Synchrofi LLC v. Foris Dax Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: SynchroFi LLC (New Mexico)
  • Defendant: Foris DAX, Inc. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-01054, E.D. Tex., 10/21/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains an established place of business in the Eastern District of Texas and has committed acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that unspecified products of Defendant infringe a patent related to single-use password authentication systems.
• Technical Context: The technology concerns secure user authentication in networked environments, a critical component for online services, financial transactions, and secure data access.
• Key Procedural History: The complaint does not reference any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date	Event
2004-10-12	’919 Patent Priority Date
2009-11-03	’919 Patent Issue Date
2025-10-21	Complaint Filing Date

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

U.S. Patent No. 7,613,919 - "Single-use password authentication"

• Patent Identification: U.S. Patent No. 7,613,919, "Single-use password authentication," issued November 3, 2009 (’919 Patent).

The Invention Explained

• Problem Addressed: The patent addresses the security drawbacks of conventional username and password systems, which are vulnerable to eavesdropping and brute-force attacks, and the complexity and inconvenience of managing multiple passwords across different online services (Compl. Ex. 1, ’919 Patent, col. 1:22-2:64).
• The Patented Solution: The invention describes a three-party authentication system comprising a client, a service provider, and a centralized authentication service. To access the service provider, the client first requests a "one-time password" from the authentication service by providing a "client moniker." The authentication service generates the one-time password and sends it to the client. The client then presents this password to the service provider, which in turn passes it to the authentication service for verification. If the password matches, the authentication service sends a unique "authentication service identifier" to the service provider, thereby authenticating the client without exposing the client's permanent credentials (like the moniker) to the service provider (Compl. Ex. 1, ’919 Patent, Abstract; col. 3:27-51).
• Technical Importance: This architecture aims to enhance security by using ephemeral credentials for login transactions and centralizing the authentication logic, separating the entity that holds the user's primary secret from the entity providing the end service (Compl. Ex. 1, ’919 Patent, col. 3:20-24).

Key Claims at a Glance

The complaint refers to "Exemplary '919 Patent Claims" but does not specify which claims are asserted, instead referencing an unprovided exhibit (Compl. ¶11). The following analysis is based on independent claim 1, a representative method claim directed to the authentication service.

• Independent Claim 1:
  • generating an authentication service identifier for the client;
  • receiving a client moniker from the client;
  • after receiving the client moniker, sending a one-time password to the client for use in accessing the service provider;
  • after sending the one-time password to the client, receiving a one-time password from the service provider;
  • if the password from the service provider matches the password sent to the client, sending the authentication service identifier for the client to the service provider to authenticate the client.

III. The Accused Instrumentality

Product Identification

• The complaint does not name any specific accused products or services (Compl. ¶11). It refers to "Exemplary Defendant Products" that are purportedly identified in "charts incorporated into this Count" via an attached "Exhibit 2" (Compl. ¶¶11, 16). Exhibit 2 was not provided with the complaint.

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the functionality or market context of the accused instrumentality.

IV. Analysis of Infringement Allegations

The complaint alleges direct and induced infringement of one or more claims of the ’919 Patent (Compl. ¶¶11, 15). However, it provides no narrative infringement theory in the body of the complaint. Instead, it states that infringement allegations are detailed in claim charts contained in an unprovided "Exhibit 2," which are incorporated by reference (Compl. ¶¶16-17). Without this exhibit, a detailed analysis of the infringement allegations is not possible.

No probative visual evidence provided in complaint.

Identified Points of Contention

• Based on the technology and claims, several points of contention may arise once the accused products and infringement theory are identified.
  • Architectural Questions: A central question may be whether the accused system employs the three distinct entities recited in the patent (client, service provider, authentication service). The defense may argue that its system architecture does not map onto this tripartite structure, for example, if the authentication and service provider functions are integrated into a single platform.
  • Scope Questions: The dispute may turn on the definition of claim terms. For instance, a question could be whether a standard username used in the accused product meets the definition of a "client moniker" as described in the patent, or if a session token meets the definition of an "authentication service identifier."

V. Key Claim Terms for Construction

"client moniker"

• Context and Importance: This term is the credential the client uses to initiate the authentication process with the authentication service. Its definition is critical because it distinguishes the user's primary secret from the one-time password used with the service provider. Practitioners may focus on this term because the patent describes it ambiguously, creating a potential dispute over its scope.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification states the moniker is "analogous to a username" (Compl. Ex. 1, ’919 Patent, col. 8:6-7), which could support an interpretation that it is a public or semi-public identifier.
  • Evidence for a Narrower Interpretation: The specification also describes the moniker as "ideally the client's everyday preferred 'password' known only to themselves" (Compl. Ex. 1, ’919 Patent, col. 3:32-34), suggesting it is a secret credential, distinct from a public username. This could support a narrower construction.

"authentication service identifier"

• Context and Importance: This is the credential that the authentication service provides to the service provider to confirm the client's identity. The scope of this term will be important for determining whether temporary tokens, session IDs, or other identifiers used in modern systems fall within the claim.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification states that "Any suitable identifier may be used" and that it "generally takes the form of an arbitrary number of characters, such as... a globally unique identifier (GUID)" (Compl. Ex. 1, ’919 Patent, col. 3:41-44; col. 8:20-24). This language may support a broad construction encompassing various types of digital identifiers.
  • Evidence for a Narrower Interpretation: The role of the identifier is consistently described as being sent to the service provider from the authentication service to complete the process. Arguments could be made that this functional context limits the term to identifiers used in a specific way within a three-party architecture, potentially excluding identifiers used in two-party or self-contained systems.

VI. Other Allegations

Indirect Infringement

• The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users on how to use its products in a manner that infringes the ’919 Patent (Compl. ¶14).

Willful Infringement

• The complaint does not use the word "willful" but lays a foundation for such a claim. It alleges that Defendant gained "actual knowledge" of its infringement upon service of the complaint and has continued to infringe despite this knowledge (Compl. ¶¶13-14).

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

Given the limited information provided, the case initially appears to turn on fundamental, threshold questions that must be answered before any substantive legal analysis can occur.

• A primary issue will be one of factual clarity: What specific products or services are accused of infringement? The complaint's complete reliance on an unprovided exhibit leaves the entire factual basis for the infringement claim undefined.
• A subsequent issue will be one of architectural mapping: Assuming an accused product is identified, does its architecture align with the three-party system (client, authentication service, service provider) that is central to the patent's claims, or does it operate on a different model that may fall outside the claim scope?
• Finally, a key legal question will be one of definitional scope: How will the court construe the term "client moniker"? Whether it is interpreted narrowly as a private secret (like a password) or broadly as a public identifier (like a username) could be dispositive for the infringement analysis.