DCT
2:25-cv-00703
Intercurrency Software LLC v. Worldremit Ltd
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Intercurrency Software LLC (Texas)
- Defendant: WorldRemit Limited (England)
- Plaintiff’s Counsel: Garteiser Honea, PLLC
- Case Identification: 2:25-cv-00703, E.D. Tex., 11/24/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant is not a U.S. resident and is subject to personal jurisdiction in the district, where it allegedly conducts regular business and where acts of infringement occurred.
- Core Dispute: Plaintiff alleges that Defendant’s international money transfer platform infringes a patent related to a consolidated financial trading platform that performs currency conversions at the transactional level.
- Technical Context: The technology concerns online financial platforms that integrate real-time currency exchange data into asset transactions to provide users with price certainty in their preferred currency.
- Key Procedural History: The operative complaint is a Second Amended Complaint. The complaint alleges the patent-in-suit has been cited by patents issued to Bank of America and argues that the claims are patent-eligible, noting that they were allowed by the USPTO over prior art.
Case Timeline
| Date | Event |
|---|---|
| 2007-04-18 | U.S. Patent No. 11,620,701 Priority Date |
| 2023-04-04 | U.S. Patent No. 11,620,701 Issued |
| 2025-11-24 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,620,701 - Platform for trading assets in different currencies
- Patent Identification: U.S. Patent No. 11,620,701, "Platform for trading assets in different currencies," issued April 4, 2023.
The Invention Explained
- Problem Addressed: The patent describes a problem in prior art financial trading systems where an investor trading an asset in a foreign currency (e.g., a Chinese investor buying U.S. stocks) had no certainty of their ultimate profit or loss at the time of the trade. This was because the currency conversion had to be performed separately from the asset transaction, exposing the investor to risks from fluctuating exchange rates (’701 Patent, col. 1:49-60). The patent asserts that prior systems did not perform currency conversion "at a transactional level" (Compl. ¶28; ’701 Patent, col. 1:61-63).
- The Patented Solution: The invention is a "consolidated trading platform" that integrates three elements: a brokerage, a market exchange, and a currency exchange (’701 Patent, col. 2:24-33). This "three-tier architecture" allows the platform to present all prices, fees, and potential profits or losses to a trader in their "preferred currency" by using real-time exchange rates (’701 Patent, Abstract; Fig. 2B). The result is that a trader "always knows exactly what he/she may end up with" before committing to a transaction (’701 Patent, col. 2:32-34).
- Technical Importance: The claimed invention purports to provide a technical solution that gives traders certainty in cross-border, multi-currency asset transactions by computationally linking asset pricing with real-time currency exchange rates on a single platform (Compl. ¶31, ¶47).
Key Claims at a Glance
- The complaint asserts independent claims 1 and 8 (Compl. ¶55).
- Independent Claim 1 recites a platform for trading an asset, comprising:
- A trading server coupled to a client machine and receiving an indicator of a first currency (a "preferred currency").
- The trading server is configured to couple to at least one currency exchange server and at least one market exchange server.
- The trading server is configured to calculate and display costs and fees in the first currency for an asset traded in a second currency.
- These costs and fees are "dynamically changed" based on a "first prevailing exchange rate."
- The trading server conducts a transaction by sending a request to the market exchange server.
- The transaction settlement is based on a "second prevailing exchange rate" calculated at the time the transaction is performed.
- Independent Claim 8 recites a platform for trading an asset, comprising:
- A client machine coupled to a trading server, executing software to send an indicator of a first currency.
- The trading server is coupled to currency and market exchange servers and calculates costs/fees in the first currency for an asset traded in a second currency.
- The client machine is caused to display the dynamically changing costs and fees.
- A transaction is conducted in response to an order from the client machine, with the client machine receiving a settlement based on a second prevailing exchange rate.
III. The Accused Instrumentality
Product Identification
- The "WorldRemit international money transfer platforms and systems" ("Accused Instrumentalities") (Compl. ¶50).
Functionality and Market Context
- The Accused Instrumentalities provide an online service for international money transfers, allowing users to send money from one country in one currency to a recipient in another country in a different currency (Compl. ¶7, ¶50).
- The service displays the amount the recipient will receive in their local currency based on a prevailing exchange rate provided at the time of the transaction, and it discloses any associated fees (Compl. p. 14). A screenshot in the complaint shows a user interface for sending 1000 USD, which is converted to 56,683 PHP based on a specified exchange rate, with a fee of 0 USD displayed (Compl. p. 14).
- The complaint alleges Defendant operates a global service serving 5.7 million customers across 130 countries and using over 70 currencies (Compl. ¶8).
IV. Analysis of Infringement Allegations
U.S. Patent No. 11,620,701 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A platform for trading an asset, the platform comprising: a trading server, coupled to a client machine associated with a user, receiving an indicator of a first currency from the client machine... | Defendant's platform, including its trading servers, is coupled to users' client machines and receives an indicator of the user's currency for the transfer. | ¶55 | col. 3:1-4 |
| wherein the trading server is configured to couple to at least one currency exchange server and at least one market exchange server... | Defendant allegedly provides a trading server coupled to one or more currency exchange servers and one or more market exchange servers. | ¶55 | col. 5:1-6 |
| the trading server is further configured to calculate costs and fees in the first currency to own or sell the asset being traded in a second currency... | The WorldRemit platform calculates and displays the total cost to the sender in the first currency (e.g., USD) to complete the transfer of the asset (money) in a second currency (e.g., PHP). | ¶50, p. 14 | col. 5:54-60 |
| the costs and fees are caused to be displayed on a display device of the client machine and are dynamically changed in accordance with a first prevailing exchange rate between the first currency and the second currency... | The WorldRemit user interface displays the exchange rate and fees, which are based on prevailing rates that fluctuate. | ¶50, p. 14 | col. 8:55-65 |
| wherein the trading server is configured to conduct a transaction of the asset by transporting a transaction request to the market exchange server upon receiving an order from the trader... | The complaint does not provide sufficient detail for analysis of this specific element. | col. 9:5-9 | |
| and reach a settlement based on a second prevailing exchange rate as soon as the transaction of the asset is performed in accordance with conditions set by the trader... | The money transfer is executed at a specific exchange rate locked in at the time of the transaction, which constitutes the settlement. | ¶50, p. 14 | col. 9:10-23 |
- Identified Points of Contention:
- Scope Questions: A central dispute may arise over the definition of "trading an asset." The patent specification repeatedly frames the invention in the context of financial securities like stocks, bonds, and commodities (’701 Patent, col. 2:20-23). The question for the court will be whether the act of remitting money constitutes "trading an asset" within the scope of the claims. A related question is whether Defendant's remittance infrastructure can be considered to include a "market exchange server," a term typically associated with securities and commodities markets.
- Technical Questions: What evidence does the complaint provide that Defendant's system architecture maps onto the claimed three-tier structure of a distinct "trading server," "currency exchange server," and "market exchange server"? The complaint makes a conclusory allegation on this point (Compl. ¶55), which suggests that the actual configuration of Defendant's servers will be a key area of factual dispute.
V. Key Claim Terms for Construction
The Term: "asset"
Context and Importance: The applicability of the patent to Defendant's money transfer service hinges on whether "currency" itself is considered an "asset" being "traded." Practitioners may focus on this term because if it is construed narrowly to mean only securities or commodities, the infringement case may fail.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim itself uses the general term "asset" without express limitation to securities. The plain and ordinary meaning of "asset" can include currency.
- Evidence for a Narrower Interpretation: The patent's Background and Detailed Description sections consistently use examples of securities, such as "US securities," "stocks," "bonds, options, commodities (e.g., oil, gold)," and futures contracts, to describe the invention's context and purpose (’701 Patent, col. 1:31-33; col. 2:20-23; col. 5:44-46). This repeated framing may support an argument that "asset" should be limited to such instruments.
The Term: "market exchange server"
Context and Importance: Claim 1 requires the "trading server" to be coupled to a "market exchange server" and to send it a "transaction request." The infringement allegation depends on whether any component of Defendant's remittance system performs the function of a "market exchange server."
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term is not explicitly defined, which could support an argument that any server system where value is exchanged meets the definition.
- Evidence for a Narrower Interpretation: The specification provides specific examples of a market exchange, such as the NYSE, suggesting a formal, organized market for trading instruments like securities (’701 Patent, col. 5:4-6). Defendant may argue its system for clearing international payments does not constitute a "market exchange server" in the manner disclosed in the patent.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Defendant induces infringement by advertising its service and providing the platform for use by its customers, knowing that such use would constitute infringement (Compl. ¶60-¶63).
- Willful Infringement: Willfulness is alleged based on Defendant’s continued infringement after having notice of the '701 patent via the filing and service of the complaint (Compl. ¶59). The complaint also alleges "willful blindness" based on a purported "practice of not performing a review of the patent rights of others" before launching products (Compl. ¶64).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "asset," as used in a patent describing a platform for trading securities and commodities, be construed to cover currency in the context of an international money transfer service?
- A key technical and factual question will be one of structural correspondence: does Defendant’s remittance platform embody the claimed three-part architecture of a distinct "trading server," "currency exchange server," and "market exchange server," or is there a fundamental mismatch between the claimed system and the accused service's infrastructure?
- An evidentiary question will be one of functionality: does the processing of a money transfer request in Defendant's system constitute "transporting a transaction request to the market exchange server" as required by the claim, or does the accused system operate in a technically distinct manner?