DCT

2:25-cv-01020

FinTegrity LLC v. Deutsche Bank AG

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-01020, E.D. Tex., 10/07/2025
  • Venue Allegations: Venue is alleged to be proper based on the Defendant being a foreign corporation.
  • Core Dispute: Plaintiff alleges that Defendant’s financial transaction systems infringe a patent related to using third-party data sources for consumer fraud protection.
  • Technical Context: The technology at issue involves authorizing financial transactions by comparing transaction data against user data collected from external sources, such as social media networks, to enhance fraud detection.
  • Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date Event
2013-03-15 U.S. Patent No. 8,635,117 Priority Date
2014-01-21 U.S. Patent No. 8,635,117 Issued
2025-10-07 Complaint Filed

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 asserts that prior art fraud detection systems rely on computationally complex, expensive, and slow heuristics that often fail to incorporate a user's real-time data, leading to inaccurate flagging of transactions ('117' Patent, col. 1:29-45).
  • The Patented Solution: The invention proposes a system that authorizes a financial transaction by retrieving data related to the transaction (e.g., merchant location) and comparing it to user-data retrieved from a "third-party information source," such as a social media network (e.g., a user's check-in location) ('117 Patent, Abstract; col. 2:57-65). This comparison of real-time or near-real-time data from disparate sources is intended to confirm the user's identity and the transaction's legitimacy with greater accuracy ('117 Patent, col. 5:15-20). The overall system architecture, connecting a point-of-sale system, a transaction authorization system, and a third-party source via a network, is depicted in Figure 1 ('117 Patent, Fig. 1).
  • Technical Importance: This approach sought to leverage the growing availability of dynamic, user-generated data from social media and other web platforms to supplement or replace static, traditional fraud detection metrics ('117 Patent, col. 5:30-40).

Key Claims at a Glance

  • The complaint asserts infringement of one or more claims of the ’117 Patent, identified as "Exemplary '117 Patent Claims" in an incorporated but unattached exhibit (Compl. ¶11, ¶16). Independent claim 1 is representative:
  • A computer-implemented process for authorizing financial transactions, comprising the steps of:
    • retrieving... transaction-data associated with a financial transaction from a... financial institution's server;
    • retrieving... user-data from a... third-party information source;
    • wherein said user-data comprises data representing at least one attribute descriptive of an authorized financial transaction, or... an unauthorized financial transaction;
    • comparing... said transaction-data to said user-data to generate (i) an authorization flag or (ii) a denial flag;
    • communicating... the generated denial flag or... the generated authorization flag to said financial institution's server... wherein the financial transaction is authorized when the generated authorization flag is communicated.
  • The complaint does not specify which, if any, dependent claims are asserted.

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as "Exemplary Defendant Products" (Compl. ¶11, ¶16). It does not name any specific Deutsche Bank AG products, services, or internal systems.

Functionality and Market Context

The complaint alleges that the "Exemplary Defendant Products practice the technology claimed by the '117 Patent" (Compl. ¶16). The complaint incorporates by reference claim charts from an unattached Exhibit 2, which purportedly detail the infringing functionality (Compl. ¶17). Without this exhibit, the complaint does not provide sufficient detail for analysis of the accused instrumentalities' specific operations or market positioning.

IV. Analysis of Infringement Allegations

The complaint references claim charts in Exhibit 2, which was not filed with the complaint, to support its infringement contentions (Compl. ¶16-17). The narrative infringement theory is that Defendant's "Exemplary Defendant Products" satisfy all elements of the asserted claims (Compl. ¶16). In the absence of the specific allegations from the claim charts, a detailed element-by-element analysis is not possible.

No probative visual evidence provided in complaint.

Identified Points of Contention

  • Evidentiary Questions: A primary issue will be identifying the specific accused "Exemplary Defendant Products" and adducing evidence that they perform each claimed step. The complaint’s lack of specificity on this point suggests that discovery will be central to establishing the factual basis for infringement.
  • Scope Questions: A likely point of dispute is whether the data sources used by Defendant's fraud detection systems qualify as a "third-party information source" as that term is used in the patent. The patent's specification heavily emphasizes "Social Media Networks" as the exemplary source ('117 Patent, col. 3:32-39; col. 4:54-58), raising the question of whether the claims can be read to cover more conventional financial data sources (e.g., credit bureaus, inter-bank networks) that may be used by the Defendant.
  • Technical Questions: A key technical question will be whether Defendant's systems perform the claimed "comparing" step to generate a dispositive "authorization flag" or "denial flag" based on user-data from an external source, or if such data is merely one of many weighted inputs in a more complex, heuristic-based fraud scoring model.

V. Key Claim Terms for Construction

  • The Term: "third-party information source" (Claim 1)
  • Context and Importance: This term is the lynchpin of the invention, defining the novel data source used for authorization. The viability of the infringement claim may depend on whether the data sources used by Defendant's systems fall within the scope of this term. Practitioners may focus on this term because the patent's examples are heavily skewed towards social media, while a large financial institution likely uses different types of third-party data.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself is not explicitly limited to social media. The specification provides a definition of "Social Media Network" but does not state that it is the only type of third-party source ('117 Patent, col. 3:32-39).
    • Evidence for a Narrower Interpretation: The specification repeatedly and consistently uses "Social Media Network" as the primary and often sole example of a "third-party information source" ('117 Patent, col. 2:1-2, col. 5:8-14, col. 7:52-56). The abstract also frames the invention in this context. This consistent emphasis could be used to argue that the scope of "third-party information source" is implicitly limited to sources of a similar character to social media (i.e., those containing dynamic, user-generated, non-financial data).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement based on Defendant's distribution of "product literature and website materials" that allegedly instruct end users to use the accused products in an infringing manner (Compl. ¶14).
  • Willful Infringement: Willfulness is alleged based on Defendant’s continued infringement after gaining "actual knowledge" of the ’117 Patent upon service of the complaint and its attached claim charts (Compl. ¶13, ¶15). The complaint does not allege pre-suit knowledge.

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

This case appears to present several fundamental questions for the court that will likely define the litigation:

  • A central issue will be one of definitional scope: Can the term “third-party information source,” which is described throughout the patent with repeated reference to social media networks, be construed to cover the types of third-party data (e.g., from credit bureaus, government agencies, or other financial data aggregators) that a global financial institution like Deutsche Bank AG would more conventionally use in its fraud prevention systems?
  • A key evidentiary question will be one of operational correspondence: Assuming the accused systems are identified, what evidence will demonstrate that they perform the specific sequence claimed—retrieving external user-data and using a comparison with transaction-data to generate a dispositive authorization or denial flag—as opposed to using such data as one of many inputs into a broader, heuristic-based risk analysis? The complaint's lack of detail shifts the entire burden of demonstrating this correspondence to discovery.