Secure Matrix LLC v. Petmate Holdings Co

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Secure Matrix LLC (Delaware)
  • Defendant: Petmate Holdings Co. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC; DNL Zito
• Case Identification: 4:25-cv-01194, N.D. Tex., 10/24/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains an established place of business in the Northern District of Texas and has committed acts of patent infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified products infringe a patent related to systems and methods for user authentication and verification.
• Technical Context: The technology concerns secure, multi-device authentication, where a user's portable device is used to authorize a transaction or login initiated on a separate computer, a common paradigm in modern e-commerce and online security.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to 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 Issues
2025-10-24	Complaint Filed

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

U.S. Patent No. 8,677,116 - Systems and methods for authentication and verification (Issued Mar. 18, 2014)

The Invention Explained

• Problem Addressed: The patent describes a "growing need to authenticate users" accessing secure internet portals or physical devices, as well as a need for "secure and fast online electronic payment capability" as e-commerce transactions increase (’116 Patent, col. 1:20-29).
• The Patented Solution: The invention proposes a verification system involving three distinct entities: a primary computer (e.g., a web server), a user's electronic device (e.g., a smartphone), and a verification server (’116 Patent, Abstract; Fig. 2). The computer provides a "reusable identifier" (e.g., as a QR code) to the user; the user's device captures this identifier, combines it with user verification data, and sends a second signal to the verification server. The verification server then evaluates the signals from both the primary computer and the user's device to determine whether to authorize the interaction (’116 Patent, col. 2:30-49).
• Technical Importance: This architecture separates the device initiating an action from the device authenticating it, creating an out-of-band verification channel intended to be more secure than traditional single-device password entry systems (’116 Patent, col. 6:35-41).

Key Claims at a Glance

The complaint does not specify which claims are asserted, instead referring to "exemplary claims" in an unattached exhibit (Compl. ¶11, 15). Independent claim 1 is representative of the technology and includes the following essential elements:

• Using a computer system to receive a first signal from a computer providing a secured capability, the signal comprising a reusable identifier assigned for a finite period of time.
• Using the computer system to receive a second signal from a user's electronic device, the signal 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.
• In response to an authorization, transmitting a third signal with authorization information to the electronic device and/or the computer.

III. The Accused Instrumentality

Product Identification

The complaint does not identify any accused products, methods, or services by name (Compl. ¶11). It refers to "Exemplary Defendant Products" detailed in claim charts within an "Exhibit 2," which was not filed with the complaint (Compl. ¶15-16).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality or market position.

IV. Analysis of Infringement Allegations

The complaint alleges that the unspecified "Exemplary Defendant Products" directly infringe the ’116 Patent by "practic[ing] the technology claimed" and satisfying "all elements of the Exemplary '116 Patent Claims" (Compl. ¶15, 16). However, the complaint incorporates these allegations by reference to claim charts in Exhibit 2, which is not included in the provided documents (Compl. ¶16). Without these charts, a detailed analysis of the infringement theory is not possible.

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Factual Question: The primary point of contention will be factual: what are the accused products, and does their architecture map onto the three-part system (originating computer, user device, verification server) required by the patent? The complaint provides no facts to support this mapping.
  • Scope Question: A likely dispute will concern whether the accused products, once identified, utilize a "reusable identifier" that is "assigned for use... for a finite period of time" as claimed (’116 Patent, col. 33:24-25). The interpretation of this temporal and functional limitation will be critical.

V. Key Claim Terms for Construction

• The Term: "reusable identifier"

• Context and Importance: This term is central to distinguishing the invention from prior art systems that may use "one-time-use" tokens. The patent’s scope hinges on whether this term covers modern session identifiers or is limited to the specific embodiments described. Practitioners may focus on this term because its construction will determine whether a wide range of modern authentication systems fall within the patent's reach.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification states the identifier "can be used more than once" and for "multiple users and multiple transactions," suggesting a broad meaning not strictly limited to a single user or session (’116 Patent, col. 9:8-16).
  • Evidence for a Narrower Interpretation: The specification repeatedly emphasizes that the identifier "does not contain user-specific or transaction-specific information" and describes embodiments using a "predefined and previously generated list" of identifiers in a "round robin usage" fashion, which may support a narrower construction limited to such systems (’116 Patent, col. 9:13-14, 9:23-43).

• The Term: "assigned for use by the secured capability for a finite period of time"

• Context and Importance: This limitation from independent claim 1 adds a temporal element to the "reusable identifier." The viability of the infringement claim will depend on whether an accused system's identifier can be shown to be "assigned" for a specific, "finite" duration in the manner claimed.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification provides examples of the finite period ranging from "one or more minutes, one or more hours, one or more days," suggesting the term could cover a wide variety of expiration protocols (’116 Patent, col. 9:44-46).
  • Evidence for a Narrower Interpretation: This phrase, when read in the context of the "round robin" embodiment, may be construed to require a pre-assignment of an identifier from a rotating list for a set time, rather than a dynamically generated session token that simply expires (’116 Patent, col. 9:36-54).

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendant distributes "product literature and website materials" that instruct end users to use the accused products in a manner that infringes the ’116 Patent (Compl. ¶14).
• Willful Infringement: The willfulness allegation is based on post-suit knowledge. The complaint asserts that its service provides Defendant with "actual knowledge" and that any continued infringing activity thereafter is willful (Compl. ¶13-14).

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

• A core issue will be one of evidentiary sufficiency: The complaint’s primary deficiency is its failure to identify the accused products or provide the referenced claim charts. The initial phase of the case will likely focus on rectifying this fundamental gap to establish a plausible infringement theory.
• A key question will be one of definitional scope: The case will likely turn on the construction of "reusable identifier... assigned for use... for a finite period of time." The central legal battle will be whether this term, as defined by the patent's specification, can be interpreted broadly enough to read on the technologies used in the yet-to-be-identified accused products, or if it is confined to the specific "round robin" system described in the patent's preferred embodiments.