Secure Matrix LLC v. Sony Interactive Entertainment LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Secure Matrix LLC (DE)
  • Defendant: Sony Interactive Entertainment LLC (Japan)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:24-cv-00459, E.D. Tex., 06/18/2024
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant has an established place of business in the District and has committed acts of infringement there.
• Core Dispute: Plaintiff alleges that unspecified "Exemplary Defendant Products" sold by Defendant infringe a patent related to systems and methods for user authentication.
• Technical Context: The technology at issue involves using a secondary electronic device, such as a smartphone, to authenticate a user for a secured capability, such as logging into a website or authorizing a payment.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 8,677,116 - "Systems and methods for authentication and verification" (Issued March 18, 2014)

The Invention Explained

• Problem Addressed: The patent describes a "growing need to authenticate users trying to access a secured internet portal (e.g., website) or a real-world secured device (e.g., lock, door)" and the corresponding need for a "secure and fast online electronic payment capability" ('116 Patent, col. 2:20-29).
• The Patented Solution: The invention provides a method where a primary computer (e.g., a web server) provides a "reusable identifier" to a user (e.g., as a QR code on a login screen) and also to a separate verification server ('116 Patent, Fig. 2). The user employs a secondary electronic device (e.g., a smartphone) to capture this identifier, combine it with user verification information, and send the combined data to the verification server, which then evaluates whether to grant access ('116 Patent, Abstract; col. 6:20-33).
• Technical Importance: This approach claims advantages over conventional systems by using a "reusable identifier" that does not contain user-specific or transaction-specific data, which can simplify the system, make identifiers like QR codes easier to decode on mobile devices, and enhance security ('116 Patent, col. 6:34-62).

Key Claims at a Glance

• The complaint does not specify which claims are asserted, instead referring to "Exemplary '116 Patent Claims" identified in an unprovided exhibit (Compl. ¶11). Claim 1 is the first independent claim of the patent.
• Independent Claim 1 includes these essential elements:
  • Using a computer system to receive a first signal from a computer providing a secured capability, where the signal contains a "reusable identifier" that is "assigned for use by the secured capability for a finite period of time."
  • Using the computer system to receive a second signal from a user's electronic device, the signal containing a copy of the "reusable identifier" and "user verification information."
  • Using a processor to evaluate, based on the first and second signals, whether the user is authorized.
  • In response to an authorization, transmitting a third signal with "authorization information" to the electronic device and/or the computer.
• The complaint reserves the right to assert other claims, which may include dependent claims (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products, methods, or services by name (Compl. ¶11). It refers generally to "Exemplary Defendant Products" that are identified only in charts within an unprovided "Exhibit 2" (Compl. ¶¶16-17).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the functionality or market context of the accused instrumentalities.

IV. Analysis of Infringement Allegations

The complaint’s infringement allegations are not detailed in the body of the document. It states that "Exhibit 2 includes charts comparing the Exemplary '116 Patent Claims to the Exemplary Defendant Products" and that these charts demonstrate how the products "satisfy all elements of the Exemplary '116 Patent Claims" (Compl. ¶16). As Exhibit 2 was not filed with the complaint, a detailed claim chart analysis is not possible. The narrative theory is that Defendant makes, uses, sells, and/or imports products that practice the technology claimed by the '116 Patent, and also has its employees internally test and use these products (Compl. ¶¶11-12).

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: A central issue may be whether the accused products' authentication mechanism uses an identifier that meets the definition of a "reusable identifier" as described in the patent. The patent distinguishes this term from conventional "one-time-use" identifiers ('116 Patent, col. 9:8-13). The analysis will question whether the accused system's identifiers are truly reusable across different transactions or users, or if they are session-specific tokens that fall outside the patent's scope.
  • Technical Questions: Claim 1 requires the reusable identifier be "assigned for use... for a finite period of time." A key technical question will be what evidence Plaintiff provides to show that the accused system's identifiers are assigned for a "finite period" and how that period is defined and enforced, as contrasted with identifiers that expire upon a single use or logout event.

V. Key Claim Terms for Construction

• The Term: "reusable identifier"

  • Context and Importance: This term is the core of the claimed invention. Its construction will be critical in determining infringement, as it distinguishes the patented method from prior art. Practitioners may focus on this term because its scope will determine whether modern, dynamically-generated authentication tokens fall within the claims.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent states a reusable identifier is one "that can be used more than once" and is "not unique to one particular user or transaction" ('116 Patent, col. 9:9-13). This could be argued to encompass a wide range of non-single-use tokens.
    • Evidence for a Narrower Interpretation: The specification also states the identifier "does not contain user-specific or transaction-specific information" and can be used in a "round robin usage" from a "predefined and previously generated list" ('116 Patent, col. 9:13-15, 9:39-42). This could support a narrower construction limited to static, pre-generated identifiers that are cycled, excluding dynamically created session tokens.

• The Term: "assigned for use by the secured capability for a finite period of time"

  • Context and Importance: This limitation in Claim 1 adds a temporal constraint to the "reusable identifier". Its definition is crucial for determining if the lifecycle of an identifier in the accused system meets the claim requirement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The plain meaning of "finite period" could be argued to cover any non-infinite duration, such as the length of a user's session.
    • Evidence for a Narrower Interpretation: The specification gives examples of finite periods such as "one or more minutes, one or more hours, one or more days," after which the identifiers can be reused in "multiple such periods of time" ('116 Patent, col. 9:42-47). This might be argued to require a fixed, predetermined duration of validity, rather than an event-based expiration (e.g., upon logout).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes the '116 Patent" (Compl. ¶14). The complaint notes that an unprovided "Exhibit 2" extensively references these materials (Compl. ¶14).
• Willful Infringement: The complaint alleges Defendant has "Actual Knowledge of Infringement" based on "the service of this Complaint" (Compl. ¶13). This allegation supports a claim for post-filing willfulness or enhanced damages. The complaint does not allege any pre-suit knowledge of the patent or infringement.

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

1. Evidentiary Basis: A threshold question for the case is what specific products, services, and functionalities are actually being accused of infringement. The complaint defers this central information entirely to an unprovided external exhibit, leaving the basis for the lawsuit undefined on the face of the pleading.
2. Definitional Scope: The dispute will likely hinge on claim construction. A core issue will be whether the authentication mechanism in the accused products uses what can be legally defined as a "reusable identifier... assigned for use... for a finite period of time," as that term is used in the patent, or whether it uses a conventional single-use or session-based token that falls outside the claimed invention.
3. Functional Mismatch: Assuming an accused product is identified, a key evidentiary question will be one of operational function: does the accused system's multi-part communication flow (between a server, a user's primary device, and a user's secondary device) map onto the specific three-signal process required by Claim 1 of the '116 Patent, or is there a fundamental mismatch in the technical architecture and data exchange?