant itself fall within the scope of the claims. Practitioners may focus on this term because the patent appears directed to participants in active trading markets, whereas the defendant's customers are likely consumers of insurance and retirement products.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The patent uses general terms like "participants" and "transacting parties" (’782 Patent, col. 2:48-49) and describes entities hierarchically (e.g., individuals, broker-dealers, clearing-houses), which could suggest a broad scope covering various actors in financial transactions (’782 Patent, col. 3:55-64).
• Evidence for a Narrower Interpretation: The specification repeatedly contextualizes the invention in the field of "trading of stocks and other securities" and "futures contracts" (’782 Patent, col. 1:9-10, col. 2:42-43). The concept of a "taker" is defined as a trading entity with an "offer to buy a trading item at a price," which may imply active, price-sensitive market participation (’782 Patent, col. 2:46-48).

The Term: "profile containing information that indicates whether said trading transactions would generate a profit"

Context and Importance

This limitation requires a specific type of analytical output. The infringement analysis will depend on whether any profiling performed by the accused systems is for the purpose of, and results in an indication of, future profitability from trading with the entity.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The claim language "indicates whether" could be argued to encompass any data point or score that correlates with profitability, rather than requiring an explicit profit/loss prediction.
• Evidence for a Narrower Interpretation: The specification provides a specific example of calculating a variable ("SIMPROF") based on the price movement of a security after a taker's transaction to determine if that taker's trades were profitable (’782 Patent, col. 4:51-62). This detailed embodiment may be used to argue for a narrower construction limited to profiles that analyze post-trade market performance.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in an infringing manner (Compl. ¶14).

Willful Infringement

The complaint asserts that its service, along with attached claim charts, provides Defendant with actual knowledge of infringement (Compl. ¶13). It alleges that any continued infringement after this notice is willful (Compl. ¶14).

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

The dispute as framed by the complaint will likely center on fundamental questions of scope and evidence.

• A core issue will be one of definitional scope: can the patent's claims, which are described in the context of active securities trading, be construed to cover the financial services and customer interactions of an educators' insurance and financial products company?
• A key evidentiary question will be one of technical implementation: assuming the scope question is resolved in the plaintiff's favor, what evidence will demonstrate that the accused systems create a "profile" that specifically "indicates whether... trading transactions would generate a profit," as functionally required by the asserted patent?