DCT
2:25-cv-00703
Intercurrency Software LLC v. Worldremit Ltd
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., 10/15/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is subject to personal jurisdiction in the district, conducts regular business there, and is not a resident of the United States.
- Core Dispute: Plaintiff alleges that Defendant’s international money transfer platform infringes a patent related to a consolidated trading system that allows users to transact in a preferred currency by integrating real-time currency exchange data.
- Technical Context: The technology addresses financial platforms that provide users with price certainty in cross-currency transactions by performing currency conversions at the transactional level, rather than as a separate, subsequent step.
- Key Procedural History: The operative complaint is a First Amended Complaint, indicating a prior version was filed. The complaint notes that the patent-in-suit stems from a patent family with a priority date in 2007 and that the underlying inventions were reviewed by multiple patent examiners before issuance.
Case Timeline
| Date | Event |
|---|---|
| 2007-04-18 | ’701 Patent Priority Date |
| 2023-04-04 | ’701 Patent Issue Date |
| 2025-10-15 | 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"
- 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's background section describes the uncertainty faced by investors when trading assets, such as U.S. stocks, that are priced in a currency different from the investor's local currency (’701 Patent, col. 1:24-35). Previously, an investor would need to perform a bulk currency exchange before trading and another exchange after selling, with the risk that exchange rate fluctuations between the time of the trade and the time of the currency conversion could significantly affect the ultimate profit or loss (Compl. ¶15; ’701 Patent, col. 1:53-60). This meant "the investor had no certain knowledge of what profit or loss he was going to get" (’701 Patent, col. 1:53-56).
- The Patented Solution: The invention proposes a "consolidated trading platform" that integrates a brokerage, a market exchange, and a currency exchange into a single system (’701 Patent, col. 2:24-28; Fig. 2B). This platform displays all prices, fees, and potential profits or losses to the user in their "preferred currency" by applying a "prevailing exchange rate" in real-time (’701 Patent, col. 2:30-33). By performing the currency conversion "at a transactional level," the system gives the trader exact knowledge of the transaction's value in their own currency at the moment of execution (Compl. ¶16; ’701 Patent, col. 1:63-67).
- Technical Importance: This approach aimed to provide price certainty and transparency in cross-border financial transactions by embedding the currency exchange function directly into the asset trading workflow (Compl. ¶35).
Key Claims at a Glance
- The complaint asserts independent claims 1 and 8 as exemplary (Compl. ¶43).
- Independent Claim 1 recites a system comprising:
- A "trading server" coupled to a client machine, a currency exchange server, and a market exchange server.
- The server calculates and displays "costs and fees" for an asset in a user's preferred "first currency," even when the asset is traded in a "second currency."
- The displayed costs are "dynamically changed" based on 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 as soon as the transaction of the asset is performed."
- Independent Claim 8 recites a platform from the perspective of the "client machine," which sends a preferred currency indicator to the trading server and displays the dynamically updated costs and fees calculated by the server, ultimately receiving a settlement based on the second prevailing exchange rate.
III. The Accused Instrumentality
Product Identification
- The "Accused Instrumentalities" are Defendant's "WorldRemit international money transfer platforms and systems" (Compl. ¶38).
Functionality and Market Context
- The complaint describes the accused instrumentality as a platform for sending money internationally, which inherently requires currency conversion (Compl. ¶3, ¶38). The complaint provides a screenshot of the WorldRemit user interface showing a user initiating a transfer of 1000 USD to be received as 56683 PHP, based on a displayed exchange rate and fee (Compl., p. 11). The complaint alleges that this functionality constitutes a "consolidated trading platform" as covered by the patent-in-suit (Compl. ¶38).
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... receiving an indicator of a first currency from the client machine | Defendant’s servers (the backend for the WorldRemit platform) are coupled to users' devices (client machines) and receive the user's selected currency for the transfer. | ¶43 | col. 5:2-4 |
| the trading server is configured to couple to at least one currency exchange server and at least one market exchange server | Defendant's servers are allegedly coupled to currency exchange servers to facilitate the money transfer from a source currency to a destination currency. | ¶43 | col. 3:1-2 |
| the trading server is further configured to calculate costs and fees in the first currency... the costs and fees are caused to be displayed... and are dynamically changed in accordance with a first prevailing exchange rate... | The WorldRemit platform calculates and displays the final amount in the destination currency and any associated fees, based on a "First Transfer Rate" shown to the user (Compl., p. 11). The complaint alleges these values are dynamically updated. | ¶27; p. 11 | col. 5:54-61 |
| wherein the trading server is configured to conduct a transaction of the asset... and reach a settlement based on a second prevailing exchange rate as soon as the transaction of the asset is performed... | After a user initiates a transfer by clicking "Send Money," Defendant’s system allegedly conducts the transaction and settles it using a prevailing exchange rate to complete the currency conversion and transfer. | ¶43; p. 11 | col. 6:4-9 |
- Identified Points of Contention:
- Scope Questions: A central dispute may arise over whether the terms "asset" and "trading server" as used in the patent read on the accused instrumentality. The patent's specification primarily discusses trading financial securities like stocks (’701 Patent, col. 1:31-35), raising the question of whether a currency transfer service constitutes a platform for "trading an asset."
- Technical Questions: Claim 1 requires a "first prevailing exchange rate" for display and a "second prevailing exchange rate" for settlement. The complaint provides a screenshot showing only one rate, labeled "First Transfer Rate" (Compl., p. 11). This raises the evidentiary question of whether the accused system uses two distinct, time-differentiated rates as required by the claim, or if it uses a single rate that is locked in when the user initiates the transaction.
V. Key Claim Terms for Construction
The Term: "asset"
- Context and Importance: The definition of "asset" will be critical. If the term is construed narrowly to mean financial securities (e.g., stocks, bonds), as discussed in the patent’s background examples, the accused money transfer service may fall outside the claim scope. If construed more broadly to include currency itself as a tradable commodity, the infringement argument may be stronger. Practitioners may focus on this term because the applicability of the patent to the accused technology hinges on its definition.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification lists "a wide array of electronically traded financial assets such as stocks, bonds, options, commodities (e.g., oil, gold), futures/derivatives contracts, funds..." (’701 Patent, col. 2:20-24). An argument could be made that currency is a type of commodity.
- Evidence for a Narrower Interpretation: The "Background" section frames the problem to be solved exclusively in the context of an "investor in China" trading "securities listed on a US exchange" and realizing "profit or loss on his US dollar-denominated stock" (’701 Patent, col. 1:36-52). This context may support limiting "asset" to traditional securities.
The Term: "trading server"
- Context and Importance: The patentability of the claims, particularly in response to a potential challenge under 35 U.S.C. § 101, could depend on this term's construction. The complaint asserts the claimed server is an "unconventional specialty trading server" and not a generic computer (Compl. ¶23, ¶28). Whether the server is construed as a specific, tangible improvement or a generic component used for an abstract financial process will be a key issue.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the server architecture in functional terms, stating it "may be implemented in a single computing machine which may be viewed as a single server or distributed over many servers owned by different organizations" (’701 Patent, col. 5:29-32). This could support a broader, more functional definition.
- Evidence for a Narrower Interpretation: The claims require the "trading server" to be specifically configured to perform an ordered combination of steps: coupling to both currency and market exchanges, calculating costs in a preferred currency based on a live exchange rate, and executing a transaction with a settlement based on a second rate (’701 Patent, cl. 1). This specific combination of required functionalities may be argued to distinguish it from a generic server.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement under 35 U.S.C. § 271(b), asserting that Defendant, with knowledge of the patent from this lawsuit, takes active steps such as advertising that encourage its customers to use the accused platform in an infringing manner (Compl. ¶49, ¶51).
- Willful Infringement: Willfulness allegations are based on post-suit conduct, with the complaint asserting that infringement "will now be willful through the filing and service of this Complaint" (Compl. ¶47). The complaint also alleges willful blindness, based on Defendant’s purported "practice of not performing a review of the patent rights of others" before launching services (Compl. ¶52).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: Can the term "asset", which is described in the patent’s background in the context of trading financial securities like stocks, be construed to cover the currency being transferred by Defendant’s international money transfer service?
- A key factual and evidentiary question will be one of technical mapping: Does the accused WorldRemit platform, which presents a single exchange rate to the user at the time of a transaction, meet the claim requirement for both a "first prevailing exchange rate" for displaying costs and a distinct "second prevailing exchange rate" for settlement?
- An underlying legal question will likely concern patent eligibility: Does the claimed "trading server," with its specific configuration for integrating market and currency data, represent a concrete technological improvement over prior art systems, or does it claim the abstract idea of performing a cross-currency financial transaction on a generic computer?