DCT

5:25-cv-00020

TicketMatrix LLC v. Seattle Seahawks LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 5:25-cv-00020, N.D. Tex., 02/05/2025
  • Venue Allegations: Venue is alleged to be proper in the Northern District of Texas because the Defendant maintains an established place of business in the district and has purportedly committed acts of infringement there.
  • Core Dispute: Plaintiff alleges that Defendant’s ticketing systems and methods infringe a patent related to providing and managing player-specific ticket options for sporting events using probabilistic analysis.
  • Technical Context: The technology at issue concerns systems for creating and selling ticketing instruments, akin to financial options, that are tied to a specific athlete's participation in a tournament rather than a fixed event date, using statistical modeling to manage seat inventory and risk.
  • 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
2006-01-24 '452 Patent Priority Date
2010-11-09 '452 Patent Issue Date
2025-02-05 Complaint Filing Date

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"

  • Issued: November 9, 2010

The Invention Explained

  • Problem Addressed: The patent addresses the issue faced by sports fans who must purchase tickets for later-round tournament matches far in advance, without knowing which athletes will be competing. This creates a risk that the fan will pay for a ticket to a match they have little interest in, forcing them to forfeit the investment or attempt to resell the ticket at a loss (’452 Patent, col. 1:8-38).
  • The Patented Solution: The invention proposes a ticketing system that sells a "player's ticket" or a "player's ticket option," which is tied to the participation of a specific player rather than a specific match. The system uses computer modeling, including tournament simulations and player-win probabilities, to forecast the required number of seats for "player's ticket" holders in each potential match, thereby allowing the event organizer to manage inventory risk while offering fans a more flexible product (’452 Patent, col. 2:36-57; FIG. 11).
  • Technical Importance: The technology established a method for creating a new type of futures-like instrument for sporting event attendance, shifting risk from the fan to the organizer, who could then manage that risk through statistical analysis and dynamic seat allocation (’452 Patent, col. 1:39-43).

Key Claims at a Glance

  • The complaint asserts one or more claims of the ’452 Patent, identifying them as the "Exemplary '452 Patent Claims" in an unfiled exhibit (Compl. ¶11, ¶16). Independent claim 1 is representative and includes the following essential method elements:
    • Providing, via a server, "player's ticket options" that reference a player and allow the option holder to gain admission to a match in which that player participates after exercising the option.
    • Acquiring tournament information (e.g., players, draw, historical data).
    • Determining the probabilities of players winning for at least one match.
    • Determining at least one possible allocation of match admissions for the ticket option holders.
    • Allocating match admissions based on the probabilities of players winning and, critically, on "the probability of player's ticket option holders exercising the player's ticket options."
  • The complaint does not specify if dependent claims are asserted but incorporates allegations for "one or more claims" by reference (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not identify the accused products or services by name. It refers to them generally as "the Defendant products identified in the charts incorporated into this Count" and "Exemplary Defendant Products," which are detailed in an exhibit that was not filed with the complaint (Compl. ¶11, ¶16).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's specific functionality or market context. The infringement allegations imply that the accused instrumentality is a ticketing system operated by the Defendant (Compl. ¶11).

IV. Analysis of Infringement Allegations

The complaint alleges infringement but incorporates the specific element-by-element analysis by reference to an external document, Exhibit 2, which was not filed with the complaint (Compl. ¶¶ 16-17). As such, a detailed claim chart analysis based on the complaint's provided text is not possible. The complaint’s narrative theory asserts that the "Exemplary Defendant Products" practice the technology claimed by the ’452 Patent and "satisfy all elements of the Exemplary '452 Patent Claims" (Compl. ¶16).

No probative visual evidence provided in complaint.

  • Identified Points of Contention:
    • Scope Questions: A primary question will be whether the Defendant’s ticketing products or services constitute a "player's ticket option" as contemplated by the patent. The dispute may focus on whether the Defendant offers a simple right to purchase a ticket or a more complex, probabilistically managed instrument as described in the specification.
    • Technical Questions: A key technical question is whether the accused system performs the specific step of "allocating... match admissions... based on... the probability of player's ticket option holders exercising the player's ticket options" (’452 Patent, col. 30:26-34). The case may turn on what evidence the complaint provides that the accused system uses such a probabilistic model for seat allocation, as opposed to a more conventional reservation or inventory management system.

V. Key Claim Terms for Construction

  • The Term: "player's ticket option"

    • Context and Importance: This term defines the core commercial instrument at the heart of the invention. The outcome of the case may depend on whether the Defendant's product offerings are found to meet the specific definition of this term as construed from the patent.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: Claim 1 itself provides a functional definition, requiring only that the option "(a) reference at least one player, (b) allow player's ticket option holders to exercise the player's ticket options, and (c) allow... admission to a match" after exercise (’452 Patent, col. 30:12-18).
      • Evidence for a Narrower Interpretation: The specification describes the option as providing an "opportunity to purchase tickets for a match on preferential terms as compared to the general public" (’452 Patent, col. 2:20-23). A defendant may argue this language limits the claim to options that include demonstrably "preferential terms."

  • The Term: "allocating... match admissions... based on... the probability of... exercising the player's ticket options"

    • Context and Importance: This limitation appears to capture the technical novelty of the risk-management aspect of the system. Practitioners may focus on this term because infringement will likely require proof that the accused system performs this specific data-driven calculation, not just a generic estimation of demand.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: A plaintiff might argue this language covers any system that uses expected exercise rates, however derived, to inform the number of seats to set aside for option holders.
      • Evidence for a Narrower Interpretation: The specification provides extensive detail on using computer-run tournament simulations to generate probability distributions for the number of seats required (’452 Patent, col. 15:7-39; FIGS. 6-8). This detailed disclosure could support a narrower construction requiring a specific statistical modeling process.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that the Defendant induces infringement by distributing "product literature and website materials" that instruct end users on how to use the accused products in an infringing manner (Compl. ¶14). The pleading states that the Defendant has had the requisite knowledge for inducement "At least since being served by this Complaint," which suggests the claim is directed at post-filing conduct (Compl. ¶15).
  • Willful Infringement: Willfulness is predicated on the allegation that the Defendant obtained "actual knowledge of infringement" upon service of the complaint and nonetheless "continues to make, use, test, sell, offer for sale, market, and/or import" the accused products (Compl. ¶¶ 13-14).

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

  • Evidentiary Sufficiency: A threshold issue is whether the Plaintiff can substantiate its conclusory allegations with sufficient factual evidence. A key evidentiary question will be whether the accused "Defendant Products" can be shown to perform the specific, data-driven functions central to the patent—namely, managing a player-based ticket "option" and using probabilistic analysis of exercise rates to allocate seat inventory.
  • Definitional Scope: The case will likely turn on a battle over claim construction. A core issue will be one of technical definition: can the term "allocating... based on... probability," which is described in the patent in the context of complex statistical simulations, be construed to cover the inventory management functions of the Defendant’s ticketing system? The answer will likely determine whether there is a fundamental match or mismatch in technical operation.