DCT

1:25-cv-09529

Cedar Lane Tech Inc v. Ingalls & Snyder LLC

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-09529, S.D.N.Y., 11/14/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Southern District of New York because Defendant has an established place of business in the district and has committed acts of patent infringement there.
  • Core Dispute: Plaintiff alleges that Defendant’s unidentified trading products and systems infringe a patent related to generating conditional, customized trade offers for semi-anonymous market participants based on their trading history.
  • Technical Context: The technology at issue pertains to electronic financial trading systems that use trader-specific historical data to enable more informed pricing and risk management in otherwise anonymous trading environments.
  • Key Procedural History: The complaint does not allege any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date Event
2010-04-08 U.S. Patent No. 8,577,782 Priority Date
2013-11-05 U.S. Patent No. 8,577,782 Issues
2025-11-14 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"

  • Patent Identification: U.S. Patent No. 8,577,782, “Trading with conditional offers for semi-anonymous participants,” issued November 5, 2013 (’782 Patent). (Compl. ¶¶ 8-9).

The Invention Explained

  • Problem Addressed: The patent’s background section notes that the trend toward automated electronic trading has increased anonymity, such that buyers and sellers typically do not know the identity of their counterparties, precluding the use of party-specific information in setting prices. (’782 Patent, col. 1:8-15).
  • The Patented Solution: The invention describes a method and system to facilitate "informed, semi-anonymous, trading." (’782 Patent, col. 2:60-61). The system associates a trading entity with a unique "identifier," acquires that entity's transaction history, and allows a "Liquidity Provider" to generate a profile based on that history. (’782 Patent, Abstract; Fig. 1). This profile can then be used to generate a conditional trade offer that is directed only to the specific trading entity associated with that identifier, allowing for customized pricing without revealing the entity's actual identity. (’782 Patent, col. 1:21-28).
  • Technical Importance: This approach allows market makers to differentiate between traders based on their past trading behavior—for example, to identify potentially informed "toxic traders"—and adjust their bid/ask spreads accordingly, which can improve risk management and pricing efficiency. (’782 Patent, col. 6:32-57).

Key Claims at a Glance

  • The complaint does not specify which claims of the ’782 Patent are asserted in its main body, instead incorporating by reference "Exemplary '782 Patent Claims" detailed in an unprovided Exhibit 2. (Compl. ¶¶ 11, 16). The following analysis is based on independent claim 1, a representative method claim.
  • Independent Claim 1 of the ’782 Patent recites a method comprising the following essential elements:
    • 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 the identifier.
    • Receiving an offer to buy or sell a trading item from a liquidity provider based on a profile generated from the trade history.
    • The profile contains information indicating whether the trading entity's past transactions would generate a profit.
    • The offer is made only to the trading entity associated with the identifier.
    • The offer is processed through an exchange that handles transactions for items with a bid/offer spread.

III. The Accused Instrumentality

Product Identification

  • The complaint does not specifically name the accused products, referring to them generally as "Exemplary Defendant Products" and incorporating by reference charts from an unprovided Exhibit 2 for identification. (Compl. ¶¶ 11, 16).

Functionality and Market Context

  • The complaint alleges that the accused products "practice the technology claimed by the '782 Patent." (Compl. ¶16). It further alleges that Defendant's employees internally test and use these products. (Compl. ¶12).
  • The complaint does not provide sufficient detail for analysis of the specific functionality of the accused products or their market context.

IV. Analysis of Infringement Allegations

The complaint incorporates infringement claim charts by reference to an external exhibit, which was not provided with the filing. (Compl. ¶¶ 16-17). The narrative infringement theory alleges that the "Exemplary Defendant Products" satisfy all elements of the asserted claims, either literally or under the doctrine of equivalents. (Compl. ¶16). The core of the allegation is that Defendant's trading systems and products utilize the patented method of analyzing a trader's history via an identifier to generate customized, conditional offers. (Compl. ¶¶ 11, 16).

No probative visual evidence provided in complaint.

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 appears to be a critical functional limitation. The infringement analysis will likely depend on whether the defendant's system generates a profile for this specific predictive purpose. Practitioners may focus on this term because its construction will determine if general risk analysis based on trade history meets the claim element, or if a more explicit profitability analysis is required.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification defines "trading history" broadly as "any relevant information relating to the trader, including information relating to the past trades of the trader, the identity of the trader, a classification of the trader, etc." (’782 Patent, col. 2:65 - col. 3:2). This could support a less restrictive interpretation of the resulting "profile."
      • Evidence for a Narrower Interpretation: The detailed description provides specific examples of how profitability is calculated, such as by creating variables that compare execution prices with prices one minute later ("SIMPROF") or that track the actual profit earned by the liquidity provider ("ACTPROF"). (’782 Patent, col. 4:50 - col. 5:5). This language may support a narrower construction requiring a direct calculation or prediction of profitability.

  • The Term: "offer being only made to said trading entity associated with said identifier" (from Claim 1).

    • Context and Importance: This limitation defines the targeted nature of the communication. The dispute may center on whether the accused system's offers are truly exclusive to a single identified entity or are more broadly available, even if priced based on that entity's profile.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent describes offers being broadcast "through a centralized exchange" where "any number of Takers can subscribe." (’782 Patent, col. 4:6-9). This might suggest that while the offer is based on one profile, its technical accessibility is wider, with a matching system ensuring it is only accepted by the intended party.
      • Evidence for a Narrower Interpretation: The summary states the "offer being only directed to the taker associated with said identifier." (’782 Patent, col. 1:30-31). This phrasing, along with the claim language, suggests a high degree of exclusivity and may be used to argue that the offer must be transmitted in a way that is technically inaccessible to other trading entities.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement based on post-complaint conduct. It asserts that after being served with the complaint, Defendant continued to sell the accused products and distribute "product literature and website materials" that allegedly instruct end users on how to use the products in an infringing manner. (Compl. ¶¶ 14-15).
  • Willful Infringement: The complaint alleges that service of the complaint and its attached (but unprovided) claim charts constitutes "Actual Knowledge of Infringement." (Compl. ¶13). It further alleges that despite this knowledge, Defendant continued its infringing activities. (Compl. ¶14). While the term "willful" is not used, these allegations form a basis for a claim of post-filing willfulness and enhanced damages. The prayer for relief also requests that the case be declared "exceptional" under 35 U.S.C. § 285. (Compl. p. 5).

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

  • A core issue will be one of functional specificity: does the accused trading system generate a "profile" for the specific purpose of indicating whether a trader's transactions "would generate a profit," as required by the claim language, or does it use historical data for more general risk management or analytics that may fall outside the claim's scope?
  • A key evidentiary question will be one of technical implementation: what factual evidence, to be developed during discovery, will show that the Defendant’s systems perform each step of the claimed method, particularly the generation of an "offer" that is "only made to" a specific trading entity based on its identifier-linked profile? The complaint's conclusory allegations will require substantiation with detailed evidence of the accused systems' internal operations.