DCT

7:25-cv-00118

Secure Matrix LLC v. Southwest Airlines Co

I. Executive Summary and Procedural Information

Parties & Counsel:
- Plaintiff: Secure Matrix LLC (DE)
- Defendant: Southwest Airlines Co. (TX)
- Plaintiff’s Counsel: Rabicoff Law LLC
Case Identification: 7:25-cv-00118, W.D. Tex., 03/12/2025
Venue Allegations: Venue is alleged to be proper based on Defendant maintaining an established place of business within the Western District of Texas and committing alleged acts of infringement in the district.
Core Dispute: Plaintiff alleges that unspecified systems used and/or offered by Defendant infringe a patent related to methods for user authentication that leverage a user's mobile device.
Technical Context: The technology relates to multi-factor authentication systems, a critical component of modern cybersecurity for securing access to online accounts and services.
Key Procedural History: The complaint does not mention any prior litigation, licensing history, or other significant procedural events related to the patent-in-suit.

Case Timeline

Date	Event
2012-11-21	'116 Patent Priority Date
2014-03-18	'116 Patent Issue Date
2025-03-12	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," issued March 18, 2014

The Invention Explained

Problem Addressed: The patent describes a "growing need to authenticate users" for both online portals and real-world devices, as well as a need for a "secure and fast online electronic payment capability" ('116 Patent, col. 1:20-27).
The Patented Solution: The invention is a multi-component authentication system. A computer providing a secured service (e.g., a website) sends a "reusable identifier" to both a central verification server and the user's display (e.g., as a QR code). The user employs an electronic device (e.g., a smartphone) to capture this identifier, combines it with their own verification information, and transmits this package to the verification server. The server then evaluates the information to grant or deny access ('116 Patent, Abstract; Fig. 2).
Technical Importance: The system's use of a "reusable identifier" is positioned as an advantage over systems that generate unique, one-time-use codes for every transaction, purportedly simplifying the process and reducing server computing requirements ('116 Patent, col. 6:34-59).

Key Claims at a Glance

The complaint does not specify which claims it asserts, referring generally to "one or more claims" and "the Exemplary '116 Patent Claims" (Compl. ¶11). Independent claim 1 is representative of the patented method.
Independent Claim 1 (Method):
- Using a computer system to receive a first signal from a computer providing a secured capability, where the signal contains a "reusable identifier" that is assigned for use for a "finite period of time";
- Using the system to receive a second signal from a user's electronic device, where this signal contains a copy of the reusable identifier and "user verification information";
- Using a processor to evaluate the signals to determine if the user is authorized; and
- Transmitting a third signal with authorization information to the user's device or the service-providing computer in response to a successful evaluation.
The complaint reserves the right to assert additional claims, including dependent claims (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not specifically name any accused product, method, or service. It refers to "Exemplary Defendant Products" that are purportedly identified in an "Exhibit 2" to the complaint (Compl. ¶¶ 11, 16). This exhibit was not filed with the complaint document.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality. It alleges generally that Defendant makes, uses, sells, and offers for sale infringing devices, and that its employees internally test and use these products (Compl. ¶¶ 11-12). This suggests the accused instrumentalities could include internal and/or customer-facing authentication systems, such as a customer login portal.

IV. Analysis of Infringement Allegations

The complaint incorporates by reference claim charts from an unfiled "Exhibit 2" and does not provide a narrative description of infringement in the body of the complaint (Compl. ¶¶ 16-17). As the exhibit containing the infringement allegations is not available, a detailed analysis or claim chart summary cannot be constructed. The complaint's infringement theory rests entirely on the contents of this missing document.

No probative visual evidence provided in complaint.

Identified Points of Contention:
- Technical Questions: A threshold issue will be identifying the specific Southwest Airlines system(s) at issue. Once identified, a key factual question will be whether those systems actually operate as claimed. Specifically, what evidence will show that the accused systems (1) generate a "reusable identifier" that is sent from a service computer to a user's display, (2) process a copy of that same identifier received from a user's separate electronic device, and (3) perform the authorization based on these coordinated signals?
- Scope Questions: The dispute may center on whether the accused system's authentication token qualifies as a "reusable identifier" that is "assigned for use... for a finite period of time" as required by the claim. The definition of this term relative to modern, session-based tokens will likely be a significant point of contention.

V. Key Claim Terms for Construction

The Term: "reusable identifier"
- Context and Importance: This term is central to the patent's asserted point of novelty. The infringement analysis will depend heavily on whether the token, code, or other identifier used in Defendant's system falls within the scope of this term.
- Intrinsic Evidence for Interpretation:
  - Evidence for a Broader Interpretation: The specification defines "reusable" as an identifier "that can be used more than once" and is "not unique to one particular user or transaction" ('116 Patent, col. 9:7-12). This language could support a broad reading covering any identifier that is not strictly a single-use token.
  - Evidence for a Narrower Interpretation: The patent also describes the identifier in the context of a "round robin usage" from a "predefined and previously generated list" ('116 Patent, col. 9:22-41). This could support a narrower construction requiring the identifier to be one of a pool of static, pre-generated codes, potentially excluding dynamically generated session tokens.
The Term: "assigned for use by the secured capability for a finite period of time"
- Context and Importance: This limitation qualifies the "reusable identifier," and its construction will be critical for determining the boundaries of the claim. The nature of the "assignment" and the "finite period" will be debated.
- Intrinsic Evidence for Interpretation:
  - Evidence for a Broader Interpretation: The specification gives examples of finite periods, including "one or more minutes, one or more hours, one or more days," suggesting flexibility ('116 Patent, col. 9:42-44). This could be argued to cover any identifier with a defined, non-infinite lifespan, such as a session token that expires upon logout.
  - Evidence for a Narrower Interpretation: This phrase, read in conjunction with the "round robin" embodiment, could be argued to require a predetermined, fixed lifecycle for the identifier that is independent of a specific user's session, which a party could argue is functionally different from a token that is created at the start of a session and destroyed at its end.

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 its products in a manner that allegedly infringes the '116 Patent (Compl. ¶14).
Willful Infringement: The complaint alleges that Defendant gained "actual knowledge" of its infringement upon service of the complaint and the (unattached) claim charts, and that it "continues to make, use, test, sell, [and] offer for sale" the accused products despite this knowledge (Compl. ¶¶ 13-14). The prayer for relief requests enhanced damages pursuant to 35 U.S.C. § 284 (Compl. Prayer ¶ D).

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

A primary issue will be evidentiary and factual: Given the complaint's reliance on an unfiled exhibit, the initial phase of the case will focus on discovering which specific Southwest Airlines authentication systems are accused and establishing the technical facts of how those systems actually operate.
A central legal question will be one of claim construction: Can the term "reusable identifier," which the patent describes in the context of a "round robin" queue of pre-generated codes, be construed to cover the potentially more dynamic, session-based authentication tokens common in modern web security? The outcome of this definitional dispute will likely be dispositive for infringement.