Secure Matrix LLC v. J Hilburn Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Secure Matrix LLC (Delaware)
  • Defendant: J. Hilburn, Inc. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC; DNL Zito
• Case Identification: 3:25-cv-02891, N.D. Tex., 10/24/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains an established place of business within the Northern District of Texas.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to systems and methods for user authentication and verification.
• Technical Context: The technology concerns multi-device security protocols, commonly used for two-factor authentication to secure online logins, payments, and other sensitive digital interactions.
• Key Procedural History: The complaint does not allege any prior litigation, licensing history, or other significant procedural events related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 8,677,116 - Systems and methods for authentication and verification

The Invention Explained

• Problem Addressed: The patent describes a "growing need to authenticate users" accessing secured internet portals or making online payments, seeking a method that is both secure and fast (’116 Patent, col. 1:20-29).
• The Patented Solution: The invention provides a three-party authentication system involving a user's primary computer, a separate electronic device (e.g., a smartphone), and a central verification server. A computer seeking access to a secured capability (e.g., a website) sends a "reusable identifier" to a verification server; the user's separate device then sends a copy of that same identifier along with "user verification information" to the server. A processor at the server evaluates both signals to determine if the user is authorized and, if so, sends an authorization signal back to the computer or the user's device (’116 Patent, Abstract; col. 6:3-33). This process is depicted in figures such as Figure 2, which shows the flow of information between a user browser, a mobile device, a web server, and a verification server.
• Technical Importance: This architecture aims to enhance security by separating the initiation of a transaction from its verification across two different devices, a common paradigm in modern multi-factor authentication. (Compl. ¶15).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims," including "at least the exemplary claims" identified in an attached exhibit (Compl. ¶11). Independent claim 1 is representative of the patented method.
• Essential Elements of Independent Claim 1:
  • A computer system receives a first signal from a computer, which contains a "reusable identifier" corresponding to a secured capability that is assigned for a "finite period of time."
  • The computer system receives a second signal from a user's separate electronic device, which contains a copy of the reusable identifier and "user verification information."
  • A processor evaluates the first and second signals to determine if the user is authorized.
  • If authorized, the computer system transmits a third signal with authorization information to the computer and/or the user's electronic device.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint refers to "Exemplary Defendant Products" but does not identify any specific product, method, or service by name (Compl. ¶11, ¶15).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the functionality of the accused instrumentalities. It states that charts in an exhibit compare the patent claims to the accused products, but this exhibit was not provided with the complaint (Compl. ¶15, ¶16).

IV. Analysis of Infringement Allegations

The complaint alleges that infringement is detailed in claim charts included as Exhibit 2; this exhibit was not provided (Compl. ¶15, ¶16). The complaint's narrative asserts that the "Exemplary Defendant Products" practice the technology claimed by the ’116 Patent, satisfying all elements of the asserted claims (Compl. ¶15-16). Without the accused product's identity or the claim charts, a detailed infringement analysis is not possible.

No probative visual evidence provided in complaint.

Identified Points of Contention

Based on the patent's claims and the general nature of the allegations, key disputes may center on the following questions:

• Architectural Questions: Does the accused system utilize the three distinct computing entities described in the patent (a primary computer, a separate user device, and a verification server)? Does the data flow in the accused system match the claimed sequence of receiving a first signal from the primary computer and a second signal from the separate device before evaluation?
• Scope Questions: What feature in the accused product constitutes the "reusable identifier"? Does that identifier operate only for a "finite period of time" as required by the claim, and what evidence defines that period? What data in the accused system constitutes "user verification information" separate from the identifier itself?

V. Key Claim Terms for Construction

• The Term: "reusable identifier" (Claim 1)
• Context and Importance: This term is central to the invention's novelty, distinguishing it from systems that use single-use tokens. The definition of "reusable" will be critical to determining infringement, as it dictates whether identifiers used in an accused system (e.g., session tokens, QR codes) fall within the claim scope.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests a broad meaning by stating the identifier "does not contain user-specific or transaction-specific information" and can be reused for "multiple users and multiple transactions" (’116 Patent, col. 9:11-16). This may support construing the term to cover any non-unique, recyclable token.
  • Evidence for a Narrower Interpretation: The claim itself requires the identifier to be "assigned for use by the secured capability for a finite period of time." The specification further describes embodiments where identifiers are used sequentially from a predefined list in a "round robin" fashion, and where an identifier, while reusable in a subsequent time period, "cannot be used again within the same time period" (’116 Patent, col. 9:45-51). This language could support a narrower construction tied to a rotating or time-limited set of identifiers.

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 the accused products in a manner that infringes the ’116 Patent (Compl. ¶14).
• Willful Infringement: The complaint does not explicitly use the term "willful." However, it alleges that the filing and service of the complaint constitutes "actual knowledge" and that Defendant's infringement continues despite this knowledge, which may form the basis for a claim of post-suit willful infringement (Compl. ¶13, ¶14).

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

1. A Threshold Evidentiary Question: The primary and immediate issue is the identification of the "Exemplary Defendant Products." Without details on what products are accused and how they function, which the complaint defers to an unprovided exhibit, no substantive analysis of infringement can occur.
2. A Core Issue of Definitional Scope: The case will likely turn on the construction of "reusable identifier assigned for use... for a finite period of time." Whether this claim language can be read to cover modern session tokens, persistent login identifiers, or other authentication data used by the accused products will be a central point of dispute.
3. A Question of Architectural Congruence: A key factual question will be whether the accused system's architecture maps onto the specific three-part communication flow required by the claims—specifically, whether it separately receives signals from two distinct user-side sources (a primary computer and a separate electronic device) at a verification server before authorizing a session.