DCT

4:25-cv-01306

Secure Matrix LLC v. Doskocil Mfg Co Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:25-cv-01306, N.D. Tex., 11/19/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant is a Texas corporation with an established place of business in the Northern District of Texas, where it has allegedly committed acts of patent infringement.
  • Core Dispute: Plaintiff alleges that Defendant’s unspecified products infringe a patent related to methods for authenticating a user for a secure online interaction using a separate electronic device.
  • Technical Context: The technology at issue falls within the domain of multi-factor authentication, where a user's mobile device is used as a second factor to verify identity when accessing a service on a different computer, relevant to secure logins and online payments.
  • Key Procedural History: The complaint does not allege any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date Event
2012-11-21 ’116 Patent Priority Date
2014-03-18 ’116 Patent Issue Date
2025-11-19 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" for secure online portals and transactions, as well as for real-world devices actuated via the internet (’116 Patent, col. 1:20-29). The goal is to provide a "secure and fast" method for such authentication and payment capabilities (’116 Patent, col. 1:27-29).
  • The Patented Solution: The invention proposes a three-part authentication system typically involving a primary computer (e.g., a desktop), a user's electronic device (e.g., a smartphone), and a verification server (’116 Patent, Fig. 2). The computer displays a "reusable identifier" (such as a QR code) to the user; the user's device captures this identifier and sends it, along with "user verification information," to the verification server; the server then evaluates the data and, if valid, sends an authorization signal back to the primary computer to grant the user access (’116 Patent, Abstract; col. 6:4-33).
  • Technical Importance: The system is designed to enhance security and user experience by using identifiers that do not need to contain sensitive user-specific or transaction-specific information, which simplifies the identifier (e.g., a lower-resolution QR code) and reduces server-side computing requirements (’116 Patent, col. 6:35-62).

Key Claims at a Glance

  • The complaint alleges infringement of "exemplary claims" identified in an unattached exhibit (Compl. ¶11). Based on the patent’s structure, independent claim 1 is representative of the asserted method.
  • Essential elements of Independent Claim 1 include:
    • Using a computer system to receive 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, 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.
    • Transmitting a third signal with authorization information to the computer and/or the user's device in response to a successful evaluation.

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products, methods, or services by name (Compl. ¶11). It refers generally to "Exemplary Defendant Products" that are purportedly identified in an exhibit not attached to the publicly filed complaint (Compl. ¶11, ¶15).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the functionality or market context of any accused instrumentality.

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant's "Exemplary Defendant Products" infringe the ’116 Patent, stating that charts in an unattached "Exhibit 2" compare the patent claims to these products (Compl. ¶15). As this exhibit was not provided, a detailed claim chart summary cannot be constructed. The complaint’s narrative theory is conclusory, asserting that the accused products "practice the technology claimed by the '116 Patent" and "satisfy all elements of the Exemplary '116 Patent Claims" without providing specific factual allegations in the body of the complaint itself (Compl. ¶15). No probative visual evidence provided in complaint.

  • Identified Points of Contention:
    • Pleading Sufficiency: A threshold issue for the court may be whether the complaint, by relying entirely on an external, unattached document for its substantive infringement allegations, meets the plausibility pleading standard required by Federal Rule of Civil Procedure 8 and the Supreme Court's decisions in Bell Atlantic Corp. v. Twombly and Ashcroft v. Iqbal.
    • Technical Questions: Absent any description of the accused products, it is not possible to identify specific technical questions. Central to any future infringement analysis will be establishing the basic facts of how Defendant’s systems operate, including whether they generate identifiers, how those identifiers are used, what data they contain, and how user verification is accomplished.

V. Key Claim Terms for Construction

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

    • Context and Importance: The scope of this term is central to the invention. Practitioners may focus on whether "reusable" is limited by the specification's teachings, which distinguish the invention from systems that use "one-time-use" or "unique" identifiers containing transaction-specific data (Compl. ¶116 Patent, col. 9:16-23).
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The plain meaning of "reusable" suggests any identifier that can be used more than once would meet the limitation.
      • Evidence for a Narrower Interpretation: The specification repeatedly emphasizes as an advantage that the identifier "does not contain user-specific or interaction-specific information" (’116 Patent, col. 2:40-42) and that this makes the system "safer to use" and less complex (’116 Patent, col. 6:58-62). This could support a construction that limits the term to identifiers lacking such specific data.

  • The Term: "assigned for use... for a finite period of time" (Claim 1)

    • Context and Importance: This temporal limitation will be critical for determining infringement. The parties will likely dispute the nature and duration required to satisfy the "finite period."
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: Any period that is not infinite could be considered "finite," potentially reading on identifiers that are valid for long durations before being cycled.
      • Evidence for a Narrower Interpretation: The specification describes embodiments where identifiers are "only valid for a finite and predetermined period of time (e.g., one or more minutes, one or more hours, one or more days)" and may be reused in a subsequent period after others have been used in a "round robin fashion" (’116 Patent, col. 9:42-51). This suggests a more structured and potentially shorter-term assignment than an indefinite validity.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement to infringe, asserting that Defendant distributes "product literature and website materials" that instruct end users to use the accused products in an infringing manner (Compl. ¶14).
  • Willful Infringement: The willfulness allegation is based solely on knowledge obtained from the service of the complaint itself (Compl. ¶13). The complaint does not allege any facts suggesting Defendant had knowledge of the ’116 Patent prior to the lawsuit's filing.

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

  • A threshold procedural issue will be one of pleading sufficiency: does the complaint, which outsources all of its substantive factual allegations to an unattached exhibit, provide the "short and plain statement" of the claim required by Rule 8, or will it be found deficient under the Twombly/Iqbal plausibility standard?
  • A central claim construction dispute will concern the definitional scope of "reusable identifier": is the term limited by the specification's repeated distinctions over the prior art to identifiers that are free of user- and transaction-specific data, or does its plain meaning simply require that it be usable more than once?
  • A key evidentiary question will turn on the temporal limitation of "assigned for use...for a finite period of time": what technical evidence will be required to demonstrate that an identifier in an accused system is "assigned" for a specific period, as opposed to merely being active or valid until replaced?