FinTegrity LLC v. Barclays Bank PLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: FinTegrity LLC (New Mexico)
  • Defendant: Barclays Bank PLC (United Kingdom)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-01018, E.D. Tex., 10/07/2025
• Venue Allegations: Venue is asserted based on the defendant being a foreign corporation.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to financial fraud protection systems that authorize transactions by comparing transaction data with user data obtained from third-party sources like social media networks.
• Technical Context: The technology at issue operates in the financial technology (fintech) sector, addressing the persistent challenge of authenticating credit card and other financial transactions to prevent fraud.
• Key Procedural History: The patent-in-suit is a continuation of a prior U.S. patent application, which may be relevant to the scope and interpretation of its claims. The complaint does not mention any prior litigation, licensing history, or administrative challenges involving the patent.

Case Timeline

Date	Event
2013-03-15	Earliest Priority Date for U.S. Patent No. 8,635,117
2013-08-09	Application Date for U.S. Patent No. 8,635,117
2014-01-21	Issue Date for U.S. Patent No. 8,635,117
2025-10-07	Complaint Filing Date

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

U.S. Patent No. 8,635,117 - "System and method for consumer fraud protection"

The Invention Explained

• Problem Addressed: The patent's background section describes conventional fraud detection methods as computationally expensive, slow, and often inaccurate, leading to both fraudulent transactions being approved and legitimate ones being incorrectly flagged. A key deficiency identified is the lack of access to a user's "real-time data" to verify a transaction's authenticity (’117 Patent, col. 1:30-44).
• The Patented Solution: The invention proposes a system that authorizes a financial transaction by retrieving data about the transaction (e.g., merchant name and location) and comparing it against "user-data" retrieved from a "third-party information source," such as a social media network (’117 Patent, Abstract; col. 1:57-65). For example, if a credit card is used in Chicago, the system could check a user's social media profile for a recent "Check-In" in Chicago to help confirm the user's presence and authorize the charge (’117 Patent, col. 5:62-col. 6:6). Figure 1 illustrates this architecture, showing a central "Transaction Authorization System" (104) that communicates with financial institutions (114), a point-of-sale system (110), and a "Third-Party Information Source" (106) to perform this verification.
• Technical Importance: This approach seeks to improve fraud detection accuracy and efficiency by leveraging dynamic, user-generated data that reflects a person's real-time location and activities, reducing reliance on static historical data and complex predictive algorithms (’117 Patent, col. 6:15-20).

Key Claims at a Glance

• The complaint alleges infringement of "exemplary claims" without specifying claim numbers in the main body, instead referencing an external exhibit (Compl. ¶11). The analysis below focuses on independent claim 1 as a representative claim.
• Independent Claim 1 recites a computer-implemented process with the following essential elements:
  • 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 represents 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."
  • Generating an authorization flag when the transaction-data "substantially matches" the user-data for an authorized transaction.
  • Generating a denial flag when the transaction-data "substantially matches" the user-data for an unauthorized transaction.
  • Communicating the generated flag to the financial institution's server to authorize or deny the transaction.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint does not identify any accused products or services by name. It refers generally to "Exemplary Defendant Products" that are purportedly detailed in claim charts attached as Exhibit 2 (Compl. ¶¶11, 16).

Functionality and Market Context

The complaint alleges that the "Exemplary Defendant Products practice the technology claimed by the ’117 Patent" (Compl. ¶16). However, because the complaint does not name the products or provide the referenced claim charts, it does not provide sufficient detail for analysis of the specific functionality of the accused instrumentalities.

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant’s unidentified products infringe the ’117 Patent by practicing the claimed technology, and it incorporates by reference claim charts from an external document, Exhibit 2, which was not filed with the complaint (Compl. ¶¶16-17). The complaint asserts that these charts demonstrate how the accused products "satisfy all elements of the Exemplary ’117 Patent Claims" (Compl. ¶16). Without access to these charts, a detailed element-by-element analysis is not possible.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

The Term: "third-party information source" (from Claim 1)

• Context and Importance: The scope of this term is central to the infringement analysis, as it defines the universe of data sources from which "user-data" can be retrieved. The definition will determine whether the accused system must interact with social media specifically or if any external data provider would suffice.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The plain language of independent claim 1 does not limit the source to social media. The specification also refers more broadly to "third-party websites, networks, applications and/or databases" (’117 Patent, col. 6:66-col. 7:1).
  • Evidence for a Narrower Interpretation: The patent repeatedly uses "Social Media Network" as the primary and often sole example of a third-party source (’117 Patent, Abstract; col. 2:2-3). Dependent claim 2 explicitly narrows the term to "a social media network," which could be used to argue that the independent claim must be broader but may also suggest the core of the invention lies in social media integration.

The Term: "substantially matches" (from Claim 1)

• Context and Importance: This term of degree is critical for determining the conditions under which an authorization or denial flag is generated. The dispute will likely focus on how close the correlation between transaction data and user data must be to meet this standard.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent suggests that an exact match is not required. For instance, it describes authorizing a transaction if a location is "within a predetermined distance" of the user's location data, implying a degree of tolerance (’117 Patent, col. 2:12-14, col. 14:59-62).
  • Evidence for a Narrower Interpretation: A defendant may argue that the term requires a direct and unambiguous correlation to avoid the very false positives the patent claims to solve. The patent's examples often involve clear correlations, such as a user "Check-In" at a specific merchant or a calendar event for a trip to a specific city, which may be used to argue for a tighter required match (’117 Patent, col. 12:1-3; col. 14:1-3).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, asserting that since the filing of the suit, Defendant has knowingly sold its products and distributed "product literature and website materials" that instruct end users on how to use the products in an infringing manner (Compl. ¶¶14-15).
• Willful Infringement: The complaint does not contain an explicit count for willful infringement. However, it alleges "Actual Knowledge of Infringement" arising from the service of the complaint and its attached claim charts (Compl. ¶13). This allegation forms a basis for potential post-suit willful infringement and a request for enhanced damages under 35 U.S.C. § 284, which Plaintiff includes in its prayer for relief (Compl. p. 4, ¶D).

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

• A primary evidentiary question will be one of technical operation: As the complaint does not specify the accused products, a central issue will be for the Plaintiff to demonstrate through discovery what Barclays’ fraud-detection systems actually do and whether they perform the claimed steps of retrieving data from a "third-party information source" and "comparing" it to transaction data to generate authorization or denial flags.
• The case will also turn on a question of definitional scope: How broadly will the court construe the term "third-party information source"? The answer will determine whether the patent covers only systems that use social media data, as heavily featured in the patent’s examples, or if it extends to systems using other forms of external, non-transactional user data.
• A third key issue will be the interpretation of functional proximity: What degree of correlation is required for transaction data to "substantially match" user data? The resolution of this issue will dictate whether a loose geographic or behavioral correlation is sufficient for infringement or if a more direct and precise link is required by the claims.