Cedar Lane Tech Inc v. Uhlmann Price Securities LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cedar Lane Technologies Inc. (Canada)
  • Defendant: Uhlmann Price Securities, LLC (Illinois)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 1:25-cv-15329, N.D. Ill., 12/17/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has an established place of business in the district and has committed acts of alleged infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s unidentified financial trading products and services infringe a patent related to electronic trading systems that generate conditional offers for semi-anonymous participants based on their trading history.
• Technical Context: The technology at issue involves systems for electronic securities and futures trading, specifically methods that allow liquidity providers to price offers based on the historical trading behavior of otherwise anonymous market participants.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) 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

• Issued: November 5, 2013
• Short Name: ’782 Patent

The Invention Explained

• Problem Addressed: In modern electronic trading systems, the anonymity of buyers and sellers prevents parties from pricing trades based on information about their counterparty (’782 Patent, col. 1:12-16; col. 2:50-54). This lack of information may lead to suboptimal pricing, particularly for liquidity providers who face risks from trading with "toxic traders" possessing superior short-term market knowledge (’782 Patent, col. 6:32-45).
• The Patented Solution: The invention proposes a system where a trading participant, or "taker," is associated with an identifier that does not reveal their personal identity but allows their trading history to be tracked (’782 Patent, col. 1:20-24; Abstract). A "liquidity provider" can then acquire this history, generate a profile of the taker (e.g., to assess if they are a "toxic trader"), and generate a conditional trade offer with a price based specifically on that taker's profile (’782 Patent, col. 1:26-31; Fig. 1). The system thereby enables "informed, semi-anonymous, trading based on stored knowledge of the trading history" without revealing the trader's actual identity (’782 Patent, col. 2:59-63).
• Technical Importance: This approach allows market makers to mitigate risk and offer more tailored pricing by distinguishing between different types of anonymous traders based on their past behavior. (Compl. ¶9; ’782 Patent, col. 6:46-57).

Key Claims at a Glance

• The complaint alleges infringement of "one or more claims" of the ’782 Patent but does not identify any specific claims in the body of the complaint (Compl. ¶11). It refers to "Exemplary '782 Patent Claims" that are purportedly identified in an attached but unprovided exhibit (Compl. ¶¶11, 16).
• The complaint reserves the right to assert additional claims (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products by name. It refers generally to "Exemplary Defendant Products" and "Defendant products" throughout the allegations (Compl. ¶¶11-12, 14-16).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's specific functionality. It alleges in a conclusory manner that the "Exemplary Defendant Products practice the technology claimed by the '782 Patent" (Compl. ¶16). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint states that detailed infringement allegations are contained in claim charts attached as Exhibit 2 (Compl. ¶¶16-17). As this exhibit was not provided, the infringement theory is summarized below based on the complaint's narrative allegations.

The complaint alleges that the unidentified "Exemplary Defendant Products" infringe the ’782 Patent either literally or under the doctrine of equivalents (Compl. ¶11). The core allegation is that these products "practice the technology claimed by the '782 Patent" and "satisfy all elements of the Exemplary '782 Patent Claims" (Compl. ¶16). Without the referenced claim charts or identification of specific accused products and asserted claims, a detailed analysis of the infringement theory is not possible.

• Identified Points of Contention: Given the lack of specific allegations, any litigation will first need to resolve foundational questions before addressing technical disputes.
  • Scope Questions: A primary issue will be identifying which, if any, of Defendant's products or services fall within the scope of the patent's claims. The complaint's failure to name an accused product suggests a potential dispute over the basic applicability of the patent to Defendant's business.
  • Technical Questions: Once products are identified, a key question will be whether they perform the specific functions claimed in the ’782 Patent, such as associating a trader with a persistent but semi-anonymous identifier, generating a trader "profile" based on historical transactions, and creating a "conditional offer" based on that specific profile.

V. Key Claim Terms for Construction

The complaint does not identify specific asserted claims, precluding an analysis of key claim terms for construction.

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 its products in a manner that allegedly infringes the ’782 Patent (Compl. ¶¶14-15). These materials are purportedly referenced in the unprovided Exhibit 2 (Compl. ¶14).
• Willful Infringement: The willfulness allegation is predicated on post-suit knowledge. The complaint asserts that service of the complaint itself provides Defendant with "actual knowledge of infringement" and that any continued infringement thereafter is willful (Compl. ¶¶13-14).

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

The initial phase of this case will likely focus on resolving the ambiguities in the complaint before substantive technical and legal arguments can be addressed. The central questions are:

1. Identification of the Accused Instrumentality: A threshold issue will be for the Plaintiff to identify with specificity which of Defendant's products or services are accused of infringement, as the current complaint fails to do so.
2. Mapping to the Patented System: A key technical question will be whether the accused products, once identified, actually implement the core architecture of the ’782 patent: a system where liquidity providers generate specific, conditional offers to semi-anonymous takers based on profiles derived from their unique trading histories.
3. Basis for Knowledge and Intent: For the indirect and willful infringement claims, a central question will be what evidence, beyond the complaint itself, demonstrates that the Defendant knew of the patent and intended for its customers to infringe.