Secure Matrix LLC v. Santikos Real Estate Services LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Secure Matrix LLC (DE)
  • Defendant: Santikos Real Estate Services, LLC (TX)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 7:25-cv-00120, W.D. Tex., 03/12/2025
• Venue Allegations: Venue is alleged to be proper in the Western District of Texas because the Defendant maintains an established place of business in the District and has allegedly committed acts of patent infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified products and services infringe a patent related to multi-device systems for user authentication and verification.
• Technical Context: The technology at issue addresses secure user authentication, a critical component of e-commerce, online account access, and digital payments.
• Key Procedural History: The complaint does not allege any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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 identifies a "growing need to authenticate users" for accessing secured internet portals, real-world devices like locks, and for conducting secure online electronic payment transactions (Compl. ¶9; ’116 Patent, col. 2:19-29).
• The Patented Solution: The invention describes a multi-component authentication system. A user seeking access via a primary device (e.g., a computer) is presented with a "reusable identifier," such as a QR code. The user then employs a second, personal electronic device (e.g., a smartphone) to capture this identifier, combine it with "user verification information," and send the combined data to a remote verification server. This server evaluates the request and, if approved, transmits authorization back to the primary device and/or the user's personal device to grant access ('116 Patent, Abstract; Fig. 2).
• Technical Importance: The use of a "reusable identifier" that does not contain sensitive user or transaction data is presented as an advantage, potentially simplifying the system, making visual codes easier for mobile devices to read, and reducing server-side computational load compared to systems that must generate a unique, complex identifier for each transaction ('116 Patent, col. 6:35-58).

Key Claims at a Glance

• The complaint asserts infringement of at least one independent claim. Claim 1 is representative:
  • Using a computer system to receive a first signal from a computer providing a secured capability, where the signal comprises a "reusable identifier" assigned for a "finite period of time".
  • Using the computer system to receive 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.
  • Transmitting a third signal with "authorization information" to the user's device and/or the initial computer in response to a successful evaluation.
• The complaint reserves the right to assert other claims, including dependent claims (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as the "Exemplary Defendant Products" (Compl. ¶11).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's specific functionality or market context. It states that the products are identified in claim charts attached as Exhibit 2, but this exhibit was not included with the filed complaint (Compl. ¶11, ¶16-17).

IV. Analysis of Infringement Allegations

The complaint alleges that the "Exemplary Defendant Products" directly infringe the ’116 Patent but provides no specific factual allegations in the body of the complaint to support this (Compl. ¶11). Instead, it incorporates by reference the analysis from claim charts in an external "Exhibit 2," which was not provided with the docketed materials (Compl. ¶16-17).

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Evidentiary Question: The primary issue for the court will be evidentiary. Lacking specific allegations or the referenced Exhibit 2, it is unclear what specific products are accused or what evidence Plaintiff will offer to show that these products perform each step of the claimed methods.
  • Technical Question: A fundamental question will be whether the accused products, once identified, actually implement the specific architecture of the ’116 Patent. For example, do they utilize a "reusable identifier" that is distinct from "user verification information" and transmitted in separate but correlated signals, or do they use a more conventional, integrated authentication method?

V. Key Claim Terms for Construction

"reusable identifier"

• Context and Importance: This term is the central inventive concept. Its construction will determine whether the patent's scope is limited to the specific type of "dumb" identifier described in the embodiments (e.g., a non-unique QR code) or if it can cover a wider range of modern authentication tokens. Practitioners may focus on this term because the distinction between "reusable" and "one-time-use" is a critical feature of the patented system.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent 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. 9:8-12). This language could support an interpretation covering any persistent token used to initiate authentication for multiple users or sessions.
  • Evidence for a Narrower Interpretation: The specification repeatedly states the identifier "does not contain user-specific or interaction-specific information" ('116 Patent, col. 9:12-14). An accused infringer may argue that this limits the term to simple, static identifiers that carry no specific data, distinguishing it from more complex tokens that might be considered "reusable" in other contexts.

"user verification information"

• Context and Importance: The definition of this term, and its required separation from the "reusable identifier", is key to the claimed process. The infringement analysis depends on whether an accused system maintains this separation.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent provides a broad list of what this could be, including user-specific data (name, email) and device-specific data (hardware ID string), suggesting it covers any information that links an authentication attempt to a specific user or their device ('116 Patent, col. 12:8-15).
  • Evidence for a Narrower Interpretation: Claim 1 requires receiving the "reusable identifier" in a "first signal" and the "user verification information" in a "second signal." A party could argue that this claim structure requires distinct transmissions and that systems where user or device data is intrinsically bundled with the initial identifier do not meet this limitation.

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 the accused products in a manner that allegedly infringes the ’116 Patent (Compl. ¶14-15).
• Willful Infringement: The complaint bases its allegation of "Actual Knowledge" on the service of the complaint itself, which may support a claim for post-suit willful infringement. No facts are alleged to support pre-suit knowledge of the patent or the alleged infringement (Compl. ¶13-14).

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

• A primary threshold question is one of evidentiary sufficiency: given the complaint's reliance on an unprovided external exhibit, what specific products are being accused of infringement, and what factual support will Plaintiff offer to demonstrate that these products practice each element of the asserted claims?
• A central legal issue will be one of definitional scope: can the term "reusable identifier", as described in the patent as being devoid of user-specific information, be construed to cover the authentication mechanism used in Defendant's products, or is there a fundamental mismatch in technical operation?