DCT
4:25-cv-00313
TicketMatrix LLC v. Houston NFL Holdings LP
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: TicketMatrix LLC (NM)
- Defendant: Houston NFL Holdings, L.P. (Houston Texans) (DE)
- Plaintiff’s Counsel: Rabicoff Law LLC
- Case Identification: 4:25-cv-00313, S.D. Tex., 04/24/2025
- Venue Allegations: Venue is alleged to be proper based on Defendant maintaining an established place of business (NRG Stadium) in the district and committing the alleged acts of patent infringement within the district.
- Core Dispute: Plaintiff alleges that Defendant’s computerized ticketing systems infringe a patent related to dynamically allocating event admissions based on probabilistic models of player success in a tournament.
- Technical Context: The technology addresses the market for sports and entertainment ticketing, specifically for tournament-style events where the participants in later rounds are not known at the time of initial ticket sales.
- Key Procedural History: The operative pleading is a First Amended Complaint. The complaint alleges that the filing of the Original Complaint on January 26, 2025, established Defendant's actual knowledge of the patent for the purposes of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2006-01-24 | '452 Patent Priority Date (Application Filed) |
| 2010-11-09 | '452 Patent Issue Date |
| 2025-01-26 | Original Complaint Filing Date |
| 2025-04-24 | First Amended 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
- Patent Identification: 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's background section identifies a deficiency in conventional ticketing for sporting tournaments. Fans often must purchase tickets for later-round matches before the competing players are known, which can result in fans buying tickets for matches they have "little interest" in attending ('452 Patent, col. 1:28-35; Compl. ¶11). This creates inefficiency in ticket allocation and can lead to a "suboptimal...fan experience" ('452 Patent, col. 1:35-38; Compl. ¶12).
- The Patented Solution: The invention is a computerized method for selling "player's tickets" that are tied to a specific player's participation rather than a specific match ('452 Patent, col. 2:54-59). The system uses computational techniques, such as running multiple tournament simulations, to calculate the probabilities of players advancing and to determine the number of seats that should be allocated for "player's ticket" holders for each potential match at "various levels of confidence" ('452 Patent, col. 2:40-49; Compl. ¶14). This allows an event organizer to manage seat inventory based on probabilistic outcomes rather than fixed schedules.
- Technical Importance: The described approach seeks to shift the paradigm from event-centric to player-centric ticketing, using computational modeling to manage the financial and logistical risks associated with uncertain tournament outcomes (Compl. ¶17).
Key Claims at a Glance
- The complaint asserts infringement of "one or more claims," with a focus on at least Claim 1 (Compl. ¶¶ 20, 23).
- Independent Claim 1 is a method claim with the following essential elements:
- Providing, via a server, "player's ticket options" that reference at least one player and allow holders to gain admission to a match where that player competes.
- Acquiring tournament information (e.g., players, draw, historical data).
- Determining, for at least one match, the "probabilities of players winning" based on the tournament information.
- Determining at least one "possible allocation of match admissions" for the ticket option holders.
- Allocating match admissions based on the determined player-winning probabilities and, crucially, also on "the probability of player's ticket option holders exercising the player's ticket options."
III. The Accused Instrumentality
Product Identification
The complaint does not identify specific accused products by name, referring to them generally as "Exemplary Defendant Products" or Defendant's ticketing systems and methods (Compl. ¶23).
Functionality and Market Context
The complaint alleges that Defendant, an NFL franchise, uses, offers for sale, and sells infringing products and services for ticketing (Compl. ¶¶ 23, 26). The infringement allegations are contained in claim charts incorporated by reference as Exhibit 2, which was not provided with the complaint document (Compl. ¶¶ 28-29). The complaint asserts that these systems perform the functions recited in the patent claims, including determining probabilities of player success and allocating tickets accordingly, but provides no independent technical description of how the accused systems operate (Compl. ¶20). No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint incorporates infringement allegations by reference to an external claim chart exhibit, which is not provided. The following chart summarizes the infringement theory for Claim 1 based on the narrative allegations in the complaint.
'452 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| providing, via the player's ticketing server, player's ticket options that: (a) reference at least one player, (b) allow player's ticket option holders to exercise the player's ticket options, and (c) allow the player's ticket option holders admission to a match in which the at least one player is playing after exercising the player's ticket option; | The complaint does not provide sufficient detail for analysis of this element, but generally alleges that Defendant's ticketing systems infringe the patent's claims (Compl. ¶23). | ¶23 | col. 30:10-18 |
| acquiring, using the player's ticketing server, information about a tournament, including information selected from the group consisting of players, a tournament draw, and historical data; | The complaint does not provide sufficient detail for analysis of this element, but generally alleges that Defendant's ticketing systems infringe the patent's claims (Compl. ¶23). | ¶23 | col. 30:19-23 |
| determining, using the player's ticketing server, for at least one match of the tournament probabilities of players winning based on the tournament information; | The complaint alleges that Defendant’s system performs the inventive concept of "determining, using the player's ticketing server, for at least one match of the tournament probabilities of players winning based on the tournament information" (Compl. ¶20). | ¶20 | col. 30:24-27 |
| determining, using the player's ticketing server, at least one possible allocation of match admissions for player's ticket options for the at least one match based on the player's ticket options provided and the tournament draw; and | The complaint alleges that Defendant’s system performs the inventive concept of "determining, using the player's ticketing server, at least one possible allocation of match admissions for player's ticket options for the at least one match" (Compl. ¶20). | ¶20 | col. 30:28-33 |
| allocating, using the player's ticketing server, match admissions for player's ticket options for the at least one match based on the at least one possible allocation of match admissions, on the probabilities of players winning the at least one match, and on the probability of player's ticket option holders exercising the player's ticket options. | The complaint alleges that Defendant’s system performs the inventive concept of "allocating, using the player's ticketing server, match admissions...on the probabilities of players winning the at least one match, and on the probability of player's ticket option holders exercising" them (Compl. ¶20). | ¶20 | col. 30:34-42 |
- Identified Points of Contention:
- Scope Questions: The patent’s specification and figures heavily emphasize a tournament-bracket structure (e.g., tennis) where future opponents are unknown ('452 Patent, Fig. 1). A potential dispute is whether the claims can be interpreted to cover ticketing for a professional football league, where the season schedule is largely predetermined. This raises the question of whether the term "tournament" as used in the patent can read on an NFL season.
- Technical Questions: The complaint alleges that the accused systems perform complex probabilistic calculations but provides no specific evidence. A central question will be whether Plaintiff can demonstrate that Defendant’s system actually performs the two distinct probability calculations required by Claim 1: (1) the probability of a player winning a future match, and (2) the probability of a fan exercising a ticket option based on that outcome.
V. Key Claim Terms for Construction
The Term: "probabilities of players winning"
- Context and Importance: This term is the technical core of the invention. The infringement analysis will depend on whether this requires the complex, simulation-based analysis detailed in the patent or if a simpler form of forecasting would suffice. Practitioners may focus on this term because the patent's disclosure of running "various techniques for simulating matches" suggests a specific, computationally intensive process ('452 Patent, col. 2:42-43).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself does not specify how the probabilities must be determined, only that they are "based on the tournament information" ('452 Patent, col. 30:26-27). This could suggest that any method of determination using that information is covered.
- Evidence for a Narrower Interpretation: The detailed description repeatedly discusses using "historical data," running "computer simulations of the tournament," and generating "probability distributions" to determine outcomes ('452 Patent, col. 2:40-55, col. 12:9-24). A defendant may argue that these detailed descriptions limit the claim term to these more sophisticated, simulation-based methods.
The Term: "allocating...based on...the probability of player's ticket option holders exercising the player's ticket options"
- Context and Importance: This limitation requires a second, distinct probabilistic calculation related to fan behavior, not just player performance. Proving that an accused system performs this specific step is a significant evidentiary hurdle. Its construction is critical because it separates the invention from simpler systems that might only forecast player success or general ticket demand.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim does not prescribe a specific algorithm. An argument could be made that any system that adjusts seat allocation based on an expectation of how many option-holders will show up meets this limitation.
- Evidence for a Narrower Interpretation: The specification describes this feature as a "dampening technique" used to "determine the allocation of seats based on the potential exercise of player's ticket options" ('452 Patent, col. 25:10-14, col. 23:55-62). This specific framing may support a narrower construction requiring a direct, mathematically-defined "dampening" of the seat allocation based on a calculated exercise probability.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating Defendant provides its products to customers and distributes "product literature and website materials" that instruct and encourage infringing use (Compl. ¶¶ 26-27).
- Willful Infringement: Willfulness is alleged based on Defendant’s continued infringing activities after receiving "actual knowledge" of the '452 Patent upon service of the original complaint on January 26, 2025 (Compl. ¶¶ 25-26).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of applicability: can the patent’s claims and terminology, which are described in the context of knockout-style tournaments with unknown future matchups (e.g., tennis), be construed to cover the ticketing systems for a professional football league that operates with a largely pre-determined seasonal schedule?
- A key evidentiary question will be one of technical proof: can Plaintiff produce evidence that Defendant’s system performs the specific, two-part probabilistic analysis recited in Claim 1—calculating not only the probability of player success but also the separate probability of fans exercising their options—or does the accused system utilize a more general-purpose inventory or demand forecasting algorithm that falls outside the claim scope?