Secure Matrix LLC v. Mouser Electronics Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Secure Matrix LLC (Delaware)
  • Defendant: Mouser Electronics, Inc. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC; DNL Zito
• Case Identification: 4:25-cv-01193, N.D. Tex., 10/24/2025
• Venue Allegations: Venue is alleged to be proper based on Defendant maintaining an established place of business within the Northern District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s products and services infringe a patent related to systems for user authentication and verification.
• Technical Context: The technology addresses methods for securing access to online portals or services by using a separate electronic device, such as a smartphone, to authenticate a user's session.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or post-grant proceedings involving the patent-in-suit.

Case Timeline

Date	Event
2012-11-21	U.S. Patent No. 8,677,116 Priority Date
2014-03-18	U.S. Patent No. 8,677,116 Issue Date
2025-10-24	Complaint Filing Date

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

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

• Patent Identification: U.S. Patent No. 8,677,116, "Systems and methods for authentication and verification," issued March 18, 2014 (’116 Patent).

The Invention Explained

• Problem Addressed: The patent describes a "growing need to authenticate users trying to access a secured internet portal... or a real-world secured device," noting that as consumer transactions increasingly occur online, a need for "secure and fast online electronic payment capability is also growing" (’116 Patent, col. 2:19-29).
• The Patented Solution: The invention proposes a three-party authentication system comprising a user's electronic device (e.g., a smartphone), a computer providing a "secured capability" (e.g., a website on a PC), and a separate verification server (’116 Patent, Fig. 2). The computer displays a "reusable identifier" (such as a QR code), which the user's device captures. The user's device then transmits a signal containing a copy of this identifier along with "user verification information" to the verification server. The server evaluates this signal against a signal it receives from the first computer to determine if the user is authorized and, if so, transmits an authorization signal to complete the authentication process (’116 Patent, Abstract; col. 6:4-33).
• Technical Importance: This approach leverages the widespread availability of personal mobile devices to offer an alternative to traditional password-based login systems, aiming for improved security and user experience in online authentication and transactions (’116 Patent, col. 2:19-29).

Key Claims at a Glance

The complaint alleges infringement of "one or more claims" without specifying them (Compl. ¶11). The independent claims, which form the basis for the patent's scope, are analyzed below.

• Independent Claim 1 (a method) includes these essential elements:
  • Receiving a first signal from a computer providing a secured capability, the signal comprising a "reusable identifier assigned for use... for a finite period of time."
  • Receiving a second signal from a user's electronic device, comprising a copy of the reusable identifier and "user verification information."
  • Using a processor to evaluate, based on the first and second signals, whether the user is authorized.
  • Transmitting a third signal with authorization information to the electronic device and/or the computer if the user is authorized.
• Independent Claim 11 (a system) includes these essential elements:
  • A first input to receive first signals from computers, each signal comprising a "reusable identifier."
  • A second input to receive second signals from user electronic devices, each signal comprising a copy of the reusable identifier and "user verification information."
  • A storage device with associations between secured capabilities and identifiers, and between user information and verified users.
  • A processor configured to evaluate whether a user is authorized based on the signals.
  • An output to transmit a third signal with authorization information.

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as the "Exemplary Defendant Products" (Compl. ¶11).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused products' functionality. It states that charts comparing the patent claims to the "Exemplary Defendant Products" are included in an "Exhibit 2" (Compl. ¶15). However, Exhibit 2 was not filed with the complaint, leaving the specific products and their operation unidentified.

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

The complaint alleges that charts in the unattached Exhibit 2 demonstrate that the "Exemplary Defendant Products practice the technology claimed by the '116 Patent" and "satisfy all elements of the Exemplary '116 Patent Claims" (Compl. ¶15-16). Without this exhibit, a detailed infringement analysis based on the complaint's allegations is not possible. The narrative theory relies entirely on the contents of this missing exhibit.

• Identified Points of Contention: Based on the patent claims and the general nature of the dispute, several technical and legal questions may arise.
  • Scope Questions: A central issue may be the interpretation of "reusable identifier." The infringement analysis may turn on whether the identifier used in the accused system can be used more than once and for multiple users, as described in the patent (’116 Patent, col. 9:6-14), or if it contains session-specific data that might place it outside the claim's scope.
  • Technical Questions: A key factual question will be whether the accused system's architecture maps onto the three-party structure (user device, host computer, verification server) required by the claims. The complaint does not provide evidence to determine if the accused system sends signals with the specific content (e.g., a copy of the identifier plus separate verification information) required by the claim limitations.

V. Key Claim Terms for Construction

• The Term: "reusable identifier" (Claim 1, 11)

• Context and Importance: This term appears in every independent claim and is positioned as a key feature distinguishing the invention from systems using "one-time-use" codes (’116 Patent, col. 6:53-58). The outcome of the infringement analysis will heavily depend on whether the accused product's authentication token or code is deemed "reusable" as that term is construed.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification defines "reusable" with reference to an identifier that "can be used more than once" and is "not unique to one particular user or transaction" (’116 Patent, col. 9:6-12). This language could support a construction that covers any identifier not strictly for single use by a single user.
  • Evidence for a Narrower Interpretation: The patent also states the reusable identifier "does not contain user-specific or transaction-specific information" (’116 Patent, col. 9:12-14) and frequently uses a static QR code as an example. This could support a narrower construction limited to identifiers that are generic and devoid of any dynamic, user-specific, or session-specific data.

• The Term: "user verification information" (Claim 1, 11)

• Context and Importance: This term defines what the user's device adds to the authentication request to prove the user's identity. The nature of this data in the accused product will be critical to determining infringement, as it must be distinct from the "reusable identifier."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification discloses that this information can include a wide variety of data, such as the user's name or email, "device-specific information" like a hardware ID, or "information derivable from user-specific information" (’116 Patent, col. 12:5-20). This suggests the term could encompass many different forms of authentication data.
  • Evidence for a Narrower Interpretation: The claim structure requires this information to be sent alongside a "copy of the reusable identifier." This may support an interpretation that the "user verification information" must be a data element separate from, and not embedded within, the identifier itself.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement, stating that Defendant distributes "product literature and website materials" that instruct users to operate the accused products in a manner that directly infringes the ’116 Patent (Compl. ¶14).
• Willful Infringement: The basis for willfulness is alleged post-suit knowledge. The complaint asserts that its service "constitutes actual knowledge" and that Defendant's continued infringing activities despite this knowledge are willful (Compl. ¶13-14).

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

• A primary issue will be evidentiary: what is the precise technical operation of the accused products? Because the complaint fails to identify the products or provide the referenced claim charts, the initial phase of litigation will likely focus on discovering the facts necessary to articulate a specific infringement theory.
• A central legal issue will be one of claim construction: how will the court define a "reusable identifier"? The case may turn on whether this term, described in the patent as being separate from user-specific data, can be construed to read on the types of modern authentication tokens used in the accused systems, which may contain encrypted or session-specific information.
• A key question of infringement will be whether the accused system's architecture and data flows align with the three-party model recited in the claims. The analysis will require determining if the accused system transmits distinct signals corresponding to the "first signal" (from the host computer) and "second signal" (from the user's device) as claimed.