Secure Matrix LLC v. Star Furniture Co LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Secure Matrix LLC (Delaware)
  • Defendant: Star Furniture Company, LLC (Texas)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 4:25-cv-04771, S.D. Tex., 10/06/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains an established place of business in the district and has committed alleged acts of patent infringement there.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to systems and methods for user authentication and verification.
• Technical Context: The technology at issue concerns methods for securely authenticating users for online interactions, such as logging into a website or making an electronic payment, often involving a secondary personal device.
• 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	’116 Patent Priority Date
2014-03-18	’116 Patent Issue Date
2025-10-06	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"

The Invention Explained

• Problem Addressed: The patent describes a "growing need to authenticate users" accessing secured internet portals or real-world devices, as well as a need for a "secure and fast online electronic payment capability" (’116 Patent, col. 1:20-29).
• The Patented Solution: The invention proposes a multi-component system to solve this problem. A verification server acts as an intermediary between a computer providing a secured service (e.g., a website) and a user's separate electronic device (e.g., a smartphone) (’116 Patent, Abstract). The computer sends a "reusable identifier" to the verification server; the user's device sends a copy of that same identifier along with user verification information; the server evaluates whether the user is authorized; and, if so, transmits an authorization signal back to the computer and/or the user's device (’116 Patent, col. 1:32-49; Fig. 2).
• Technical Importance: The system's use of a "reusable identifier" that does not contain user-specific or transaction-specific information is presented as an advantage, allowing for simpler graphical codes (like QR codes), faster processing, and enhanced security compared to systems that encode sensitive data for each transaction (’116 Patent, col. 6:35-62).

Key Claims at a Glance

• The complaint alleges infringement of one or more claims, identifying them as the "Exemplary '116 Patent Claims" in a referenced exhibit not attached to the pleading (Compl. ¶11). Independent claim 1 is representative of the core method.
• Independent Claim 1 (Method):
  • 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 an electronic device being used by the user, the signal comprising a copy of the reusable identifier and user verification information.
  • Using a processor of the computer system to evaluate, based on the first and second signals, whether the user is authorized.
  • In response to an indication that the user is authorized, using the computer system to transmit a third signal comprising authorization information to the electronic device and/or the computer.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as "Exemplary Defendant Products" listed in claim charts that are incorporated by reference but not attached to the public filing (Compl. ¶11, ¶16).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality. It alleges on information and belief that "numerous other devices" also infringe (Compl. ¶11). No details are provided regarding the products' commercial importance or market positioning.

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant's "Exemplary Defendant Products practice the technology claimed by the '116 Patent" and states that this is "set forth in these charts" (Compl. ¶16). However, the complaint was filed without the referenced "Exhibit 2" containing these claim charts. Therefore, the complaint itself provides no specific factual allegations mapping limitations of the asserted claims to features of the accused products (Compl. ¶17).

No probative visual evidence provided in complaint.

Identified Points of Contention

Lacking specific infringement allegations, analysis must anticipate likely areas of dispute based on the patent's claims and the nature of the defendant, a furniture company. The dispute may center on whether the defendant's website authentication or e-commerce payment system meets the specific multi-device, multi-signal architecture of the asserted claims.

• Scope Questions: A central question may be whether a conventional user login process, potentially conducted on a single device (e.g., a customer's computer or smartphone), can satisfy the claim requirement for receiving a "first signal" from the computer providing the service and a distinct "second signal" from "an electronic device being used by the user."
• Technical Questions: The complaint provides no evidence detailing how the accused products allegedly generate, transmit, and process a "reusable identifier" in the manner claimed. A key factual dispute may be whether the accused system utilizes an identifier that is decoupled from user-specific information and is communicated between multiple system components as described in the patent (’116 Patent, col. 6:35-41).

V. Key Claim Terms for Construction

"reusable identifier"

• Context and Importance: This term is the core of the claimed invention. Its construction will be critical to determining infringement, as it distinguishes the claimed method from systems using unique, "one-time-use" identifiers or identifiers that contain user-specific data. Practitioners may focus on whether this term requires the identifier to be generic and non-user-specific, or if it can cover user-specific identifiers like usernames or session tokens that are used multiple times.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language states the identifier is "reusable," which could be interpreted simply as being usable more than once (’116 Patent, col. 33:23-24). The specification also notes that the identifier "may or may not be encrypted," suggesting its content is not inherently sensitive (’116 Patent, col. 9:4-5).
  • Evidence for a Narrower Interpretation: The specification repeatedly contrasts the invention with conventional systems by stating the "reusable identifier... does not contain user-specific or transaction-specific information" and that this is an advantage (’116 Patent, col. 9:11-14; col. 6:35-41). The patent states that because no user- or transaction-specific information is included, the "QR code... can be much simpler" and safer to use (’116 Patent, col. 6:41-48, 60-62). This suggests the "reusable" nature is tied to its generic, non-specific content.

"an electronic device being used by the user"

• Context and Importance: This term appears in the limitation for receiving the "second signal" and seems distinct from the "computer providing the secured capability" that originates the "first signal." The definition will determine whether the claims require a two-device system (e.g., a PC and a smartphone) or if they can be read on a process occurring within a single user device.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term itself does not explicitly forbid the "electronic device" and the "computer" from being the same physical hardware, which could support an argument that the claims cover software-differentiated components on one device.
  • Evidence for a Narrower Interpretation: The specification and figures consistently depict a two-device architecture. For example, Figure 2 shows a "User browser" (30) and a separate "Mobile device" (20) interacting with servers (’116 Patent, Fig. 2). The description details embodiments where a user "scan[s] the QR code displayed by the second electronic device" using a "first electronic device," such as a smartphone scanning a computer screen (’116 Patent, col. 6:19-23).

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in an infringing manner (Compl. ¶14). The allegation of knowledge and intent is explicitly tied to the date of service of the complaint (Compl. ¶15).

Willful Infringement

The complaint alleges that service of the complaint itself provides "actual knowledge of infringement" (Compl. ¶13). It further alleges that "Despite such actual knowledge, Defendant continues to make, use, test, sell, offer for sale, market, and/or import" the accused products, which forms the basis for a claim of post-suit willful infringement (Compl. ¶14).

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

• A core issue will be one of architectural mismatch: Does the accused system—likely a standard e-commerce website—actually implement the multi-device, intermediary-server architecture required by the claims, or will Plaintiff's infringement theory attempt to read the claims onto a conventional single-device login process?
• A dispositive question will be one of definitional scope: Can the term "reusable identifier," which the patent describes as being free of user-specific information, be construed to cover conventional web technologies like usernames or session cookies that are inherently tied to a specific user account?
• An evidentiary question will be one of factual proof: As the complaint provides no technical details of the accused system, a central issue for discovery will be for Plaintiff to produce evidence that Defendant's system actually performs the claimed steps of generating and separately transmitting a "first signal" and a "second signal" for authentication as claimed.