Secure Matrix LLC v. Taco Bueno Restaurants Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Secure Matrix LLC (DE)
  • Defendant: Taco Bueno Restaurants, Inc. (DE)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: Secure Matrix LLC v. Taco Bueno Restaurants, Inc., 2:25-cv-00011, E.D. Tex., 01/06/2025
• Venue Allegations: Venue is alleged to be proper based on Defendant having an established place of business in the district and having committed alleged acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to systems and methods for user authentication that utilize a mobile device.
• Technical Context: The technology concerns secure user authentication for online portals or real-world devices, a critical function for e-commerce, online account access, and secure transactions.
• 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"

• Patent Identification: U.S. Patent No. 8,677,116, "Systems and methods for authentication and verification," issued March 18, 2014. (Compl. ¶¶ 8-9).

The Invention Explained

• Problem Addressed: The patent identifies a "growing need to authenticate users trying to access a secured internet portal... or a real-world secured device" and the corresponding need for a "secure and fast online electronic payment capability." (’116 Patent, col. 1:20-28).
• The Patented Solution: The invention describes a multi-party authentication process. A primary computer (e.g., a web server) provides a "reusable identifier" to a user. A separate electronic device belonging to the user (e.g., a smartphone) captures this identifier, combines it with user verification information, and sends both to a distinct verification server. This server then evaluates the combined information to determine if the user is authorized and, if so, transmits an authorization signal to permit the interaction. (’116 Patent, Abstract; Fig. 2). The system architecture distinguishes between the computer providing the service, the user's device, and the verification system. (’116 Patent, col. 5:26-33).
• Technical Importance: The use of a "reusable identifier" that does not contain sensitive user- or transaction-specific information is described as an advantage, potentially making the system faster, more reliable, and scalable compared to systems that generate complex, one-time-use codes for each transaction. (’116 Patent, col. 6:35-52).

Key Claims at a Glance

• The complaint alleges infringement of "one or more claims" but does not identify any specific asserted claims in its text, instead referring to "Exemplary '116 Patent Claims" in a non-provided exhibit. (Compl. ¶¶ 11, 16).
• Independent Claim 1, as a representative example, includes the following essential elements:
  • Using a computer system to receive a first signal from a computer that provides a secured capability, where the signal comprises a "reusable identifier" assigned for use for a "finite period of time."
  • Using the computer system to receive a second signal from a user's electronic device, where the signal comprises a copy of the reusable identifier and "user verification information."
  • Using a processor of the computer system to evaluate, based on the first and second signals, whether the user is authorized.
  • Transmitting a third signal with authorization information to the user's device or the first computer in response to a successful evaluation. (’116 Patent, col. 33:18-39).
• 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 "Defendant products" and "Exemplary Defendant Products" that are purportedly identified in charts within a non-provided exhibit. (Compl. ¶11, ¶16).

Functionality and Market Context

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

IV. Analysis of Infringement Allegations

The complaint alleges infringement by incorporating by reference claim charts in a non-provided "Exhibit 2." (Compl. ¶¶ 16-17). As the exhibit containing the specific infringement allegations is not available, a detailed claim chart summary cannot be constructed. The complaint provides no narrative description of the accused product's functionality that could be mapped to the claim elements. No probative visual evidence provided in complaint.

Identified Points of Contention

Based on the patent's claims and the general nature of the dispute, the infringement analysis raises several questions:

• Architectural Questions: What evidence will Plaintiff provide that Defendant's system architecture maps to the three distinct entities required by Claim 1: a "computer providing the secured capability," a user's "electronic device," and a separate "computer system" (verification server) that performs the claimed evaluation steps?
• Technical Questions: How will Plaintiff demonstrate that any token or identifier used in the accused system functions as a "reusable identifier" that is specifically "assigned for use... for a finite period of time," as claimed, rather than a conventional session ID or other type of authentication token? (’116 Patent, col. 33:24-25). What constitutes the "user verification information" in the accused system, and how is it transmitted? (’116 Patent, col. 33:29-30).

V. Key Claim Terms for Construction

"reusable identifier"

• Context and Importance: This term is central to the invention's purported novelty. Its construction will determine whether a wide range of authentication tokens (e.g., session IDs, QR codes) fall within the claim scope. Practitioners may focus on this term because the patent repeatedly distinguishes it from "one-time-use" or "unique" identifiers used in conventional systems. (e.g., ’116 Patent, col. 9:10-21).
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests the identifier can be reused for "multiple users and multiple transactions," which could support a broad reading not tied to a single user session. (’116 Patent, col. 9:15-16).
  • Evidence for a Narrower Interpretation: The specification explicitly states the identifier "does not contain user-specific or interaction-specific information," which could be used to argue that tokens containing such data are outside the scope. (’116 Patent, col. 33:40-42).

"assigned for use by the secured capability for a finite period of time"

• Context and Importance: This limitation defines the temporal nature of the "reusable identifier". The infringement analysis depends on whether the accused system's identifiers have this specific lifecycle property.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the "finite and predetermined period of time" as potentially being "one or more minutes, one or more hours, one or more days," suggesting significant flexibility. (’116 Patent, col. 9:43-45).
  • Evidence for a Narrower Interpretation: The description of using identifiers "sequentially" in a "round robin fashion" may suggest a more structured, managed, and potentially shorter period of validity than an open-ended session. (’116 Patent, col. 9:30-41).

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendant induces infringement by distributing "product literature and website materials" that instruct end-users on how to use the accused products in an infringing manner. (Compl. ¶14).
• Willful Infringement: The willfulness allegation is based exclusively on alleged post-suit knowledge. The complaint asserts that service of the complaint itself provided Defendant with "actual knowledge of infringement" and that any continued infringement thereafter is willful. (Compl. ¶¶ 13-14).

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

1. Evidentiary Sufficiency: A threshold question is whether the complaint, which fails to identify any specific accused product or provide the exhibits detailing its infringement theory, can survive a motion to dismiss. The case will depend on what specific products are ultimately accused and the evidence of their technical operation.
2. Claim Construction: The dispute will likely focus on the definitional scope of the core claim terms. A key issue will be whether the phrase "reusable identifier... assigned for use... for a finite period of time" can be construed to read on the authentication tokens used in the accused system, or if those tokens operate in a fundamentally different manner.
3. Architectural Mapping: A central evidentiary challenge for the Plaintiff will be to prove that the accused system's architecture comprises the three distinct components recited in the claims (service computer, user device, and verification system) and that they interact in the specific sequence mandated by the patent.