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: bitFlyer Inc. (Japan)
- Plaintiff’s Counsel: Garteiser Honea, PLLC
- Case Identification: 2:25-cv-00703, E.D. Tex., 01/12/2026
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is subject to personal jurisdiction in the district, transacts substantial business there, and has committed acts of infringement in the district, including offering to sell and selling accused products.
- Core Dispute: Plaintiff alleges that Defendant’s cryptocurrency trading platforms infringe a patent related to systems for conducting financial transactions in a user’s preferred currency.
- Technical Context: The technology addresses the complexities of international financial trading by integrating real-time currency conversion into the trading process, a significant issue in both traditional securities and modern digital asset markets.
- Key Procedural History: This First Amended Complaint is filed in a lead case with several member cases against other defendants. The asserted patent is a continuation of an earlier patent, U.S. Patent No. 10,062,107.
Case Timeline
| Date | Event |
|---|---|
| 2007-04-18 | Priority Date for U.S. Patent No. 11,620,701 |
| 2014-XX-XX | Defendant bitFlyer founded |
| 2023-04-04 | U.S. Patent No. 11,620,701 Issued |
| 2026-01-12 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,620,701 - *"Platform for Trading Assets in Different Currencies"*
The Invention Explained
- Problem Addressed: In traditional systems for trading foreign assets (e.g., a Chinese investor buying U.S. stocks), the currency conversion happens separately from the asset transaction. This creates uncertainty, as an investor has "no certain knowledge of what profit or loss he was going to get because the currency exchange rate... may fluctuate significantly enough to affect the ultimate profit or loss" (’701 Patent, col. 1:55-63; Compl. ¶31). The prior art lacked the ability to perform currency conversion "at a transactional level" ('701 Patent, col. 2:1-3; Compl. ¶32).
- The Patented Solution: The invention proposes a consolidated trading platform using a "three-tier architecture" that includes a brokerage, a market exchange for the asset, and a currency exchange ('701 Patent, col. 2:25-33; Compl. ¶34). This system presents all prices, fees, and potential profit/loss estimates to the trader in their preferred currency by using a real-time "prevailing exchange rate" ('701 Patent, col. 2:30-33). This integration allows a trader to "always know exactly what he/she may end up with" before committing to a transaction ('701 Patent, col. 2:35-37; Compl. ¶35).
- Technical Importance: The described approach aimed to reduce risk and uncertainty in cross-border financial transactions by technologically coupling the asset trade with the currency conversion. (Compl. ¶39, 51).
Key Claims at a Glance
- The complaint asserts independent claims 1 and 8 ('701 Patent; Compl. ¶60).
- Essential Elements of Independent Claim 1 (System Claim):
- A trading server coupled to a client machine, at least one currency exchange server, and at least one market exchange server.
- The server is configured to calculate costs and fees in a first currency (the user's preference) for an asset traded in a second currency.
- The costs and fees are displayed on the client machine and are "dynamically changed in accordance with a first prevailing exchange rate."
- The server conducts a transaction by sending a request to the market exchange server.
- The server reaches a settlement based on a "second prevailing exchange rate" calculated when the transaction is performed.
- Essential Elements of Independent Claim 8 (System Claim):
- A client machine coupled to a trading server, executing a software product.
- The software sends an indicator of a first (preferred) currency to the server.
- The client machine displays costs and fees for an asset traded in a second currency, which are dynamically changed based on a "first prevailing exchange rate."
- The client machine receives a settlement based on a "second prevailing exchange rate" calculated by the trading server "right before the transaction takes place."
III. The Accused Instrumentality
Product Identification
- The "bitFlyer trading platforms and systems, and corresponding mobile apps," which constitute a consolidated platform for trading cryptocurrency (Compl. ¶55).
Functionality and Market Context
- The complaint describes the accused instrumentalities as a global cryptocurrency exchange platform that allows users to buy and sell digital assets like Bitcoin (Compl. ¶4-7). The complaint alleges that Defendant "provides a trading server... coupled to one or more currency exchange servers... and one or more market exchange servers" to facilitate these transactions (Compl. ¶60). A screenshot from Defendant's website shows a trading interface for the "Bitcoin Marketplace," displaying price charts and buy/sell functions (Compl. p. 16). The platform is positioned as a major global exchange, with the complaint noting it is the "largest bitcoin exchange in the world by volume" at one point and trusted by millions of customers (Compl. ¶7).
IV. Analysis of Infringement Allegations
'701 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a trading server, coupled to a client machine associated with a user, ... wherein the trading server is configured to couple to at least one currency exchange server and at least one market exchange server | Defendant provides a trading server (its platform) that is coupled to currency exchange servers and market exchange servers. | ¶60 | col. 11:41-48 |
| 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 bitFlyer platform allows users to trade crypto assets (second currency) using fiat currency (first currency) and displays the associated costs. | ¶55 | col. 11:48-54 |
| 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 | The bitFlyer user interface on web and mobile apps displays dynamically updated prices and fees for crypto transactions. | ¶55, p. 16 | col. 11:55-61 |
| 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 bitFlyer platform executes user orders to buy or sell cryptocurrency on its exchange. | ¶55, 60 | col. 11:62-65 |
| and reach a settlement based on a second prevailing exchange rate as soon as the transaction of the asset is performed | The bitFlyer platform settles transactions based on the exchange rate at the time of the trade. | ¶55, 60, 63 | col. 12:1-5 |
- Identified Points of Contention:
- Scope Questions: A central issue may be whether the term "currency exchange server", as described in the patent in the context of traditional foreign exchange (fiat currencies), can be construed to cover the systems used by bitFlyer for fiat-to-crypto or crypto-to-crypto conversions. Similarly, the definition of "market exchange server" from the patent's era may be contested as it applies to a modern cryptocurrency exchange.
- Technical Questions: The complaint alleges the existence of distinct "trading", "currency exchange", and "market exchange" servers in Defendant's architecture (Compl. ¶60). A technical question for the court will be whether the bitFlyer platform actually operates as a collection of discrete servers performing these specific, claimed functions, or if it is a more integrated system where these functionalities are not separately identifiable in the manner claimed.
V. Key Claim Terms for Construction
The Term: "trading server"
Context and Importance: The complaint characterizes the patented server as an "unconventional specialty trading server," not a "generic computer component" (Compl. ¶39, 44). The defendant will likely argue its servers are standard, off-the-shelf components performing conventional functions. The construction of this term will be critical to determining whether the invention is a specific, specialized machine or a more abstract process performed on general-purpose computers.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims describe the server in functional terms—what it is "configured to" do (e.g., "calculate costs and fees," "conduct a transaction")—which may support an interpretation covering any server that performs those functions ('701 Patent, cl. 1).
- Evidence for a Narrower Interpretation: The detailed description explains the server as part of a specific "three-tier architecture" that includes a brokerage, a market exchange, and a currency exchange ('701 Patent, col. 2:25-28). This architectural context could be used to argue for a narrower construction limited to servers operating within such a specific structure.
The Term: "currency exchange server"
Context and Importance: The infringement allegation depends on bitFlyer's system for converting between currencies (e.g., USD to BTC) meeting the definition of a "currency exchange server." Practitioners may focus on this term because its meaning is rooted in traditional finance, and its application to cryptocurrency systems is a point of potential technical and legal dispute.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims do not specify the type of currency, which could support reading the term to cover exchanges between any two units of value, including fiat and crypto. Claim 1 requires the server to provide a "prevailing exchange rate," a function performed by crypto exchanges ('701 Patent, col. 11:58-59).
- Evidence for a Narrower Interpretation: The background section discusses the problem in the context of trading U.S. securities using traditional foreign currencies like Chinese RMB ('701 Patent, col. 1:30-45). This context may support an argument that the term was intended to cover only servers dealing with sovereign fiat currencies.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement, stating Defendant took "active steps... such as advertising an infringing use, which supports a finding of an intention for the accused product to be used in an infringing manner" (Compl. ¶66, 68).
- Willful Infringement: Willfulness is alleged based on post-suit knowledge via the filing and service of the complaint (Compl. ¶64). The complaint also alleges pre-suit willful blindness, asserting Defendant has a "practice of not performing a review of the patent rights of others... prior to launching products" (Compl. ¶69).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope and technological evolution: Can claim terms like "currency exchange server" and "market exchange server", which are grounded in the patent's description of traditional securities and fiat currency markets, be construed to read on the distinct technical architecture of a modern cryptocurrency exchange that facilitates fiat-to-crypto and crypto-to-crypto transactions?
- A key evidentiary question will be one of architectural correspondence: What evidence will be presented to establish that Defendant's allegedly integrated trading platform functions as the discrete, multi-server "three-tier architecture" required by the patent claims, particularly concerning the interaction between a distinct "trading server" and separate "currency" and "market" exchange servers?
- A third question will concern the inventive concept in light of Alice: Does the claim's specific configuration of servers to dynamically calculate and display prices in a preferred currency represent a patent-eligible technical solution to a technical problem, as Plaintiff argues (Compl. ¶39, 51), or an abstract idea of performing currency conversion implemented on generic computers?