TicketMatrix LLC v. Kansas City Chiefs Football Club Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: TicketMatrix LLC (NM)
  • Defendant: Kansas City Chiefs Football Club, Inc. (TX)
  • Plaintiff’s Counsel: Rabicoff Law LLC; DNL Zito
• Case Identification: 3:25-cv-00284, N.D. Tex., 02/05/2025
• Venue Allegations: Venue is asserted based on Defendant maintaining an established place of business within the Northern District of Texas and allegedly committing acts of infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s system for selling tickets infringes a patent related to providing and managing event ticket options tied to the future participation of a specific player or team.
• Technical Context: The technology concerns systems that sell access rights to sporting events based on participant affinity rather than a fixed schedule, using probabilistic analysis to manage seat inventory for contingent future games.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or 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"

• Patent Identification: 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 describes a problem for sports fans who want to see a specific player or team in a tournament or playoff series but must buy tickets for a specific game before the participants are known (Compl. ¶ 9; ’452 Patent, col. 1:24-37). This creates a risk for the fan of purchasing a ticket to a match they have little interest in if their preferred player or team is eliminated beforehand (’452 Patent, col. 1:32-37).
• The Patented Solution: The invention is a system for selling a "player's ticket" or "player's ticket option" that is linked to a specific player or team, not a specific game (’452 Patent, col. 1:51-57). The system uses tournament information (e.g., player seedings, bracket structure) and historical data to calculate the probabilities of a player advancing and to run simulations of the tournament (’452 Patent, FIG. 11, col. 2:36-57). Based on these probabilities, the system determines how many seats to allocate for these option-holders in future, contingent matches, thereby managing inventory risk for the event organizer (’452 Patent, col. 2:51-57).
• Technical Importance: This approach creates a new type of ticketing product that shifts the risk of a player's early elimination from the fan to the ticket seller, allowing fans to purchase access based on allegiance to a participant rather than a fixed event schedule (’452 Patent, col. 1:44-51).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims" without specifying them (Compl. ¶ 11). The independent claims are 1 (a method), 6 (a system), and 11 (a machine-readable storage medium).
• The essential elements of independent claim 1 include:
  • providing player's ticket options that reference at least one player and allow admission to a match after the option is exercised;
  • acquiring tournament information, such as player data, a tournament draw, and historical data;
  • determining the probabilities of players winning for at least one match;
  • determining a possible allocation of match admissions for the ticket option holders; and
  • allocating match admissions based on the win probabilities and the probability that option holders will exercise their options.
• Independent claims 6 and 11 recite substantially similar limitations directed to a system with a configured processor and a machine-readable storage medium, respectively (’452 Patent, col. 31:46 - 33:10). The complaint reserves the right to assert other claims, including dependent claims (Compl. ¶ 11).

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as "Exemplary Defendant Products" without specifying product names (Compl. ¶ 11). Given the Defendant is the Kansas City Chiefs Football Club, Inc., the accused instrumentality is presumably the team's ticketing system used to sell products such as season ticket holder playoff options or other ticket packages contingent on the team's advancement.

Functionality and Market Context

The complaint alleges that Defendant makes, uses, sells, and offers to sell the accused products, and that its employees internally test and use them (Compl. ¶¶ 11-12). However, the complaint does not provide specific technical details about how the accused system operates, instead incorporating by reference an unattached exhibit (Compl. ¶¶ 16-17). The complaint does not provide sufficient detail for analysis of the accused instrumentality's commercial importance or market positioning.

IV. Analysis of Infringement Allegations

The complaint references, but does not include, claim charts in an exhibit that purportedly compare the asserted claims to the accused products (Compl. ¶¶ 16-17). Without this exhibit, the infringement allegations can only be summarized narratively.

The complaint alleges that Defendant’s products "practice the technology claimed by the '452 Patent" and "satisfy all elements" of the exemplary claims (Compl. ¶ 16). The narrative infringement theory suggests that Defendant's ticketing system provides fans (e.g., season ticket holders) with options to purchase tickets for future playoff games. This right is contingent on the Kansas City Chiefs team participating in those games. To manage this process, Plaintiff's theory would require that Defendant's system performs the claimed steps of acquiring data (e.g., playoff structure, team and opponent data), determining the team's probability of advancing to each potential game, and allocating a corresponding number of seats or admissions for those who hold the ticket options, based on those probabilities.

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: The patent’s examples are primarily drawn from individual sports tournaments like tennis (’452 Patent, col. 4:35-37, FIG. 1). A point of contention may be whether the term "tournament," as used in the patent, can be construed to cover a professional sports league's playoff system and the associated ticketing processes.
  • Technical Questions: A central question will be what evidence exists that Defendant’s system performs the specific probabilistic calculations required by the claims. For example, does the system "determin[e]... probabilities of players winning" and the "probability of player's ticket option holders exercising the player's ticket options," or does it operate as a simpler reservation system that does not rely on such statistical modeling as taught in the patent? (’452 Patent, Claim 1).

V. Key Claim Terms for Construction

• The Term: "player's ticket option"

• Context and Importance: This term defines the fundamental product at issue. The outcome of the case may depend on whether the ticket packages sold by the Defendant (e.g., a "pay-as-we-play" playoff plan) fall within the scope of this term. Practitioners may focus on this term to determine if the patent covers team-based sports ticketing or is limited to the individual-player tournament context of its examples.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent states that "options for purchasing tickets... may be available to sports fans" and that a holder receives "the option of purchasing tickets for a match on preferential terms" (’452 Patent, col. 2:17-22). This broad language may support an interpretation covering various types of contingent ticketing products.
  • Evidence for a Narrower Interpretation: The detailed description and figures repeatedly use a 16-player single-elimination tennis tournament as the primary example, which could suggest the term's scope is informed by, or even limited to, that context (’452 Patent, col. 4:35-37, FIG. 1).

• The Term: "determining... probabilities of players winning"

• Context and Importance: This limitation describes a core technical function of the claimed invention. The infringement analysis will likely turn on whether Defendant's system performs a "determination" that meets the patent’s requirements.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification suggests probabilities can be estimated based on general "attributes of the players," such as "current form and skill level," or from "historical data" (’452 Patent, col. 9:1-10). This could support arguing that even a less complex predictive model satisfies the limitation.
  • Evidence for a Narrower Interpretation: The patent describes and depicts detailed methods for determining probabilities, including using pseudo-normal distributions and running thousands of tournament simulations (’452 Patent, col. 8:12-20, FIGS. 2, 6-8). This could support a narrower construction requiring a sophisticated statistical analysis, not just a simple forecast or reservation.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement based on Defendant's sale of products and distribution of "product literature and website materials" that allegedly instruct end users to use the products in an infringing manner (Compl. ¶¶ 14-15).
• Willful Infringement: Willfulness is alleged based on Defendant’s knowledge of the ’452 patent obtained "at least since being served by this Complaint" (Compl. ¶¶ 13, 15). This constitutes an allegation of post-suit willfulness.

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

• A core issue will be one of definitional scope: can the patent's claims, which are exemplified in the context of individual-player tournaments, be construed to cover the structure and operation of a professional football team’s playoff ticketing system?
• A key evidentiary question will be one of technical implementation: what evidence can be presented to show that the accused ticketing system performs the specific, multi-step probabilistic analysis and seat allocation methods required by the claims, as distinct from a more conventional ticket reservation system?
• A secondary legal question will relate to the theory of indirect infringement: given that the asserted claims are directed to a back-end server system, what specific actions by end-users (fans) could constitute direct infringement that the Defendant could be liable for inducing?