DCT
1:25-cv-01503
EasyWeb Innovations LLC v. X Corp
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: EasyWeb Innovations, LLC (New York)
- Defendant: X Corp. f/k/a Twitter, Inc. (Nevada)
- Plaintiff’s Counsel: Hecht Partners LLP
- Case Identification: 1:25-cv-01503, W.D. Tex., 09/15/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant X Corp. maintains a regular and established place of business in the district, specifically an office in Austin, and has committed acts of infringement there.
- Core Dispute: Plaintiff alleges that Defendant’s social media platform, formerly known as Twitter and now X, infringes a patent related to methods for allowing individual users to select from multiple levels of security for accessing a computer system.
- Technical Context: The technology concerns user-customizable computer security, where different users of the same system can choose their own preferred balance between convenience and security strength for authentication.
- Key Procedural History: The complaint notes that during prosecution, the asserted patent overcame a patent-eligibility rejection under 35 U.S.C. § 101. The applicant successfully argued that the claims represented a "concrete improvement" over conventional, system-wide security schemes by enabling security selection on a per-user basis.
Case Timeline
| Date | Event |
|---|---|
| 1999-03-11 | U.S. Patent No. 10,114,905 Priority Date |
| 2016-01-01 | Alleged launch of infringing Twitter Applications |
| 2018-10-30 | U.S. Patent No. 10,114,905 Issues |
| 2025-09-15 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,114,905 - "Individual User Selectable Multi-Level Authorization Method for Accessing a Computer System"
The Invention Explained
- Problem Addressed: The complaint asserts that at the time of the invention, computer access security systems were typically rigid and "administered system-wide," forcing all users of a system to use the same, single security method without any choice for customization (Compl. ¶18). This meant a user could not opt for a more secure authentication method than the system's default (Compl. ¶18).
- The Patented Solution: The invention provides a method where individual users of a computer system can select a security scheme from a "plurality of security schemes" provided by the system (’905 Patent, Abstract). The key innovation is that these schemes have different security levels, with at least one scheme requiring "additional identification information" compared to another, allowing users to choose their own balance between security and convenience (’905 Patent, Abstract; Compl. ¶19). A user’s choice is then stored as a preference associated with their account and used for subsequent authorizations (’905 Patent, col. 45:38-44).
- Technical Importance: The technology is presented as an improvement in computer functionality that moves beyond the conventional "one-size-fits-all" approach to security, giving individual users control over their own authorization strength (Compl. ¶¶19, 24).
Key Claims at a Glance
- The complaint asserts infringement of claims 1-20 (Compl. ¶32). Independent claim 1 is a method claim.
- The essential elements of independent claim 1 include:
- Prompting a particular user for a selection of a security scheme from a plurality of schemes.
- Wherein a first scheme requires a specific number of identification information and a second scheme requires additional identification information beyond the first.
- Storing the user's selection as a preference in the user's storage area.
- Authorizing the user's access to the computer system when the selected security scheme is satisfied.
- The complaint asserts both independent and dependent claims (Compl. ¶32).
III. The Accused Instrumentality
Product Identification
- The accused products are "all versions and variants of the Twitter Web and Desktop/Mobile Applications since 2016," also referred to as the Twitter system, and now known as the X platform (Compl. ¶¶26, 28).
Functionality and Market Context
- The complaint alleges that the accused products infringe by providing users with customizable access security options (Compl. ¶33). Specifically, the platform allegedly "allows each particular user to select between a standard username/email/phone number and password security scheme, and a Two-factor security scheme that requires an additional piece of identification information to authorize the user to access their account" (Compl. ¶29). The complaint further alleges that this selection is independent of the choices made by other users on the same system (Compl. ¶29). The complaint does not provide sufficient detail for analysis of the product's market positioning.
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint.
- Claim Chart Summary: The complaint does not contain a claim chart exhibit, but its narrative allegations support the following interpretation for claim 1.
’905 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| prompting the particular user of the computer system for a selection of a particular security scheme from among the plurality of security schemes | The Twitter/X platform provides users the option to enable different security methods for their accounts. | ¶29 | col. 45:26-29 |
| wherein first of the plurality of security schemes requires a specific number of identification information to authorize the particular user | The standard login option, which requires a username/password. | ¶29 | col. 45:30-33 |
| and a second of the plurality of security schemes requires additional identification information beyond that of the first scheme to authorize the particular user | The two-factor authentication option, which requires an additional piece of information (e.g., a code from a mobile device) beyond the password. | ¶29 | col. 45:33-37 |
| storing the selection as a preference in the particular user's storage area | The user's choice to enable or disable two-factor authentication is stored as a setting for their specific account. | ¶19, ¶29 | col. 45:38-40 |
| thereafter authorizing the particular user to access the computer system when the selected security scheme of the particular user is satisfied | The system authorizes access after the user successfully provides the credentials required by their chosen security method (either password-only or password-plus-2FA code). | ¶29 | col. 45:41-44 |
- Identified Points of Contention:
- Scope Questions: A central question may be whether offering a standard login and an optional two-factor authentication (2FA) feature constitutes providing a choice between a "plurality of security schemes" as the term is used in the patent. The defense may argue that 2FA is an enhancement to a single scheme rather than a distinct, selectable alternative scheme.
- Technical Questions: The complaint does not detail the specific user interface or workflow for selecting a security option. A key factual question will be whether the accused product’s functionality for enabling 2FA in a settings menu meets the claim limitation of "prompting the particular user... for a selection."
V. Key Claim Terms for Construction
The Term: "security scheme"
Context and Importance: This term is foundational to the infringement case. The definition will determine whether a standard password login and an optional 2FA layer are considered two distinct "schemes" that a user selects between, or merely two configurations of a single underlying authentication scheme.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent abstract describes the schemes functionally, based on enabling a "personal preferred balance between convenience and security" (’905 Patent, Abstract). Claim 1 itself defines the schemes by their differing requirements for identification information, suggesting any two selectable methods with different information requirements could qualify (col. 45:30-37).
- Evidence for a Narrower Interpretation: The patent does not appear to offer an explicit definition that would clearly limit the term. A defendant may argue that the context implies more architecturally distinct systems rather than an optional, additive security layer.
The Term: "prompting... for a selection"
Context and Importance: Infringement of this active step depends on the user interaction required by the accused platform. Practitioners may focus on this term because the act of "prompting" could be construed to require more than passively making an option available in a settings menu.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent describes an interactive menu where a user makes a selection, which could support an interpretation where "prompting" means presenting a menu of options for the user to act upon (’905 Patent, col. 19:51-64).
- Evidence for a Narrower Interpretation: A defendant might argue that "prompting" requires an unavoidable, active solicitation for a choice (e.g., during account setup), as opposed to an optional setting a user must navigate to find.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement by asserting that Defendant provides "instructions, documentation, and other information to customers and end-users suggesting that they use the Accused Products in an infringing manner" (Compl. ¶36).
- Willful Infringement: Willfulness is alleged based on the assertion that "Defendant was on notice of the Patent in Suit since it was published" (Compl. ¶38). This allegation does not specify that Defendant had actual knowledge of the patent prior to the lawsuit.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of patent eligibility: given the complaint’s extensive pre-emptive defense of the patent's validity under 35 U.S.C. § 101, a primary battleground will be whether the claims are directed to the abstract idea of tiered security access and, if so, whether enabling this on a per-user basis constitutes a concrete, technological improvement sufficient to confer patentability under the Alice framework.
- A second key issue will be one of definitional scope: can the term "security scheme," as used in the patent, be construed to cover a standard password login and an optional, add-on 2FA feature as two distinct, selectable schemes, or does the claim language require more fundamentally different systems?
- A third question will be evidentiary: what specific evidence will show that the accused platform’s user interface and backend system perform the "prompting" and "storing" steps as claimed, moving beyond the high-level allegations in the complaint?