TicketMatrix LLC v. Dallas Cowboys LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: TicketMatrix LLC (New Mexico)
  • Defendant: Dallas Cowboys LLC (Texas)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 4:25-cv-00103, E.D. Tex., 02/05/2025
• Venue Allegations: Venue is alleged to be proper because the Defendant has an established place of business in the district, has committed acts of patent infringement in the district, and Plaintiff has suffered harm there.
• Core Dispute: Plaintiff alleges that Defendant’s ticketing systems and methods infringe a patent related to providing tickets that are linked to the participation of a specific player or team rather than to a specific event date.
• Technical Context: The technology concerns financial and logistical methods for managing and selling event tickets, particularly for multi-stage events like sports tournaments or seasons where future matchups are uncertain.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review (IPR) proceedings, or specific licensing history related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 7,831,452 - Systems and methods for providing enhanced player's ticket features

Issued November 9, 2010.

The Invention Explained

• Problem Addressed: The patent's background section describes a problem in sports ticketing where fans must purchase tickets for future matches (e.g., tournament semi-finals) without knowing which players will compete, risking investment in an uninteresting event ('452 Patent, col. 1:26-38).
• The Patented Solution: The invention solves this by proposing a "player's ticket," which allows a fan to purchase a ticket that grants admission to any match in which a specific, referenced player participates ('452 Patent, Abstract; col. 1:53-61). The system uses probabilities of player success to determine seat allocations and pricing, creating a new type of ticketing product that mitigates risk for fans and can be optimized for profitability by the event organizer ('452 Patent, col. 2:36-55).
• Technical Importance: This approach introduced a method for creating and pricing what are essentially financial options on player or team performance within the context of event ticketing, allowing organizers to capture value from fan loyalty to specific participants rather than just to specific event slots ('452 Patent, col. 2:56-62).

Key Claims at a Glance

• The complaint does not identify specific asserted claims in its main body. It alleges infringement of "Exemplary '452 Patent Claims" which are identified only in an external "Exhibit 2" that was not provided with the complaint (Compl. ¶11, ¶16). Therefore, it is not possible to list the asserted independent claims or their elements.

III. The Accused Instrumentality

Product Identification

• The complaint does not name a specific accused product, method, or service. It refers generally to "Defendant products" which it states are identified in charts within the unprovided Exhibit 2 (Compl. ¶11).

Functionality and Market Context

• The complaint does not provide any description of the relevant features or functionality of the accused instrumentalities or any allegations regarding their market position (Compl. ¶1-19).

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits to detail its infringement allegations but does not provide these exhibits (Compl. ¶16-17). In their absence, the infringement theory must be summarized from the complaint’s narrative. The complaint alleges that the "Exemplary Defendant Products practice the technology claimed by the '452 Patent" and that these products "satisfy all elements of the Exemplary '452 Patent Claims" (Compl. ¶16). No specific details on how any particular product feature meets any specific claim element are provided in the complaint itself.

No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: A central issue may be whether the patent's claims, which are described using examples from individual-player elimination tournaments like tennis, can be construed to cover the ticketing systems of a professional sports team with a league-based schedule. The specification's statement that a "player's ticket may be considered a 'team's ticket'" may support a broader interpretation, but the specific claim language will be decisive ('452 Patent, col. 4:42-44).
• Technical Questions: The complaint does not provide sufficient detail to identify specific technical questions regarding the operation of the accused products.

V. Key Claim Terms for Construction

As the complaint does not identify any specific asserted claims, instead incorporating them by reference to an unprovided exhibit, it is not possible to identify key claim terms for construction.

VI. Other Allegations

Indirect Infringement

• The complaint alleges induced infringement, stating that the Defendant distributes "product literature and website materials" that instruct end users to use the accused products in a manner that infringes the '452 Patent (Compl. ¶14-15). The complaint references the unprovided Exhibit 2 for examples of these materials (Compl. ¶14).

Willful Infringement

• The complaint alleges that the Defendant has "Actual Knowledge of Infringement" based on the service of the complaint itself (Compl. ¶13). It further alleges that "Despite such actual knowledge, Defendant continues to make, use, test, sell, offer for sale, market, and/or import" the accused products (Compl. ¶14). These allegations may form the basis for a claim of post-suit willful infringement.

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

1. Evidentiary Sufficiency: A primary question will be whether the evidence presented in the unprovided "Exhibit 2" is sufficient to plausibly allege that the Defendant's specific ticketing products meet each element of the asserted patent claims. The viability of the case hinges on the details absent from the complaint's main body.

2. Claim Scope and Applicability: A core legal issue will be one of definitional scope: can the patent’s claims, developed in the context of tournament-style events with uncertain player matchups, be interpreted to read on the ticketing model for a professional sports team like the Dallas Cowboys, which operates within a more structured league schedule?

3. Basis for Knowledge and Intent: The allegations of indirect and potential willful infringement will depend on Plaintiff’s ability to demonstrate not only direct infringement by end-users but also that the Defendant's specific actions and marketing materials actively encouraged that infringement with knowledge of the '452 Patent.