Secure Matrix LLC v. Souper Salad LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Secure Matrix LLC (Delaware)
  • Defendant: Souper Salad, LLC (Texas)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 7:25-cv-00119, 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.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to systems and methods for user authentication and verification, typically involving a multi-device process.
• Technical Context: The technology concerns secure user authentication, for purposes such as logging into websites or authorizing electronic payments, by coordinating between a primary computer and a user's separate electronic device.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or administrative proceedings (e.g., IPRs) related to the patent-in-suit.

Case Timeline

Date	Event
2012-11-21	Earliest Priority Date for U.S. Patent No. 8,677,116
2013-08-09	Application Filing Date for U.S. Patent No. 8,677,116
2014-03-18	Issue Date of U.S. Patent No. 8,677,116
2025-03-12	Complaint Filing Date

II. Technology and Patent(s)-in-Suit Analysis

• Patent Identification: U.S. Patent No. 8,677,116 (Systems and methods for authentication and verification), issued March 18, 2014. (Compl. ¶9).
• The Invention Explained:
  • Problem Addressed: The patent addresses a "growing need to authenticate users" accessing secured online portals or real-world devices, and the corresponding need for a "secure and fast online electronic payment capability." (’116 Patent, col. 1:20-29).
  • The Patented Solution: The invention is a method for authenticating a user that involves three main communications. A central system (e.g., a verification server) receives a first signal from a computer a user is interacting with (e.g., a merchant's website on a PC) containing a "reusable identifier" (such as one encoded in a QR code). (’116 Patent, col. 6:5-23). The system then receives a second signal from the user's personal electronic device (e.g., a smartphone) containing a copy of that same identifier plus "user verification information." (’116 Patent, col. 2:35-39). A processor evaluates this information to determine if the user is authorized and, if so, transmits a third signal containing authorization back to the computer and/or the user's device. (’116 Patent, col. 2:41-49; Fig. 3A).
  • Technical Importance: The system's use of a "reusable identifier" that does not contain user-specific or transaction-specific data is described as an advantage over conventional systems, suggesting it can be simpler, faster, and reduce server computing requirements compared to generating unique identifiers for every transaction. (’116 Patent, col. 6:35-62).
• Key Claims at a Glance:
  • The complaint alleges infringement of "one or more claims" and refers to "Exemplary '116 Patent Claims" in an unprovided exhibit. (Compl. ¶11). Independent claims 1 and 11 appear to cover the core methods and systems.
  • Independent Claim 1 recites a method of using a computer system to authenticate a user, comprising the steps of:
    • Receiving a first signal from a computer providing a secured capability, where the signal comprises a "reusable identifier" assigned for a "finite period of time";
    • Receiving a second signal from a user's electronic device, where the signal comprises a copy of the reusable identifier and "user verification information";
    • Using a processor to evaluate whether the user is authorized based on the first and second signals; and
    • Transmitting a third signal with authorization information in response to a successful evaluation. (’116 Patent, col. 33:18-34:3).
  • The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

• Product Identification: The complaint does not name any specific accused products, methods, or services. It refers generically to "Defendant products identified in the charts" and "Exemplary Defendant Products," referencing an external 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 functionality or market context of any accused instrumentality. It alleges that Defendant makes, uses, sells, and has its employees test the accused products. (Compl. ¶11-12).

IV. Analysis of Infringement Allegations

The complaint provides no factual detail regarding infringement in its main body, instead stating that it "incorporates by reference in its allegations herein the claim charts of Exhibit 2." (Compl. ¶17). As Exhibit 2 was not provided, a detailed analysis of the infringement allegations is not possible. The narrative theory is limited to the conclusory statement that the "Exemplary Defendant Products practice the technology claimed by the '116 Patent." (Compl. ¶16).

No probative visual evidence provided in complaint.

• Identified Points of Contention: Given the lack of specific allegations, any infringement analysis is speculative. However, a dispute would necessarily involve mapping the features of an unspecified Souper Salad product or service (e.g., an online ordering platform, customer loyalty application, or internal login system) to the claim elements.
  • Scope Questions: A central question will be whether the accused instrumentality uses an "identifier" that meets the patent's definition of "reusable," particularly the limitation that it is assigned for a "finite period of time" and, as described in the specification, does not contain user-specific information. (’116 Patent, col. 9:13-16, col. 33:24-25).
  • Technical Questions: A key evidentiary question will be whether the accused system performs the claimed three-part signal exchange: (1) a signal from a first computer to a verification system, (2) a separate signal from a user's device to that same system, and (3) an authorization signal transmitted back. The architecture of the accused system will be a primary focus.

V. Key Claim Terms for Construction

• The Term: "reusable identifier"

• Context and Importance: This term is the technological core of the asserted independent claims and is used to distinguish the invention from prior art that allegedly uses "one-time-use" or "unique" identifiers. (’116 Patent, col. 9:17-21). Its construction will be critical to determining the scope of infringement, as nearly any modern authentication system uses some form of identifier.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The plain meaning of "reusable" could be argued to encompass any identifier that is not destroyed after a single use. The claims themselves do not explicitly require the identifier to lack user-specific information.
  • Evidence for a Narrower Interpretation: The specification repeatedly contrasts the invention with systems using complex, transaction-specific codes and states the reusable identifier "does not contain user-specific or transaction-specific information." (’116 Patent, col. 9:13-16). Defendants may argue that this description limits the term to simple, generic tokens used in a round-robin fashion, as described in the embodiments. (’116 Patent, col. 9:43-46).

• The Term: "user verification information"

• Context and Importance: This term defines the data that must be sent from the user's personal device in the second signal to the verification server. Whether the accused product transmits information meeting this definition will be a key infringement question.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The term itself could be broadly construed to mean any information that helps verify a user, such as a username/password combination or a session cookie.
  • Evidence for a Narrower Interpretation: The specification provides a specific list of what this term can comprise, including information "specific to) the user (e.g., the user's first name, family name, email address, phone number)" or information "specific to) the first electronic device 20 (e.g., a device identification character string, hardware-specific information...)." (’116 Patent, col. 12:5-14). A party could argue the term should be limited to these disclosed categories.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement. The factual basis is 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). The specific content of these materials is purportedly detailed in the unprovided Exhibit 2. (Compl. ¶14).
• Willful Infringement: The complaint does not use the term "willful." It alleges "Actual Knowledge of Infringement" based on the service of the complaint itself. (Compl. ¶13). This allegation, if proven, could only support a claim for enhanced damages for post-suit conduct, as no facts supporting pre-suit knowledge are alleged.

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

1. Evidentiary Sufficiency: The central and most immediate issue is the complaint's lack of factual specificity. A primary question is whether the plaintiff can substantiate its bare-bones allegations with concrete evidence detailing how an accused Souper Salad product actually operates and maps onto the patent claims, a burden that may be tested early in the litigation.
2. Definitional Scope: The case will likely turn on the construction of the term "reusable identifier". The key question for the court will be whether this term is limited to the specification's specific embodiment of a simple, non-user-specific token, or if it can be read more broadly to cover other types of persistent identifiers used in modern authentication systems.
3. Architectural Mismatch: A core technical question will be one of functional operation. The litigation will likely focus on whether the accused system's architecture truly mirrors the three-party communication structure required by the claims—involving a first computer, a separate user device, and a distinct verification server—or if there is a fundamental mismatch in how the systems are designed and communicate.