DCT
2:25-cv-03444
EasyWeb Innovations LLC v. Fastmail US LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: EasyWeb Innovations, LLC (New York)
- Defendant: FastMail US LLC (Pennsylvania)
- Plaintiff’s Counsel: Hecht Partners LLP
- Case Identification: 2:25-cv-03444, E.D. Pa., 07/07/2025
- Venue Allegations: Venue is based on Defendant’s established place of business in Philadelphia, Pennsylvania, and alleged acts of infringement occurring within the district.
- Core Dispute: Plaintiff alleges that Defendant’s email service, which allows individual users to select between standard password-based security and two-factor authentication, infringes a patent related to user-selectable, multi-level computer access authorization methods.
- Technical Context: The technology concerns customizable computer security, allowing end-users to balance convenience against the strength of authentication required to access a system.
- Key Procedural History: The complaint highlights that during prosecution, the asserted patent overcame a rejection under 35 U.S.C. § 101. The applicant successfully argued that the claims were not directed to an abstract idea but rather a concrete improvement in computer functionality by enabling security scheme selection on a per-user basis, which was asserted to be an unconventional technological improvement at the time of filing.
Case Timeline
| Date | Event |
|---|---|
| 1999-03-11 | U.S. Patent No. 10,114,905 Priority Date |
| 2018-10-30 | U.S. Patent No. 10,114,905 Issued |
| 2019-02-16 | Earliest date of alleged infringement cited in complaint |
| 2025-07-07 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,114,905 - "Individual User Selectable Multi-Level Authorization Method for Accessing a Computer System"
- Patent Identification: U.S. Patent No. 10,114,905, "Individual User Selectable Multi-Level Authorization Method for Accessing a Computer System," issued October 30, 2018.
The Invention Explained
- Problem Addressed: The complaint alleges that computer security systems at the time of the invention (priority date 1999) were deficient because they generally offered only a single, system-wide security scheme, which deprived individual users of the ability to customize their security level (Compl. ¶16).
- The Patented Solution: The invention is a computer-implemented method that provides users of a system with a choice from a plurality of security schemes, where at least one scheme is more secure (e.g., requires more identification information) than another. Each user’s selection is stored in their individual account and subsequently used to authorize their access, allowing for a user-customizable balance between security and convenience (’905 Patent, Abstract; Compl. ¶17). The system is described as being able to implement different "Identification and Security means" (I&S) for each user, allowing a user to "choose the I&S that best meets their particular I&S needs" (’905 Patent, col. 14:56-59).
- Technical Importance: The technology is framed as a concrete improvement to computer functionality by introducing user-level customization of security strength, a concept the patentee argued was unconventional at the time of filing (Compl. ¶14).
Key Claims at a Glance
- The complaint asserts direct infringement of claims 1-20, with independent claims 1, 9, and 18 (’905 Patent, col. 45:11-48:22; Compl. ¶36).
- Independent claim 1, a method claim, includes the following essential elements:
- Arranging a storage area on a computer system to include multiple user accounts.
- Prompting a user to select a security scheme from a plurality of available schemes, where a first scheme requires a specific amount of identification information and a second scheme requires additional identification information.
- Storing the user’s selection as a preference in that user’s storage area.
- Authorizing the user’s access to the system only when the requirements of their selected security scheme are met.
III. The Accused Instrumentality
Product Identification
The Accused Products are "all versions and variants of the FastMail's Website since at least 2019," which provide an email, contact, and calendar platform (Compl. ¶25).
Functionality and Market Context
The complaint focuses on the security settings of the FastMail service. It alleges that users are given a choice between a "standard username/email and password security scheme" and a more secure "two-factor security scheme" (also referred to as two-step verification or 2FA) (Compl. ¶26). Activating the 2FA scheme requires the user to provide an additional piece of identification information—such as a code from an authenticator app, a physical security key, or an SMS code—to log in (Compl. ¶31). A screenshot from FastMail's website, included in the complaint, explains that 2FA "increases the security of your account by requiring something you have... to be paired with something you know (your password)" (Compl. p. 10). The user's choice to enable or disable 2FA is stored as a preference for their account (Compl. ¶29).
IV. Analysis of Infringement Allegations
’905 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A computer-implemented method for...providing a plurality of security schemes... | The FastMail system allegedly provides two security schemes: a standard scheme (username/password) and a two-factor security scheme (username/password plus a 2FA code). | ¶26, ¶30, ¶31 | col. 13:42-48 |
| arranging at least one storage area of the computer system to include a plurality of user accounts each with a respective user storage area; | The FastMail service runs on a computer system with servers that host a plurality of user accounts, each with its own storage area for user-specific data and preferences. | ¶27 | col. 45:21-25 |
| prompting the particular user...for a selection of a particular security scheme from among the plurality of security schemes, wherein a first...requires a specific number of identification information...and a second...requires additional identification information... | FastMail prompts users to select a security scheme via its user interface, which includes a "Password & Security" screen. The standard scheme requires two pieces of information (username, password), while the 2FA scheme requires a third piece (e.g., a verification code). A provided screenshot shows the interface for this selection (Compl. p. 11). | ¶28, ¶30, ¶31 | col. 45:26-36 |
| storing the selection as a preference in the particular user's storage area; | A user's choice to enable or disable 2FA is allegedly stored as a preference in their account's storage area, dictating the security requirements for subsequent logins. | ¶29, ¶32 | col. 45:37-39 |
| thereafter authorizing the particular user to access the computer system when the selected security scheme of the particular user is satisfied. | The system authorizes access based on the stored preference. If 2FA is enabled, the user must provide the third piece of identification; if not, only the username and password are required. | ¶33 | col. 45:40-43 |
Identified Points of Contention
- Scope Questions: The ’905 patent has a 1999 priority date and a specification heavily focused on telephone-based interactive voice response (IVR) and fax-based message publishing systems. A central legal question may be whether the term "security scheme," as used in the patent, can be construed to cover modern, web-based two-factor authentication, or if its scope is implicitly limited by the patent's original technological context.
- Technical Questions: The complaint alleges that navigating to a settings page to enable 2FA constitutes being "prompted... for a selection." A potential point of contention is whether this user-initiated action meets the claim limitation, or if the claim requires a more active, system-initiated prompt, such as during an initial account setup workflow, as might be suggested by the patent’s IVR-based examples.
V. Key Claim Terms for Construction
Term for Construction: "plurality of security schemes"
- Context and Importance: This term is foundational to the infringement claim. Its construction will determine whether FastMail's system—which offers a default state (password only) and an optional, enhanced state (2FA enabled)—meets the limitation. Practitioners may focus on this term because its interpretation will decide if a binary on/off security feature qualifies as a "plurality" from which a user "selects."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The ordinary meaning of "plurality" is two or more. Plaintiff alleges that a standard password scheme and a 2FA scheme are two distinct schemes, thus meeting the plain language of the term (Compl. ¶26).
- Evidence for a Narrower Interpretation: The patent specification describes an interactive menu of options presented to a user (e.g., ’905 Patent, Fig. 5, step 555, "USER OPTIONS/PREFERENCES MENU"). A defendant may argue this context implies a choice among multiple, discrete, co-equal options, rather than toggling a single additional security layer on or off.
Term for Construction: "prompting the particular user... for a selection"
- Context and Importance: The infringement allegation hinges on whether presenting an option within a settings menu that a user must navigate to constitutes "prompting." The case may turn on whether this requires an active, system-initiated prompt or if a passive, available-upon-request option suffices.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The complaint alleges FastMail's user interface offers a "security settings prompt" (Compl. ¶28). The term "prompt" can be broadly interpreted to mean any user interface element that elicits a choice.
- Evidence for a Narrower Interpretation: The patent’s detailed description is rooted in IVR systems, where a user is audibly and sequentially prompted to make a selection (e.g., "press '1' to publish a fax") (’905 Patent, col. 18:62-67). This may support an argument that the term requires an unavoidable, active prompt rather than an optional setting on a configuration page.
VI. Other Allegations
Indirect Infringement
The complaint alleges induced infringement under 35 U.S.C. § 271(b), stating that FastMail encourages infringement by providing instructions, online documentation, technical support, and marketing materials that instruct customers on how to use the accused user-selectable security features (Compl. ¶40).
Willful Infringement
Willfulness is alleged based on FastMail acting with "knowledge of the 905 Patent and with the intent, or willful blindness" that its actions constituted infringement (Compl. ¶41). The complaint does not specify whether this knowledge is alleged to be pre- or post-suit.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of patent eligibility and context: Given the patent’s 1999 priority date and its prosecution history overcoming a § 101 rejection, a key question will be whether the claims are properly construed as a patent-eligible technological improvement, or as an abstract idea of offering security options that is preemptively broad when applied to modern web technologies far removed from the patent's original IVR and fax-based disclosure.
- A central question of claim construction will determine the outcome: Can the term "plurality of security schemes," which originates in a patent describing distinct menu options, be interpreted to read on a modern system that offers a single security feature (2FA) that a user can either enable or disable?
- A key evidentiary question will be one of factual infringement: Does a user proactively navigating to a settings page to configure 2FA satisfy the claim element of the system "prompting the particular user... for a selection," or does the patent's specification require a more direct, system-initiated prompt for the claim to be met?