FinTegrity LLC v. Seon Tech KFT

I. Executive Summary and Procedural Information

• Case Name: FinTegrity LLC v. SEON Technologies Kft.
• Parties & Counsel:
  • Plaintiff: FinTegrity LLC (New Mexico)
  • Defendant: SEON Technologies Kft. (Hungary)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-293, E.D. Tex., 03/12/2025
• Venue Allegations: Venue is asserted on the basis that the Defendant is a foreign corporation.
• Core Dispute: Plaintiff alleges that Defendant’s unnamed fraud protection products infringe a patent related to authorizing financial transactions by comparing transaction details with user data obtained from third-party sources like social media.
• Technical Context: The technology addresses financial fraud detection by supplementing traditional transaction data with dynamic, real-time user information from sources such as social media networks to improve identity verification.
• Key Procedural History: The asserted patent is a continuation of a prior application. The complaint itself is alleged to provide Defendant with actual knowledge of infringement, forming the basis for post-suit willfulness allegations.

Case Timeline

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

• U.S. Patent No. 8,635,117, "System and method for consumer fraud protection," issued January 21, 2014

The Invention Explained

• Problem Addressed: The patent asserts that prior art fraud detection methods rely on "computationally complex heuristics and expensive computer systems" that are often slow, produce incorrect results by flagging legitimate transactions or missing fraudulent ones, and lack access to a user's real-time data ('117 Patent, col. 1:30-45).
• The Patented Solution: The invention describes a process and system for authorizing a financial transaction by augmenting traditional transaction data with information from external sources. The system retrieves "transaction-data" (e.g., merchant location, purchase amount) and compares it to "user-data" (e.g., social media check-ins, 'liked' merchants, calendar events) retrieved from a "third-party information source" like a social media network to authorize or deny the transaction ('117 Patent, Abstract; col. 2:57-64). Figure 1 illustrates this architecture, showing a central authorization system (104) pulling data from both a point-of-sale system (110) and a third-party source (106) to make a determination ('117 Patent, Fig. 1).
• Technical Importance: The described technology aims to improve the accuracy and efficiency of fraud detection by leveraging dynamic, user-generated data that reflects a consumer's real-time location and intentions, a data source not typically used in conventional, purely financial-based systems ('117 Patent, col. 1:46-52).

Key Claims at a Glance

The complaint alleges infringement of "one or more claims" and "Exemplary '117 Patent Claims" without specifying them, instead referring to an unprovided exhibit (Compl. ¶¶ 11, 16). The analysis below focuses on the first independent claim as a representative example. The complaint implicitly reserves the right to assert additional claims.

• Independent Claim 1 (Process):
  • Retrieving transaction-data associated with a financial transaction from a financial institution's server.
  • Retrieving user-data from a third-party information source, where the user-data describes attributes of either an authorized or an unauthorized financial transaction.
  • Comparing the transaction-data to the user-data to generate either an "authorization flag" or a "denial flag."
  • Communicating the generated flag back to the financial institution's server to complete or block the transaction.

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products, referring to them generally as "Defendant products" and "Exemplary Defendant Products" (Compl. ¶11). It states these products are identified in an attached Exhibit 2, which was not provided with the complaint document (Compl. ¶16).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's specific functionality. It makes the conclusory allegation that the accused products "practice the technology claimed by the '117 Patent" and that they are made, used, sold, and imported in the United States (Compl. ¶¶ 11, 16).

IV. Analysis of Infringement Allegations

The complaint references, but does not include, claim charts in an "Exhibit 2" that purportedly compare the asserted claims to the accused products (Compl. ¶17). In the absence of these charts and any specific factual allegations in the complaint body, a detailed infringement analysis is not possible.

The complaint’s narrative theory is that the Defendant's products directly infringe because they "practice the technology claimed by the '117 Patent" and "satisfy all elements of the Exemplary '117 Patent Claims" (Compl. ¶16). Direct infringement is also alleged based on Defendant’s internal testing of the products (Compl. ¶12).

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Evidentiary Question: A primary issue will be whether Plaintiff can produce evidence demonstrating how the unnamed accused products perform the specific steps of the asserted claims. The complaint itself offers no such evidence, making it impossible to assess the factual basis for the infringement allegations.
  • Technical Question: Assuming Plaintiff later provides evidence, a key technical question will be whether the accused products actually "retrieve" data from a "third-party information source" as required by the claim, or if they rely on data generated internally, by a financial institution, or by other non-third-party sources.
  • Scope Question: A central legal dispute may arise over the definition of "comparing." The court may need to determine if the accused system’s method for analyzing data and flagging transactions performs the specific comparison recited in the claims or operates in a fundamentally different manner.

V. Key Claim Terms for Construction

• The Term: "third-party information source"

  • Context and Importance: This term is foundational to the patent's novelty, as it distinguishes the invention from systems that rely only on data held by the parties to a transaction. The outcome of the case may depend on whether the data sources used by Defendant's system qualify as a "third-party information source".
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification provides a broad list of examples, including "Social Media Networks, common interest forums and/or e-mail domains (e.g., Gmail.com, Yahoo.com)" ('117 Patent, col. 6:8-11), which could support an interpretation covering any data provider external to the user and the financial institution.
    • Evidence for a Narrower Interpretation: The specification heavily emphasizes "Social Media Networks" and gives specific examples like "Facebook®, MySpace®, Google+®, Twitter®, and Foursquare®" ('117 Patent, col. 4:35-39). A party could argue the term should be construed more narrowly to mean public or semi-public networks where users voluntarily share personal activity data, rather than any commercial data vendor.

• The Term: "user-data"

  • Context and Importance: The infringement analysis depends entirely on what type of information the accused system uses and whether it falls within the patent's definition of "user-data". Practitioners may focus on this term because it defines the informational input that drives the claimed invention.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent provides a wide-ranging list of potential "user-data" types, including "approved merchants, a shared Location, a user behavior, or a calendar event" ('117 Patent, col. 2:61-63) and "relationship status, and social event calendars" ('117 Patent, col. 8:17-19). This language suggests the term covers a diverse set of personal information.
    • Evidence for a Narrower Interpretation: The specification describes a process where the user actively links accounts and "may designate the type of user-data" to be shared ('117 Patent, col. 8:10-12; Fig. 2). This could support an argument that "user-data" is limited to information that a user has explicitly and consciously authorized for sharing in a fraud-detection context, as opposed to data that is passively collected or inferred.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant provides "product literature and website materials" that instruct customers on how to use the accused products in an infringing manner (Compl. ¶14). The specifics of these materials are purportedly detailed in the unprovided Exhibit 2 (Compl. ¶14).
• Willful Infringement: The allegation of willfulness is based entirely on post-suit conduct. The complaint asserts that the filing of the lawsuit itself provides "actual knowledge of infringement," and that any continued infringing activity by the Defendant thereafter is willful (Compl. ¶¶ 13-14).

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

• A primary issue will be one of evidentiary sufficiency: given that the complaint lacks specific factual allegations and relies on an unprovided exhibit, a threshold question is what evidence Plaintiff will introduce to connect the functionality of any specific SEON product to the limitations of the asserted claims.
• The case will likely turn on definitional scope: can the patent’s core terms, such as "third-party information source" and "user-data", be construed to read on the specific data sources and data types utilized by Defendant's fraud-detection technology? The resolution of this question will likely determine the outcome of the infringement analysis.
• A third key question relates to inducement: assuming direct infringement is established, the court will have to decide whether Defendant’s customer-facing materials actively "encourage" or "instruct" users to perform the claimed steps, thereby demonstrating the specific intent required for a finding of induced infringement.