DCT

2:25-cv-18551

Single Action Bet Tech LLC v. Penn Entertainment Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-18551, D.N.J., 12/12/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the District of New Jersey because Defendant Penn Interactive Ventures, LLC maintains offices in the district, and both defendants have allegedly committed acts of infringement there.
  • Core Dispute: Plaintiff alleges that Defendant’s Hollywood Casino online gaming and sports betting platform infringes patents related to single-action bet placement technology.
  • Technical Context: The technology addresses user interface efficiency in the online gambling sector, aiming to streamline the process of placing a real-money bet into a single user action, particularly for mobile devices.
  • Key Procedural History: The complaint alleges that Plaintiff provided Defendant with pre-suit notice of the patents-in-suit via a letter dated December 4, 2024, which also invited licensing discussions. Subsequent discussions between the parties through September 2025 were reportedly unsuccessful, which may form the basis for allegations of willful infringement. The complaint notes that the ’397 patent is a continuation of the ’345 patent.

Case Timeline

Date Event
2013-06-12 ’345 and ’397 Patents Priority Date
2017-07-11 ’345 Patent Issue Date
2023-02-21 ’397 Patent Issue Date
2024-12-04 Plaintiff sends letter to Defendant identifying patents-in-suit
2025-12-12 Complaint Filing Date

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

U.S. Patent No. 9,704,345 - "Single Action Betting System and Method"

  • Patent Identification: U.S. Patent No. 9,704,345, "Single Action Betting System and Method," issued July 11, 2017.

The Invention Explained

  • Problem Addressed: The patent’s background section identifies that mobile betting games conventionally required users to perform multiple, separate actions to select a bet amount, place the bet, and begin the game. This multi-step process was described as potentially causing users to become "uninterested or unwilling to place the bet," especially on small touchscreen devices (Compl. ¶37; ’345 Patent, col. 1:18-25).
  • The Patented Solution: The invention proposes a client-server system that consolidates the betting process into a "single action" from the user. In response to this single user input, a client device sends a request containing a player identifier to a backend server. The server then automatically retrieves the player's stored information (e.g., credentials and funds), validates the transaction, places the bet, and initiates gameplay without requiring further user actions (Compl. ¶¶38-41; ’345 Patent, col. 2:25-40).
  • Technical Importance: This approach was designed to make placing real-money bets on mobile devices "easier and quicker," thereby improving the user experience and encouraging more frequent wagering (Compl. ¶38; ’345 Patent, col. 1:54-59).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶55).
  • Claim 1 of the ’345 Patent requires:
    • Displaying information identifying a betting opportunity on a client system.
    • In response to "only a single action," sending a request to place the bet with a player identifier to a server system.
    • Receiving the request at a backend betting component.
    • Retrieving additional, previously stored information for the identified player.
    • Validating the player's credentials and verifying sufficient funds based on the retrieved information.
    • Generating a bet based on the request and placing it to commence the game if validation and verification are successful.
    • Whereby the bet is placed and gameplay is initiated "without using multiple actions by the player."

U.S. Patent No. 11,587,397 - "Single Action Betting System and Method"

  • Patent Identification: U.S. Patent No. 11,587,397, "Single Action Betting System and Method," issued February 21, 2023.

The Invention Explained

  • Problem Addressed: As a continuation of the ’345 patent, the ’397 patent addresses the same problem of cumbersome, multi-click betting workflows on mobile devices that could lead to user abandonment before a bet is completed (Compl. ¶47; ’397 Patent, col. 1:26-38).
  • The Patented Solution: The invention describes a method where a single user action on a client device triggers a sequence of automated checks on a backend server. Asserted claim 9 specifically recites server-side steps for validating player credentials, authorizing the client system, and, critically, verifying that the client system is in a jurisdiction where betting is legally permitted. Once these conditions are met, the server generates the bet and initiates gameplay (Compl. ¶49; ’397 Patent, col. 7:9-39). The specification details a system architecture with a "player credential store" and a "jurisdiction rules store" to enable these automated checks (Compl. ¶50; ’397 Patent, col. 3:9-13).
  • Technical Importance: The claimed invention provides a technical framework for streamlining the user-facing betting process while simultaneously handling essential backend regulatory and security checks, such as geolocation verification, which are fundamental to the operation of legal online gaming platforms (Compl. ¶¶50-51; ’397 Patent, col. 3:66-4:6).

Key Claims at a Glance

  • The complaint asserts independent claim 9 (Compl. ¶74).
  • Claim 9 of the ’397 Patent requires a method of:
    • Causing a client system to display a betting opportunity.
    • Receiving a request to place the bet with a player identifier at a server system, responsive to a "single action" at the client.
    • Validating at least one credential of the player.
    • Authorizing the client system.
    • Verifying the client system is in a jurisdiction that permits the bet.
    • Generating the bet at the server system, which is then placed and initiates gameplay.
    • Generating a win/loss outcome after gameplay.
    • Displaying a "re-bet option" on the client system that confirms the re-bet and verifies adequate funds.

III. The Accused Instrumentality

Product Identification

  • The accused products and services are collectively referred to as the "Hollywood Casino System," which includes the Hollywood Casino Mobile App, associated websites like hollywoodcasino.com and espnbet.com, and the underlying backend server infrastructure (Compl. ¶¶12-13).

Functionality and Market Context

  • The Hollywood Casino System is an online platform for real-money gambling, offering casino games and sports wagering to users in various U.S. states (Compl. ¶¶8, 11). The complaint focuses on the functionality where a user can initiate a round of gameplay, such as a slot machine spin, through a single tap on a button within the mobile app (Compl. ¶58). The system is alleged to handle user account registration, fund management, balance tracking, and geolocation verification to comply with state gaming regulations (Compl. ¶¶61, 80). A screenshot from a news release indicates the app is available in markets such as Michigan (Compl. p. 15).

IV. Analysis of Infringement Allegations

’345 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
displaying, under control of a client system, information identifying a betting opportunity for a user... The Hollywood Casino App displays various games and selectable wagering options, presenting betting opportunities. ¶57 col. 2:13-16
in response to only a single action being performed, sending a request to place the bet along with an identifier of a player of the game to a server system A player presses a single button (e.g., "Spin") which sends a bet request from the app to the backend server. A screenshot shows a slot game interface with a single large button to initiate play (Compl. p. 16). ¶58 col. 2:16-20
retrieving, by the betting component, additional information previously stored for the player identified by the identifier... The backend system retrieves previously stored player account data, such as personal identifiers, associated with the user's account. ¶60 col. 6:58-61
validating the credentials of the player and verifying that the player has sufficient funds... The system validates the player's stored credentials and checks the account balance for sufficient funds. An in-game message for "insufficient balance" is provided as evidence (Compl. p. 21). ¶61 col. 7:1-4
generating, by the betting component, a bet based on the request and placing the bet to commence the game... After successful validation, the backend generates the bet and automatically starts the game, which the complaint alleges is shown by the "Spin" button greying out after being pressed (Compl. p. 22). ¶62 col. 7:5-9
whereby the bet is placed and the game play is initiated without using multiple actions by the player The entire bet placement and game initiation sequence is allegedly completed with a single tap, without requiring further confirmation steps from the user. ¶63 col. 7:10-12
  • Identified Points of Contention:
    • Scope Questions: A central question may be the scope of "only a single action." The defense may argue that selecting a bet amount and then pressing a "spin" button constitutes multiple distinct user actions, not a single one. The complaint's evidence shows screens where bet amounts are set prior to the spin, which may support an argument that the accused process is multi-step (Compl. p. 16).
    • Technical Questions: Does the accused system's reliance on a pre-existing login session satisfy the "validating the credentials" step for each transaction, or does the claim require a more specific validation tied directly to the bet request itself?

’397 Patent Infringement Allegations

Claim Element (from Independent Claim 9) Alleged Infringing Functionality Complaint Citation Patent Citation
causing a client system to display information identifying a betting opportunity for a player The app displays wagering settings, including options for total spins and loss limits, before play begins. ¶76 col. 1:62-64
receiving, at a server system, a request to place the bet and an identifier corresponding to the player After a user taps the "Start" button in an autoplay setup screen, the backend server receives a request containing player identification information (Compl. p. 27). ¶77 col. 7:16-18
validating... at least one credential of the player The backend validates player credentials, such as a stored account ID or login data collected upon registration. ¶78 col. 7:19-21
authorizing... the client system The system implicitly authorizes the client device for the wagering session upon accepting the single tap, which is confirmed by subsequent balance updates reflecting the wager. ¶79 col. 7:22
verifying... that the client system is located in a jurisdiction that permits the bet The app requires users to enable location services before gameplay to verify their physical location is in a legally permitted area. A screenshot shows the prompt to "Enable location services" (Compl. p. 32). ¶80 col. 7:23-25
generating, by the server system, the bet, wherein... the bet is placed and game play is initiated Once all checks are complete, the backend generates the bet and initiates gameplay automatically in response to the single "Start" action. ¶81 col. 7:26-29
generating, after the game play is completed, an outcome that is at least one of: (i) a win... and (ii) a loss... The backend generates a win or loss outcome, which is reflected by an update to the player's visible account balance after a round of play. ¶82 col. 7:30-35
displaying, on the client system, a re-bet option to the player that confirms the re-bet... and verifies that the player has adequate funds After an autoplay sequence, the app allegedly displays a "Restart Autoplay" button, which functions as a re-bet option (Compl. p. 36). ¶83 col. 7:36-39
  • Identified Points of Contention:
    • Scope Questions: The term "authorizing... the client system" may be a point of dispute. The complaint alleges this happens implicitly when the app accepts the user's action, but the defense may argue for a more explicit authorization step that is not present.
    • Technical Questions: Does the "Restart Autoplay" button shown in the complaint's evidence (Compl. p. 36) meet all limitations of the "re-bet option," including both confirming the re-bet and verifying funds, as claimed?

V. Key Claim Terms for Construction

  • The Term: "only a single action" (’345 Patent, Claim 1) / "a single action" (’397 Patent, Claim 9)

    • Context and Importance: This phrase is the central inventive concept. Its construction will likely determine whether the accused app, which may involve prior setup steps like selecting a bet amount, falls within the scope of the claims. Practitioners may focus on this term because the infringement theory hinges on characterizing a multi-step user journey as a "single action" at the point of commitment.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification states the invention "enables a game player to combine the steps, such as selecting a bet amount, placing a bet and/or beginning the game, into a single action" (’345 Patent, col. 1:54-57). This language could support an interpretation where the final, triggering input constitutes the "single action," even if preparatory selections occurred beforehand.
      • Evidence for a Narrower Interpretation: The patent's figures depict distinct buttons for different bet amounts (e.g., "$1," "$5," "$8"), suggesting a single press both selects the amount and initiates play (’345 Patent, Fig. 1). This could support a narrower construction requiring a single physical input to perform all combined functions without prior, separate user inputs for bet configuration.

  • The Term: "validating the credentials of the player" (’345 Patent, Claim 1)

    • Context and Importance: The technical meaning of "validating" in the context of a single bet is critical. The dispute may turn on whether relying on an existing, valid login session is sufficient, or if a new, specific validation must occur in response to the bet request.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent describes a "player credential store 110 that stores data about each user... used for authentication" (’345 Patent, col. 3:3-6). This could suggest that validating credentials involves checking the request against this stored data, a process that could be satisfied by verifying an active session token tied to the authenticated user.
      • Evidence for a Narrower Interpretation: The claim recites validation as a step occurring after receiving the bet request. This sequence could imply a per-transaction check rather than a one-time session login, potentially requiring a more active authentication event in response to the "single action" itself.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendant’s advertisements, promotional materials, and user instructions encourage customers to use the accused single-action betting methods (Compl. ¶¶66, 86). Knowledge is alleged based on Defendant’s receipt of a letter identifying the patents on December 4, 2024 (Compl. ¶¶65, 85).
  • Willful Infringement: The willfulness allegation is predicated on Defendant’s alleged continued infringement after receiving pre-suit notice of the patents-in-suit via the December 2024 letter (Compl. ¶¶24, 67, 87). The prayer for relief explicitly requests a finding of willful infringement and an award of treble damages (Compl. p. 38, ¶¶ e, f).

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

  • A core issue will be one of definitional scope: can the term "single action," as defined and described in the patents, be construed to cover a user workflow where bet parameters (like wager amount) are configured in separate steps prior to a final, single input that places the bet and initiates gameplay?
  • A key evidentiary question will be one of technical implementation: what specific server-side processes are triggered by a user's bet placement in the Hollywood Casino System, and do those processes map directly onto the sequence of validation, authorization, and verification steps recited in the asserted claims?
  • A third question will relate to damages and willfulness: assuming infringement is found, the case will examine the extent to which Defendant's conduct after receiving notice in December 2024 was objectively reckless, which will be central to the determination of willfulness and potential enhancement of damages.