Cedar Lane Tech Inc v. Lasalle St Securities LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cedar Lane Technologies Inc. (Canada)
  • Defendant: LaSalle St. Securities, L.L.C. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: Cedar Lane Technologies Inc. v. LaSalle St. Securities, L.L.C., 1:26-cv-00721, N.D. Ill., 01/22/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Illinois because Defendant maintains an established place of business in the district.
• Core Dispute: Plaintiff alleges that Defendant’s electronic securities trading products and systems infringe a patent related to generating conditional trade offers for semi-anonymous participants based on their trading history.
• Technical Context: The technology at issue addresses pricing inefficiencies in anonymous electronic trading markets by allowing market makers to use a trader's past performance to offer tailored, non-public prices without fully revealing the trader's identity.
• Key Procedural History: The complaint does not reference any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date	Event
2010-04-08	’782 Patent Priority Date
2013-11-05	’782 Patent Issue Date
2026-01-22	Complaint Filed

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

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

The Invention Explained

• Problem Addressed: The patent's background section notes that the trend toward automated, electronic trading systems has led to "increasing anonymity," where buyers and sellers often do not know the identity of their counterparties. This prevents the use of information about a specific trader's history or behavior to inform pricing, which could otherwise be advantageous to both parties. (’782 Patent, col. 1:6-14, 55-58).
• The Patented Solution: The invention discloses a system that enables "informed, semi-anonymous, trading based on stored knowledge of the trading history of one or more of the participants, without revealing the exact identity of the trading parties" (’782 Patent, col. 1:59-63). In this system, a trading entity (a "taker") is associated with an identifier. A "liquidity provider" acquires the taker's transaction history, generates a profile analyzing that history (e.g., for profitability), and then generates a conditional trade offer that is directed only to the entity associated with that identifier. (’782 Patent, Abstract; Fig. 1). This allows the provider to tailor offers—for instance, by giving better prices to "naïve" traders and worse prices or wider spreads to sophisticated or "toxic" traders—based on their historical trading patterns. (’782 Patent, col. 6:46-57).
• Technical Importance: This approach seeks to reintroduce a level of personalized risk assessment into anonymous electronic markets, potentially increasing liquidity and pricing efficiency by allowing market makers to selectively price risk for different types of traders. (’782 Patent, col. 3:19-27).

Key Claims at a Glance

• The complaint does not specify which claims are asserted, referring generally to "one or more claims" and "Exemplary '782 Patent Claims" identified in an attached exhibit not included with the complaint (Compl. ¶11). Independent claim 1 is representative of the core method:
• Independent Claim 1:
  • Associating a trading entity with an identifier via a processor.
  • Acquiring the trading entity's history of trading transactions associated with that identifier.
  • Receiving a trade offer from a liquidity provider that is based on a profile generated from that trade history.
  • The profile must contain "information that indicates whether said trading transactions associated with said trading entity would generate a profit."
  • The offer must be "only made to said trading entity associated with said identifier."
  • The offer is processed through an exchange that handles transactions with a bid/offer spread.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products, methods, or services in its main body. It refers to "the Defendant products identified in the charts incorporated into this Count below (among the 'Exemplary Defendant Products')" (Compl. ¶11). These charts are part of Exhibit 2, which was not filed with the public complaint.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the functionality of the accused instrumentalities. It alleges only that the unspecified products "practice the technology claimed by the '782 Patent" (Compl. ¶16).

IV. Analysis of Infringement Allegations

As the complaint incorporates its substantive infringement allegations by reference to an exhibit that is not publicly available (Exhibit 2), a detailed claim chart summary cannot be constructed (Compl. ¶¶11, 16-17). The narrative infringement theory suggests that Defendant's unidentified trading systems or platforms perform the method of the ’782 Patent by using trader-specific historical data to generate and direct tailored offers.

No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: A central question may be whether offers generated by the accused system are "only made to said trading entity" as required by claim 1. If the accused system generates quotes that are technically available to a wider audience, even if tailored for a specific one, it could raise a dispute over the scope of this limitation.
• Technical Questions: The infringement analysis will likely depend heavily on the internal workings of the accused system. A key question will be what evidence the complaint provides that the accused system generates a "profile containing information that indicates whether said trading transactions... would generate a profit" (’782 Patent, claim 1). This implies a specific predictive or analytical function beyond merely tracking trade history, and demonstrating its presence in the accused product will be critical.

V. Key Claim Terms for Construction

The Term: "profile containing information that indicates whether said trading transactions associated with said trading entity would generate a profit" (from claim 1)

• Context and Importance: This term is the functional heart of the claimed invention, defining the analytical basis for generating a conditional offer. The case may turn on whether the accused system's logic performs this specific type of profitability analysis, as opposed to a more general risk or volume analysis.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party might argue that any historical data analysis that informs pricing satisfies this element, as pricing inherently relates to profitability. The patent refers generally to using a "trading history" to allow a "Provider to offer different prices to different Takers" (’782 Patent, col. 3:2-4), which could support a broader reading.
  • Evidence for a Narrower Interpretation: The specification provides specific examples of how this analysis is performed, such as by "compare[ing] the execution prices of an identified taker with the prices one minute later" or by calculating the "actual profit which the Liquidity Provider earned from past cases" involving that taker (’782 Patent, col. 4:53-61; col. 5:1-4). A party could argue these examples limit the claim's scope to profiles that perform these or very similar predictive profit calculations.

The Term: "liquidity provider"

• Context and Importance: This term defines one of the key actors in the claimed system. While Defendant is a securities firm, its specific role in the accused transactions (e.g., market maker, broker, exchange) will determine whether it functions as a "liquidity provider" as contemplated by the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent defines "providers" broadly as "trading entities offering a trading item at a price" (’782 Patent, col. 2:45-47). This general definition could encompass a wide range of market participants who post offers.
  • Evidence for a Narrower Interpretation: The context of the invention describes the liquidity provider as the entity that actively analyzes taker profiles to generate conditional offers, distinguishing them from a passive exchange or a simple broker. The description of the provider earning a "bid/offer spread" and adjusting it for "toxic traders" suggests the term refers specifically to a market maker. (’782 Patent, col. 6:22-26, 46-57).

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, asserting that since the filing of the complaint, Defendant has had knowledge of the ’782 Patent and has continued to sell its products and "distribute product literature and website materials inducing end users" to use the products in an infringing manner (Compl. ¶¶14-15).

Willful Infringement

The complaint does not use the word "willful" but alleges that Defendant has "actual knowledge of infringement" from the service of the complaint and has continued its allegedly infringing conduct despite this knowledge (Compl. ¶¶13-14). Plaintiff requests damages under 35 U.S.C. § 284, which includes enhanced damages for willful infringement, and also seeks a declaration that the case is "exceptional" under § 285 (Compl. Prayer D, E.i).

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

This dispute, as framed by the high-level allegations in the complaint, appears poised to center on the following key questions:

1. A primary issue will be one of evidentiary proof: Given the complaint's lack of specific factual allegations regarding the accused product's operation, a core challenge for the plaintiff will be to produce evidence demonstrating that the defendant's system performs the specific analytical functions required by the claims, particularly the generation of a "profile... indicat[ing] whether... transactions... would generate a profit."

2. The case will also involve a crucial question of claim scope: Can the functional requirement that an offer be based on a profit-indicating profile be met by general-purpose risk management algorithms common in modern trading systems, or is it limited to the specific predictive methods disclosed in the patent's specification? The construction of this term will likely be determinative for infringement.