Cedar Lane Tech Inc v. Henley & Co LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cedar Lane Technologies Inc. (Canada)
  • Defendant: Henley & Company LLC (New York)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 1:25-cv-06328, E.D.N.Y., 11/13/2025
• 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 within the district.
• Core Dispute: Plaintiff alleges that Defendant’s unnamed financial trading products infringe a patent related to systems for making conditional trade offers based on the historical trading data of semi-anonymous participants.
• Technical Context: The technology at issue addresses electronic trading platforms, aiming to reintroduce counterparty evaluation into anonymous markets by using historical data profiles to customize offers.
• Key Procedural History: The complaint does not reference any prior litigation, licensing history, or administrative proceedings (e.g., IPRs) involving 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.

The Invention Explained

• Problem Addressed: The patent’s background section notes that the rise of automated electronic trading systems has led to increased anonymity, preventing buyers and sellers from knowing the identity of their counterparties and pricing transactions accordingly (’782 Patent, col. 1:8-15).
• The Patented Solution: The invention describes a system where a trading entity ("taker") is associated with a persistent but non-identifying "identifier." A "liquidity provider" can then acquire the trading history associated with that identifier, generate a profile analyzing that history (e.g., for profitability), and make a conditional trade offer based specifically on that profile. This allows for customized, risk-adjusted pricing in an otherwise anonymous market (’782 Patent, Abstract; col. 2:56-64). Figure 1 illustrates the flow of information from a "Liquidity Taker" (14) through an "Exchange" (12) to a "Liquidity Provider" (20), which uses a "Profile Analyzer" (24) to inform an "Offer Generator" (26).
• Technical Importance: This approach seeks to mitigate information asymmetry in electronic markets by allowing sophisticated participants (liquidity providers) to differentiate between different types of anonymous traders (e.g., "naive" vs. "toxic" traders) and adjust their pricing to reduce risk (’782 Patent, col. 6:32-57).

Key Claims at a Glance

The complaint does not specify which claims of the ’782 Patent are asserted, referring only to "Exemplary '782 Patent Claims" detailed in an unprovided exhibit (Compl. ¶11, 16). The analysis below focuses on independent claim 1 as a representative claim.

• Independent Claim 1:
  • 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...
  • 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 associated with said trading entity 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.
• 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 product, method, or service. It refers generally to "Exemplary Defendant Products" (Compl. ¶11).

Functionality and Market Context

The complaint alleges that the "Exemplary Defendant Products" practice the technology claimed by the ’782 Patent (Compl. ¶16). However, it provides no specific details about the functionality, features, or operation of these accused products. The complaint also makes no allegations regarding the commercial importance or market positioning of the accused products.

IV. Analysis of Infringement Allegations

The complaint does not contain a claim chart or specific infringement allegations mapping product features to claim limitations. It instead incorporates by reference "the claim charts of Exhibit 2," which was not provided with the complaint (Compl. ¶17). The narrative infringement theory is that the "Exemplary Defendant Products practice the technology claimed by the '782 Patent" and "satisfy all elements of the Exemplary '782 Patent Claims" (Compl. ¶16).

The complaint's lack of detail regarding the accused products or their specific functionality prevents a substantive analysis of potential points of contention.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

• The Term: "a profile generated from said trade history information, the profile containing information that indicates whether said trading transactions... would generate a profit" (from Claim 1).
• Context and Importance: This term is central to the invention's core concept of enabling risk-based pricing. The dispute will likely focus on what level of data processing qualifies as generating a "profile" and whether that profile must contain a specific, forward-looking prediction of profitability, as the claim language suggests.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The detailed description provides examples of profiles that are relatively simple calculations, such as comparing execution prices with prices one minute later, which could support an argument that any analysis of historical trading patterns meets the limitation (’782 Patent, col. 4:50-65).
  • Evidence for a Narrower Interpretation: The claim language itself is quite specific, requiring the profile to contain information that "indicates whether" transactions "would generate a profit." This phrasing may support a narrower construction requiring an explicit or predictive profitability analysis, not just a collection of historical data points. The specification's discussion of identifying "toxic traders" who "consistently have special knowledge" may further support a narrower reading focused on predicting future performance (’782 Patent, col. 6:32-41).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, asserting that since being served with the complaint, Defendant has knowingly sold products and distributed "product literature and website materials" that direct end users to use the products in an infringing manner (Compl. ¶14, 15).
• Willful Infringement: The complaint alleges Defendant has "Actual Knowledge of Infringement" based on the service of the complaint and its attached claim charts (Compl. ¶13). This appears to be a theory of post-suit willfulness, as no pre-suit knowledge is alleged.

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

• A central threshold issue will be the sufficiency of the pleadings. The complaint's failure to identify any specific accused product or provide any detail on the alleged infringement may be subject to a motion to dismiss under federal pleading standards.
• Assuming the case proceeds, a core issue will be one of technical implementation: Do the accused products in fact generate and use a "profile" of a trading entity, and does that profile contain a specific analysis of whether that entity's past trades "would generate a profit," as required by the asserted claim?
• A second key question will be one of definitional scope: How broadly will the court construe the term "profile"? The outcome of the case may depend on whether a simple aggregation of historical trade data is sufficient to meet this limitation, or if a more sophisticated, predictive analysis of profitability is required by the patent.