DCT
5:25-cv-01405
Securelogix Corp v. Transunion
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: SecureLogix Corp. (Texas)
- Defendant: TransUnion (Delaware)
- Plaintiff’s Counsel: Rosenthal Pauerstein Sandoloski Agather LLP
- Case Identification: 5:25-cv-01405, W.D. Tex., 10/31/2025
- Venue Allegations: Plaintiff SecureLogix alleges venue is proper because Defendant TransUnion purposefully directed patent enforcement activities toward SecureLogix in the district and maintains a regular and established place of business in the district.
- Core Dispute: Plaintiff seeks a declaratory judgment that its Orchestra One™ Call Authentication Service does not infringe four TransUnion patents related to telephone call authentication and caller verification.
- Technical Context: The technology addresses the problem of fraudulent "spoofing" of caller ID information by analyzing an incoming telephone call's network characteristics to generate a real-time trustworthiness score before the call is answered.
- Key Procedural History: This action was filed after Plaintiff received a letter from Defendant on September 23, 2025, alleging infringement. The complaint highlights that one of the asserted patents, U.S. Patent No. 9,001,985, was subject to a prior Inter Partes Review (IPR) where numerous claims were canceled by the Patent Trial and Appeal Board (PTAB), a decision affirmed by the U.S. Court of Appeals for the Federal Circuit. Plaintiff alleges that Defendant's infringement letter asserted at least one of these canceled claims, forming the basis for a separate claim of patent misuse and unenforceability.
Case Timeline
| Date | Event |
|---|---|
| 2009-05-19 | Priority Date for ’532 and ’985 Patents |
| 2012-08-07 | ’532 Patent Issued |
| 2015-04-07 | ’985 Patent Issued |
| 2016-02-16 | Priority Date for ’913 Patent |
| 2016-12-02 | Priority Date for ’728 Patent |
| 2017-09-12 | ’728 Patent Issued |
| 2018-01-16 | ’913 Patent Issued |
| 2018-01-01 | Prior litigation involving ’532, ’985, and ’913 Patents initiated |
| 2021-09-27 | Federal Circuit affirms PTAB decision canceling claims of the ’985 Patent |
| 2022-11-03 | USPTO issues IPR Certificate confirming cancelation of claims of the ’985 Patent |
| 2025-09-23 | TransUnion sends "Claim of Infringement" letter to SecureLogix |
| 2025-10-31 | Complaint for Declaratory Judgment Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,238,532 - Method of and System for Discovering and Reporting Trustworthiness and Credibility of Calling Party Number Information
- Patent Identification: U.S. Patent No. 8,238,532, Method of and System for Discovering and Reporting Trustworthiness and Credibility of Calling Party Number Information, issued August 7, 2012.
The Invention Explained
- Problem Addressed: The patent’s background describes how modern telecommunications, including Voice over Internet Protocol (VoIP), have made it easy for malicious actors to falsify or "spoof" calling party number information (ANI or Caller ID), undermining the security of telephone-based transactions that rely on this information for authentication (e.g., financial services) ( ’532 Patent, col. 2:1-11, 2:46-59).
- The Patented Solution: The invention proposes a system that analyzes an incoming telephone call before it is answered to determine the credibility of the calling number (’532 Patent, col. 4:6-14). It does this by collecting various real-time network data points associated with the calling number—such as the telecom carrier, line type, and geographic location—and probing the network to check the line's status (’532 Patent, Fig. 1). This data is used to create a "real time pattern" that is compared against a database of expected patterns to calculate a "confidence metric" indicating the call's trustworthiness (’532 Patent, col. 5:53-64).
- Technical Importance: This approach seeks to restore trust in telephony by providing an automated, real-time method for validating a caller's purported origin before a business engages in a potentially sensitive interaction (’532 Patent, col.2:55-59).
Key Claims at a Glance
- The complaint, which seeks a declaratory judgment of non-infringement, does not identify specific claims of the ’532 Patent alleged to be infringed (Compl. ¶30).
U.S. Patent No. 9,001,985 - Method of and System for Discovering and Reporting Trustworthiness and Credibility of Calling Party Number Information
- Patent Identification: U.S. Patent No. 9,001,985, Method of and System for Discovering and Reporting Trustworthiness and Credibility of Calling Party Number Information, issued April 7, 2015.
The Invention Explained
- Problem Addressed: As a continuation of the ’532 Patent, the ’985 Patent addresses the same problem of easily falsified calling party information in modern telephone networks, which compromises security for businesses that rely on ANI for authentication (’985 Patent, col. 2:1-11).
- The Patented Solution: The patent describes a method where a call center device, upon receiving an incoming call, requests a "source origin confidence metric" from an electronic system prior to answering the call (’985 Patent, Abstract). This metric is explicitly determined based on the "operational status" of the calling party number, which can be ascertained through probing the telecommunications network to check for conditions like a busy signal, call forwarding, or answer timings (’985 Patent, col. 7:36-54). The call is only answered after this confidence metric is received (’985 Patent, col. 16:21-23).
- Technical Importance: The invention provides call centers with a tool to perform pre-answer risk assessment, enabling automated decisions on how to handle or route a call based on the verified trustworthiness of the calling number (’985 Patent, col. 2:55-59).
Key Claims at a Glance
- The infringement letter attached to the complaint identifies independent claim 13 as a basis for infringement allegations (Compl. Ex. A, p. 13).
- The essential elements of independent claim 13 are:
- Receiving an incoming call and its associated calling party number at a call center device.
- Prior to answering, requesting a "source origin confidence metric" for the number from an electronic system.
- The confidence metric is "determined based on an operational status of the calling party number or billing number."
- Receiving the confidence metric at the call center device.
- Answering the incoming call following receipt of the metric.
- The complaint notes that TransUnion alleges infringement of "one or more claims," suggesting other claims may be at issue (Compl. ¶4).
U.S. Patent No. 9,871,913 - Systems and Method to Identify ANI and Caller ID Manipulation for Determining Trustworthiness of Incoming Calling Party and Billing Number Information
- Patent Identification: U.S. Patent No. 9,871,913, Systems and Method to Identify ANI and Caller ID Manipulation for Determining Trustworthiness of Incoming Calling Party and Billing Number Information, issued January 16, 2018.
- Technology Synopsis: This patent describes a method for detecting caller ID manipulation by comparing the calling party information presented in a call request (e.g., the Caller ID) against authenticated calling party information stored by the telecommunications service provider (e.g., the true billing number associated with the line). A discrepancy between the presented information and the stored, authenticated information is used to identify potential spoofing (’913 Patent, Abstract).
- Asserted Claims: The complaint does not identify specific claims of the ’913 Patent alleged to be infringed (Compl. ¶30).
- Accused Features: The complaint indicates that Defendant has generally accused the Orchestra One™ Call Authentication Service of infringement (Compl. ¶4).
U.S. Patent No. 9,762,728 - Using Calling Party Number for Caller Authentication
- Patent Identification: U.S. Patent No. 9,762,728, Using Calling Party Number for Caller Authentication, issued September 12, 2017.
- Technology Synopsis: This patent discloses a system for authenticating a caller by using the calling party number itself as a credential, obviating the need for the caller to provide personally identifiable information. The system retrieves parameters associated with the number, such as the number of financial accounts linked to it and any associated fraud history, to determine whether the call should be authenticated (’728 Patent, Abstract).
- Asserted Claims: The complaint does not identify specific claims of the ’728 Patent alleged to be infringed (Compl. ¶30).
- Accused Features: The complaint indicates that Defendant has generally accused the Orchestra One™ Call Authentication Service of infringement (Compl. ¶4).
III. The Accused Instrumentality
Product Identification
- SecureLogix's Orchestra One™ Call Authentication Service (the "Accused Product") (Compl. ¶4).
Functionality and Market Context
- The Accused Product is described as a service providing "inbound call authentication for contact centers and other businesses" (Compl. ¶14).
- Based on the infringement letter incorporated into the complaint, the service operates by receiving an incoming call, "assigning a risk score," screening for threats based on that score, and "orchestrating authentication of good calls and bad calls, before answering" (Compl. Ex. A, p. 13).
- The letter further characterizes the Accused Product, allegedly based on SecureLogix’s own patent, as a "cloud-resident service that is queried in real time for each call... to return a score for each call, from 0 (spoofed/malicious) to 100 (clearly authentic)" (Compl. Ex. A, p. 13).
- The complaint alleges that Plaintiff SecureLogix and Defendant TransUnion's subsidiary (TRUSTID) are direct competitors in the call trust and voice network security marketplace (Compl. ¶16).
- No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint does not provide sufficient detail to analyze infringement allegations for the ’532, ’913, or ’728 patents, as no specific asserted claims are identified. The following analysis is based on claim 13 of the ’985 Patent, which is quoted in the infringement letter attached as Exhibit A to the complaint.
’985 Patent Infringement Allegations
| Claim Element (from Independent Claim 13) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A method for authenticating a calling party, comprising: receiving an incoming call from a telephonic device at a call center telephonic device; | The Accused Product is a "call authentication service for contact centers" that operates on inbound calls. | Ex. A, p. 13 | col. 15:3-6 |
| receiving a calling party number or billing number associated with the received incoming call by the call center telephonic device; | The service operates on the calling party number to generate a risk score. | Ex. A, p. 13 | col. 15:7-10 |
| prior to answering the incoming call, requesting by the call center telephonic device a source origin confidence metric... for the calling party number... | The Accused Product provides "automated scoring of the identity and trust level of every single inbound call" and performs this "before answering." | Ex. A, p. 13 | col. 15:11-16 |
| where the confidence metric is determined based on an operational status of the calling party number or billing number; | The Accused Product's "risk score" is allegedly based on analysis of SIP data, real-time carrier network information, and voice analysis. | Ex. A, p. 13 | col. 15:19-21 |
| receiving by the call center telephonic device the confidence metric for the calling party number or billing number; | The Accused Product returns a score for each call. | Ex. A, p. 13 | col. 15:22-25 |
| and answering the incoming call following receipt of the source origin confidence metric. | The Accused Product's authentication process is completed "before answering." | Ex. A, p. 13 | col. 15:26-28 |
- Identified Points of Contention:
- Legal/Procedural Question: A threshold issue is the enforceability of claim 13 of the ’985 Patent. The complaint alleges this claim was among a group of claims canceled by the USPTO in an IPR proceeding, a finding affirmed by the Federal Circuit (Compl. ¶21-22; Ex. B). The primary legal question, therefore, is whether TransUnion has asserted a known invalid patent claim, which forms the basis of SecureLogix's patent misuse allegation.
- Scope Question: Assuming the claim were enforceable, a potential dispute could arise over the meaning of "operational status." The infringement analysis may turn on whether the methods used by the Accused Product to generate a "risk score" (e.g., SIP analysis, network information analysis) fall within the scope of determining a metric "based on an operational status" as that term is defined and used within the ’985 Patent's specification.
V. Key Claim Terms for Construction
The following analysis is based on independent claim 13 of the ’985 Patent.
The Term: "source origin confidence metric"
- Context and Importance: This term defines the output of the claimed method. Its construction will be critical to determining what type of analysis and result meets this limitation. The infringement letter equates this term to a "risk score" (Compl. Ex. A, p. 13). Practitioners may focus on whether the "score" generated by the Accused Product is equivalent to the claimed "metric."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states that the metric "is produced using statistical methods" and can be a "singular determination such as 'valid' or 'invalid' or as a tiered system such as 'red,' 'yellow,' 'green'" (’985 Patent, col. 11:7-15). This could support an argument that any form of probabilistic score or classification qualifies.
- Evidence for a Narrower Interpretation: An argument for a narrower construction might contend that the term must be tied to the specific multi-step process shown in Figure 1, which includes distinct steps for carrier discovery, line type determination, geo-location, and network probing (’985 Patent, Fig. 1).
The Term: "operational status"
- Context and Importance: This term defines the required input for generating the confidence metric. The infringement dispute may hinge on whether the data analyzed by the Accused Product constitutes "operational status."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes using "network conditions, and network condition call progress message patterns" to understand the origins of a call, which suggests a broad interpretation related to any data reflecting the call's real-time state in the network (’985 Patent, col. 4:42-46).
- Evidence for a Narrower Interpretation: The detailed description of the "Network Condition" step emphasizes placing "one or more outbound calls to the telephone number" to detect line conditions like "busy, ring then answer, call forward then answer, and ringing no answer" (’985 Patent, col. 7:36-54). This could support a narrower definition requiring active probing of the line rather than just passive analysis of call data.
VI. Other Allegations
- Indirect Infringement: The complaint seeks a declaratory judgment that SecureLogix does not infringe "either directly or indirectly," but provides no specific facts for analysis of inducement or contributory infringement theories (Compl. ¶30).
- Willful Infringement: The complaint does not make allegations related to willfulness. However, the September 23, 2025 "Claim of Infringement" letter serves as pre-suit notice of the asserted patents, a fact that could be used by TransUnion to support a claim for willful infringement from that date forward (Compl. ¶4).
- Patent Misuse: The complaint includes a specific claim for "Declaratory Judgment of Unenforceability of the ’985 Patent" based on patent misuse (Compl. ¶31). The allegation is that TransUnion knowingly asserted claim 13 of the ’985 Patent, despite that claim having been previously canceled in an IPR proceeding, in an improper attempt to "restrain SecureLogix and others from lawfully competing in the marketplace" (Compl. ¶34-35).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of enforceability and misuse: did TransUnion commit patent misuse by asserting claim 13 of the ’985 Patent, which the complaint and its exhibits suggest was previously canceled by the USPTO? The resolution of this question could determine the enforceability of the entire ’985 Patent and may influence the trajectory of the broader dispute.
- A key technical question will be one of operational equivalence: assuming any asserted claims are valid and enforceable, does the Accused Product's method of generating a "risk score"—allegedly based on SIP, network, and voice analysis—constitute a determination "based on an operational status of the calling party number" as required by the patent claims and described in the specification?