Cedar Lane Tech Inc v. Corinthian Partners LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cedar Lane Technologies Inc. (Canada)
  • Defendant: Corinthian Partners, L.L.C. (New York)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 1:25-cv-07848, S.D.N.Y., 09/22/2025
• Venue Allegations: Venue is alleged to be proper based on Defendant having an established place of business in the Southern District of New York.
• Core Dispute: Plaintiff alleges that Defendant’s unidentified financial trading products infringe a patent related to systems and methods for generating conditional, targeted trade offers in semi-anonymous electronic markets.
• Technical Context: The technology concerns electronic trading platforms where market makers can use a participant's trading history to generate customized price offers, aiming to better manage risk from informed or "toxic" traders.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or administrative proceedings 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, issued November 5, 2013 (’782 Patent).

The Invention Explained

• Problem Addressed: In modern electronic trading systems, the anonymity of participants prevents parties from setting prices based on knowledge of their counterparty. This makes it difficult for liquidity providers (market makers) to price the risk associated with trading against potentially highly informed or "toxic" traders. (’782 Patent, col. 1:7-15, col. 6:32-46).
• The Patented Solution: The invention describes a system where a trading entity ("taker") is associated with a persistent but semi-anonymous identifier. A liquidity provider can access the trade history linked to this identifier to generate a "profile" that assesses the historical profitability of trading with that entity. Based on this profile, the provider can generate a conditional offer that is directed exclusively to the taker associated with that identifier, allowing for customized pricing without revealing the taker's actual identity. (’782 Patent, Abstract; col. 2:26-44). The system architecture involves a "taker unit," an "exchange unit," and a "provider unit" that includes a profile analyzer and offer generator. (’782 Patent, Fig. 1).
• Technical Importance: This approach allows market makers to differentiate pricing for different types of traders, potentially offering better prices to "naïve" traders while protecting against losses from "toxic" traders, which could increase overall market liquidity and efficiency. (’782 Patent, col. 6:46-57).

Key Claims at a Glance

The complaint does not specify which claims are asserted, referring only to "Exemplary '782 Patent Claims" detailed in an exhibit not attached to the complaint. (Compl. ¶11). Independent claims 1 and 10 are representative method claims.

• Independent Claim 1: A method comprising the essential elements of:

  • Associating a trading entity with an identifier.
  • Acquiring trade history information associated with the identifier.
  • Receiving an offer from a liquidity provider based on a profile generated from that trade history.
  • The profile must contain information indicating whether past transactions with the entity "would generate a profit."
  • The offer is "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.

• Independent Claim 10: A method comprising the essential elements of:

  • Acquiring a history of trading transactions made by a "taker" associated with an identifier.
  • Generating a profile of the taker, which includes trade history information indicating whether the transactions "would generate a profit."
  • Generating an offer to buy or sell a trading item based on that profile.
  • The offer is "only directed to said taker associated with said identifier."
  • The offer is processed through an exchange that handles transactions with a bid/offer spread.

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products, services, or methods by name. It refers generally to "Exemplary Defendant Products" that are purportedly identified in an external claims chart exhibit. (Compl. ¶¶11, 16).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the functionality or market context of any accused instrumentality. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges infringement but incorporates the specific theory by reference to an "Exhibit 2," which contains claim charts that were not filed with the complaint itself. (Compl. ¶¶16-17). As such, a detailed claim chart summary cannot be constructed from the provided documents. The complaint's narrative allegations are conclusory, stating 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).

• Identified Points of Contention: Based on the asserted patent and the general nature of the dispute, several points of contention may arise.
  • Scope Questions: A central question may be whether the accused system generates offers that are truly "only made to" or "only directed to" a specific trading entity, as required by the claims. The technical implementation of this exclusivity will likely be a key point of dispute.
  • Technical Questions: Another question will be what factual evidence demonstrates that the accused system generates a "profile containing information that indicates whether said trading transactions... would generate a profit." This raises the issue of whether the system performs the specific type of historical profitability analysis described in the patent, such as comparing execution prices to subsequent market prices. (’782 Patent, col. 4:50-60).

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" (Claim 1).

• Context and Importance: This term is central to the invention's mechanism for enabling "informed, semi-anonymous, trading." (’782 Patent, col. 2:59-60). The construction of this term will define the type and complexity of historical analysis required to infringe. Practitioners may focus on this term because it is a functional limitation that distinguishes the claimed invention from generic trading systems.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification provides multiple examples of what this analysis could entail, such as comparing execution prices to prices "one minute later" or calculating the "actual profit which the Liquidity Provider earned from past cases." (’782 Patent, col. 4:50-col. 5:4). This could support an argument that any historical analysis of trade outcomes meets the limitation.
  • Evidence for a Narrower Interpretation: A defendant may argue that the phrase "would generate a profit" implies a predictive or forward-looking quality, requiring more than a simple retrospective calculation of past gains or losses. The use of the conditional tense "would" may be argued to require an analysis of likely future profitability based on past behavior.

• The Term: "said offer being only made to said trading entity" (Claim 1) / "only directed to said taker" (Claim 10).

• Context and Importance: This limitation defines the targeted, conditional nature of the claimed offers. The dispute will likely concern the degree of exclusivity required.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification states that the offer "may only accepted by the trading entity associated with the identifier," which could suggest that the offer might be broadcast more widely but is only executable by the target entity. (’782 Patent, col. 2:42-44).
  • Evidence for a Narrower Interpretation: The phrasing "only made to" could be interpreted more strictly to mean the offer is communicated privately and is not visible to any other market participants. This interpretation would impose a higher technical burden to prove infringement.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, asserting that since the date of filing, Defendant has knowingly induced infringement by selling products and distributing "product literature and website materials" that instruct users on the infringing use. (Compl. ¶¶14-15).
• Willful Infringement: The complaint alleges that service of the complaint itself provides "actual knowledge of infringement." (Compl. ¶13). This forms the basis for potential post-filing willful infringement and induced infringement liability. No allegations supporting pre-suit knowledge are made.

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

1. A core issue will be one of definitional scope: What level of data analysis satisfies the claim requirement of generating a "profile... that indicates whether... transactions... would generate a profit"? The case may depend on whether a simple historical performance metric is sufficient or if a more complex, predictive analysis is required by the claim language.
2. A key evidentiary question will be one of technical implementation: What evidence will be presented to show that the accused system's offers are "only made to" or "only directed to" a specific trader? Given the lack of detail in the complaint, demonstrating this exclusivity will be a primary hurdle for the plaintiff.
3. A foundational question will be the identification of the accused instrumentality: The complaint’s failure to name a single accused product or describe its functionality creates significant uncertainty. Early discovery will be critical to determine if there is a factual basis for the infringement allegations.