DCT

2:26-cv-00009

Blaze Mobile Tech LLC v. Credit Union Of Texas

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-00009, E.D. Tex., 01/06/2026
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant conducts business in the district and operates physical branch locations there.
  • Core Dispute: Plaintiff alleges that Defendant’s mobile banking application and associated server infrastructure infringe three patents related to methods for conducting secure financial transactions on mobile devices.
  • Technical Context: The technology at issue concerns systems and methods for mobile banking developed in the mid-to-late 2000s, focusing on the use of non-browser-based applications, offline functionality, and server-side processing to enhance security and scalability.
  • Key Procedural History: The complaint does not allege any significant pre-suit litigation, licensing history, or administrative patent challenges involving the patents-in-suit.

Case Timeline

Date Event
2007-11-30 Earliest Priority Date for U.S. Patent No. 10,235,664
2007-11-14 Earliest Priority Date for U.S. Patent No. 11,847,649
2007-12-13 Earliest Priority Date for U.S. Patent No. 11,783,365
2019-03-19 U.S. Patent No. 10,235,664 Issued
2023-10-10 U.S. Patent No. 11,783,365 Issued
2023-12-19 U.S. Patent No. 11,847,649 Issued
2026-01-06 Complaint Filed

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

U.S. Patent No. 10,235,664 - *“Mobile Banking Transactions at a Server with Authentication”*

The Invention Explained

  • Problem Addressed: At the time of the invention, mobile banking was limited and faced challenges related to security and functionality, with customers often relying on less secure or less convenient methods like text messages, limited web browsers, or telephone-based systems (Compl. ¶22). The patent’s background section notes the increasing use of mobile devices for payment transactions like purchasing goods and transferring funds (’664 Patent, col. 1:24-34).
  • The Patented Solution: The invention describes a server-centric method for processing mobile banking transactions. A user interacts with a "non-browser based application" on their mobile device to send an identification code and PIN to a remote server for authentication (’664 Patent, col. 7:45-54). Once authenticated, the server processes transaction requests from the mobile application using a payment method stored on the server, not the device, and then sends a "digital artifact" (e.g., a receipt or confirmation) back to the application for display (’664 Patent, col. 8:13-24). This architecture is intended to centralize the handling of sensitive payment data.
  • Technical Importance: The complaint alleges this approach improves security by removing sensitive payment data from the mobile device and enhances scalability by centralizing user data management on a remote server (Compl. ¶33, ¶37).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶44).
  • Essential elements of Claim 1 include:
    • Maintaining a payment method at a remote management server.
    • Receiving an identification code and PIN from a non-browser based application on a mobile device.
    • Authenticating the user at the server based on the received code and PIN.
    • Receiving a mobile banking transaction request from the non-browser based application.
    • Processing the transaction at the server using the maintained payment method.
    • Sending a "digital artifact" from the server to the non-browser based application for display after processing.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent but makes general allegations of infringement of "one or more claims" (Compl. ¶44).

U.S. Patent No. 11,783,365 - *“Blaze Mobile Banking Using a Non-Browser Based Application”*

The Invention Explained

  • Problem Addressed: The patent background describes constraints in the mobile device environment, such as limited device memory, which can restrict the number of customized applications a user can run (’365 Patent, col. 2:1-5).
  • The Patented Solution: The invention describes a method where a mobile device runs a "non-browser based application" that serves as a generic platform. This platform can be customized based on a user's affiliation with a "special interest group (SIG)," such as a university, corporation, or sports team (’365 Patent, col. 1:10-18). The application on the device transmits authentication information (userID and password) to a remote server, requests and receives a "digital artifact," and displays it, all within the context of the customized, non-browser platform (’365 Patent, col. 10:5-48). This allows a single application framework to provide a branded experience for multiple different groups.
  • Technical Importance: This approach aims to deliver customized or branded mobile application experiences without requiring users to install numerous separate applications, thereby conserving device memory and simplifying application management (’365 Patent, col. 2:1-5).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶62).
  • Essential elements of Claim 1 include:
    • Receiving a userID and password at a non-browser based application on a mobile device.
    • Transmitting this information from the application to a remote management server for authentication.
    • After authentication, receiving a request for a mobile banking transaction at the non-browser application.
    • Transmitting the transaction request from the application to the server.
    • After the server processes the transaction, receiving a "digital artifact" from the server at the application.
    • Displaying the digital artifact within the non-browser based application.
  • The complaint alleges infringement of "one or more claims" of the ’365 Patent (Compl. ¶62).

U.S. Patent No. 11,847,649 - *“Method and System for Mobile Banking Using a Server”*

Technology Synopsis

This patent describes a method for conducting a mobile banking transaction where a server authenticates a user based on login information received from a non-browser based application on a mobile device (’649 Patent, col. 5:58-6:4). After successful authentication, the server receives and processes transaction requests from the mobile application using a payment method stored on the server and sends a "digital artifact" back to the device. The claims emphasize the server's role in receiving login information, authenticating, processing the transaction, and returning a result.

Asserted Claims

The complaint asserts at least independent claim 1 (Compl. ¶80).

Accused Features

The accused features are the Credit Union of Texas mobile application and the servers that interact with and enable it (Compl. ¶78).

III. The Accused Instrumentality

Product Identification

The "Accused Instrumentalities" are identified as the "Credit Union of Texas mobile application" provided to end users and the servers that interact with and enable the application's functionality (Compl. ¶38).

Functionality and Market Context

The complaint alleges that the Accused Instrumentalities provide mobile banking services to end users (Compl. ¶38). The complaint does not provide sufficient detail for analysis of the specific technical features of the application or servers, instead referring to Exhibits G, H, and I, which were not filed with the complaint. The allegations focus on the general provision of mobile banking functionality through a dedicated application rather than a web browser (Compl. ¶23).

IV. Analysis of Infringement Allegations

The complaint alleges that the Accused Instrumentalities infringe at least claim 1 of each of the asserted patents, either literally or under the doctrine of equivalents (Compl. ¶45, ¶63, ¶81). It does not, however, provide a detailed, element-by-element mapping of the accused product's features to the specific limitations of the asserted claims. The infringement theory is articulated at a high level: that the Defendant's mobile application and server system, in combination, perform the patented methods for secure mobile banking. The complaint includes a diagram from a patent publication incorporated by reference, showing a graphical user interface for a "Bill Pay" function on a mobile application, as an example of the technology context (Compl. ¶25).

Identified Points of Contention

  • Scope Questions: The infringement analysis may raise questions regarding the scope of key claim terms. For example, does the accused "Credit Union of Texas mobile application" meet the specific limitations of a "non-browser based application" as that term is used and defined within the patents? A central question will be whether the architectural and data-flow requirements of the claims (e.g., the specific sequence of authenticating at a server, processing a transaction using a server-stored payment method, and returning a "digital artifact") are performed by the accused system.
  • Technical Questions: A key technical question will be what evidence demonstrates that the accused system operates in the specific manner claimed. For instance, for the ’664 Patent, what evidence shows that the Defendant’s servers process transactions using a "payment method" maintained at the server in the manner claimed, as distinct from merely passing transaction data to other financial networks? For the ’365 Patent, what evidence shows the accused application functions as a customizable "generic platform" based on "special interest groups"?

V. Key Claim Terms for Construction

  • The Term: “non-browser based application” (appears in claim 1 of all asserted patents)

    • Context and Importance: This term is central to the asserted claims and appears to be a primary point of distinction over prior art systems that used web browsers (Compl. ¶22-23). The patentability and infringement analyses will likely depend heavily on how this term is construed. Practitioners may focus on this term because it seeks to define the fundamental nature of the software environment in which the invention operates.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The complaint, referencing an incorporated publication, alleges the term is synonymous with "mobile application" ('192 Pub, ¶0035, as cited in Compl. ¶24, n.4). This could support a broad interpretation covering any native mobile application.
      • Evidence for a Narrower Interpretation: The same publication also states "the mobile application 910 is not browser HTTP based" ('192 Pub, ¶0035, as cited in Compl. ¶24). This could be used to argue for a narrower definition that excludes applications that use or rely on standard web protocols for their core functionality, potentially creating a distinction from modern apps that use embedded web views or API calls over HTTPS.

  • The Term: “digital artifact” (appears in claim 1 of all asserted patents)

    • Context and Importance: This term defines the output of the claimed transaction processing method. The dispute may turn on whether the data sent back to the accused application (e.g., a confirmation screen, transaction record, or updated balance) qualifies as a "digital artifact" as claimed.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: Dependent claims in the patent family define the term broadly to include "an advertisement, coupon, ticket, media, or content" (’664 Patent, col. 10:8-9), suggesting the term is not limited to a specific data type.
      • Evidence for a Narrower Interpretation: Another dependent claim defines the artifact as a "receipt" (’664 Patent, col. 9:55-56). A defendant might argue that this, along with the specification's examples, suggests the term should be limited to discrete, transferable items rather than a dynamic display of account information.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement based on Defendant allegedly "actively marketing to, supplying, ... encouraging, ... and instructing" customers and end-users to use the accused mobile application in an infringing manner (Compl. ¶46, ¶64, ¶82). Contributory infringement is also alleged, on the basis that the accused application is a material part of the invention and is not a staple article of commerce suitable for substantial non-infringing use (Compl. ¶48, ¶66, ¶84).
  • Willful Infringement: The complaint alleges willful infringement based on knowledge of the patents obtained "at least as of the date when it was notified of the filing of this action" (Compl. ¶53, ¶71, ¶89). This suggests the claim for willfulness is based on alleged post-suit conduct.

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

This dispute appears to center on the application of patents with mid-2000s priority dates to a modern mobile banking application. The resolution will likely depend on the answers to several key questions:

  1. A central issue will be one of claim scope and construction: How will the court construe the term “non-browser based application” in the context of contemporary mobile apps that may embed web technologies or communicate via standard web protocols? Similarly, can the term “digital artifact” be construed to cover the dynamic data displays common in modern banking apps?

  2. A second key issue will be evidentiary proof of infringement: Given the complaint's high-level allegations, a primary challenge for the plaintiff will be to demonstrate through technical evidence that the accused application and server architecture performs the specific, multi-step methods recited in the claims, particularly the server-side authentication and processing logic.

  3. A third underlying question may concern patent validity: The asserted patents claim early approaches to mobile banking. The case may therefore involve an examination of whether the claimed methods were truly inventive over the state of the art in mobile and online banking during the 2005-2007 timeframe.