Secure Matrix LLC v. Taco Cabana Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Secure Matrix LLC (DE)
  • Defendant: Taco Cabana, Inc. (DE)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 7:25-cv-00117, W.D. Tex., 03/12/2025
• Venue Allegations: Venue is alleged to be proper because the Defendant maintains an established place of business in the Western District of Texas and has allegedly committed acts of infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to systems and methods for user authentication and verification.
• Technical Context: The technology concerns multi-device security protocols for authenticating a user, often for online logins or electronic payments, by using a separate personal device to verify an access attempt.
• Key Procedural History: The complaint does not reference any prior litigation, licensing history, or post-grant proceedings involving the patent-in-suit.

Case Timeline

Date	Event
2012-11-21	'116 Patent Priority Date
2013-08-09	'116 Patent Application Filing Date
2014-03-18	'116 Patent Issue Date
2025-03-12	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 for improved methods to authenticate users who are trying to access secured digital resources, such as a website, or to complete secure online transactions ('116 Patent, col. 1:20-29).
• The Patented Solution: The invention proposes a multi-component system to solve this problem. A user attempting to access a service on a first device (e.g., a computer) is presented with a "reusable identifier," often as a visual like a QR code ('116 Patent, Fig. 2). The user then uses a second, personal device (e.g., a smartphone) to scan or receive this identifier and send it, along with separate user verification information, to a verification server ('116 Patent, col. 6:20-24, col. 6:27-33). The verification server evaluates whether the user is authorized and, if so, transmits an authorization signal to grant access ('116 Patent, col. 6:30-33).
• 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, intended to simplify the process, reduce server processing loads, and enhance security by not exposing sensitive data in the initial authentication step ('116 Patent, col. 6:35-62).

Key Claims at a Glance

• The complaint asserts infringement of one or more claims without specifying them ('116 Patent, Compl. ¶11). Claim 1 is the first independent method claim.
• Essential elements of Independent Claim 1 include:
  • using a computer system to receive a first signal from a computer providing a secured capability, the first signal comprising a "reusable identifier"... assigned for use... 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 second signal comprising a "copy of the reusable identifier" and user verification information;
  • using a processor of the computer system to evaluate, based at least on the first and second signals, whether the user is authorized; and
  • in response to an authorization, transmitting a third signal comprising authorization information.

III. The Accused Instrumentality

Product Identification

The complaint does not name specific accused products. It refers generally to "Defendant products identified in the charts incorporated into this Count" and "Exemplary Defendant Products" detailed in a referenced Exhibit 2, which 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. The allegations suggest the accused products are systems made, used, or sold by Defendant that perform user authentication (Compl. ¶11). Given Defendant's business as a restaurant chain, this could refer to a customer login portal on its website, a mobile ordering application, or a loyalty rewards program. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint incorporates infringement allegations by reference to claim charts in Exhibit 2, which is not available for analysis (Compl. ¶¶16-17). The complaint's narrative theory alleges that the "Exemplary Defendant Products practice the technology claimed by the '116 Patent" and "satisfy all elements of the Exemplary '116 Patent Claims" (Compl. ¶16). Without the charts, the specific factual basis for how each claim element is met by the accused products is not articulated in the complaint itself.

• Identified Points of Contention:
  • Architectural Questions: A primary question will be whether the accused systems employ the multi-device, three-party architecture (service computer, user's electronic device, verification server) described and claimed in the '116 Patent. The complaint provides no facts to suggest such an architecture is used by Defendant.
  • Technical Questions: The infringement analysis may turn on whether the accused systems use a "reusable identifier" as contemplated by the patent. What evidence does the complaint provide that Defendant's authentication protocol uses an identifier that is reusable across different users and transactions, as opposed to conventional user-specific credentials (e.g., username/password) or session-specific tokens?

V. Key Claim Terms for Construction

The Term: "reusable identifier"

• Context and Importance: This term is the technological core of the asserted claims. Its construction will be critical to determining infringement. The patent contrasts this term with "one-time-use" or "unique" identifiers from conventional systems ('116 Patent, col. 9:16-22) and specifies that it "does not contain user-specific or transaction-specific information" ('116 Patent, col. 9:13-15). Practitioners may focus on this term because if Defendant’s system uses standard login credentials or single-use session tokens, it may not infringe.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself simply requires the identifier to be "reusable" and assigned for a "finite period of time" (e.g., '116 Patent, col. 33:24-25), which could arguably read on any credential that is not strictly single-use.
  • Evidence for a Narrower Interpretation: The specification repeatedly characterizes the identifier as lacking user or transaction-specific data ('116 Patent, col. 6:36-39) and describes embodiments where a list of such identifiers is used sequentially in a "round robin" fashion ('116 Patent, col. 9:38-44). This may support a narrower construction that excludes typical username/password systems.

The Term: "a copy of the reusable identifier"

• Context and Importance: This term appears in the claim element describing the second signal, sent from the user's electronic device ('116 Patent, col. 33:28-29). It implies that the identifier is first obtained from one source and then copied and re-transmitted from a second, distinct source. This is central to the claimed multi-device interaction (e.g., scanning a QR code from a PC screen with a phone).
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party might argue this simply means the same identifier data is present in the second signal, regardless of the mechanism.
  • Evidence for a Narrower Interpretation: The figures and detailed description consistently depict a process where a visual identifier is presented by one device and optically scanned by another, creating the "copy" for transmission ('116 Patent, Fig. 2; col. 6:20-24). This could support a narrow construction requiring a two-device transfer mechanism.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendant distributes "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes the '116 Patent" (Compl. ¶14).
• Willful Infringement: The willfulness allegation is based on post-suit knowledge. The complaint asserts that its service "constitutes actual knowledge of infringement" and that Defendant's continued alleged infringement after this date is willful (Compl. ¶¶13-14).

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

• A core issue will be one of definitional scope: can the term "reusable identifier", which the patent specification describes as lacking user-specific information, be construed to cover the authentication credentials or tokens used in Defendant’s customer-facing website or mobile application?
• A key evidentiary question will be one of architectural correspondence: does discovery reveal that Defendant’s accused system operates using the specific multi-device, multi-signal architecture required by the patent's claims, or is there a fundamental mismatch in technical operation that the vague allegations in the complaint do not address?