Secure Matrix LLC v. San Antonio Shoe Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Secure Matrix LLC (DE)
  • Defendant: San Antonio Shoe, Inc. (TX)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: Secure Matrix LLC v. San Antonio Shoe, Inc., 7:25-cv-00121, W.D. Tex., 03/12/2025
• Venue Allegations: Venue is alleged to be proper in the Western District of Texas because the Defendant has an established place of business in the District and has committed alleged acts of patent infringement there.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to systems and methods for user authentication and verification.
• Technical Context: The technology concerns secure user authentication, particularly methods that use a mobile device to interact with a separate computer system to verify a user's identity for accessing a secured resource or completing a transaction.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review (IPR) proceedings, or specific licensing history related to the patent-in-suit. The allegations of willfulness are based on knowledge obtained from the filing of the present lawsuit.

Case Timeline

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

U.S. Patent No. 8,677,116 - "Systems and methods for authentication and verification"

• Patent Identification: 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" who are attempting to access secured resources, such as internet portals or real-world devices, as well as a need for "a secure and fast online electronic payment capability" ('116 Patent, col. 1:19-29).
• The Patented Solution: The invention is a method for authentication involving multiple devices and signals. A computer providing a "secured capability" (e.g., a website login page) sends a first signal containing a "reusable identifier" (e.g., a QR code). A user's separate electronic device (e.g., a smartphone) receives a second signal containing a copy of that identifier plus user verification information. A processor then evaluates both signals to determine if the user is authorized and, if so, transmits an authorization signal back to the computer and/or the user's device ('116 Patent, Abstract; col. 1:30-49). This architecture is depicted in Figure 2 of the patent, showing a "User browser," "Mobile device," "Web Server," and "Verification Server" interacting.
• Technical Importance: The technology aims to provide a more secure and streamlined authentication process than traditional username/password systems by leveraging the ubiquity of personal mobile devices as a second factor of authentication ('116 Patent, col. 33:1-9).

Key Claims at a Glance

The complaint does not specify which claims are asserted, referring only to the "Exemplary '116 Patent Claims" in an unprovided exhibit (Compl. ¶11). Independent Claim 1, a method claim, is representative of the core invention.

• Independent Claim 1:
  • A method of using a computer system to authenticate a user seeking to conduct at least one interaction with a secured capability provided by a computer.
  • using the computer system to receive a first signal from the computer providing the secured capability, the first signal comprising a reusable identifier corresponding to the secured capability, the reusable identifier assigned for use by the secured capability 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 signal and the second signal, whether the user is authorized to conduct the at least one interaction with the secured capability.
  • in response to an indication from the processor that the user is authorized... using the computer system to transmit a third signal comprising authorization information to at least one of the electronic device and the computer.

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products or services by name (Compl. ¶11). It refers generally to "Exemplary Defendant Products" that are purportedly detailed in an unprovided claim chart exhibit (Compl. ¶16).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality. The defendant is San Antonio Shoe, Inc., a footwear company, which suggests the accused instrumentalities could relate to e-commerce websites, mobile applications for online shopping, or customer loyalty programs that require user authentication (Compl. ¶3).

IV. Analysis of Infringement Allegations

The complaint alleges direct and indirect infringement but incorporates its substantive infringement theories by reference to an unprovided document, "Exhibit 2" (Compl. ¶¶11, 15-17). The complaint asserts in a conclusory manner that the "Exemplary Defendant Products practice the technology claimed by the '116 Patent" (Compl. ¶16). Without the referenced exhibit, a detailed element-by-element analysis is not possible based on the provided documents.

No probative visual evidence provided in complaint.

Identified Points of Contention

Based on the patent and the nature of the defendant, the central infringement questions will likely involve mapping the elements of the claims to the defendant's systems.

Scope Questions

A primary question will be whether the defendant's e-commerce or customer account system constitutes the multi-component architecture described in the patent. For instance, does the defendant's system employ a distinct "verification server" that receives signals from both a user's browser (the "computer") and a user's "electronic device" as claimed, or does it use a more integrated, two-party architecture? ('116 Patent, Fig. 2).

Technical Questions

A key factual question will be whether the defendant's system transmits a "reusable identifier" that is separate from user- or transaction-specific information, as the patent emphasizes ('116 Patent, col. 6:35-41). The analysis will also question whether the defendant's system generates and processes the distinct "first signal" and "second signal" as required by the claim limitations.

V. Key Claim Terms for Construction

"reusable identifier"

• Context and Importance: This term is central to the patent's purported novelty, distinguishing the invention from systems using "one-time-use" identifiers. Its construction will be critical for determining infringement, as the defendant's system may use session tokens or other identifiers that could be argued to be either "reusable" or "one-time-use" in nature. Practitioners may focus on this term because the patent contrasts it with conventional approaches, suggesting a specific meaning was intended ('116 Patent, col. 9:15-21).
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests the term's key attribute is the lack of "user-specific or transaction-specific information," which allows it to be reused across multiple users and transactions ('116 Patent, col. 9:11-14).
  • Evidence for a Narrower Interpretation: The patent also describes embodiments where the "reusable" identifier is still limited, for example, being "only valid for a finite and predetermined period of time" or used in a "round robin usage" system ('116 Patent, col. 9:40-48). This could support a narrower definition that requires more than simple reusability.

"secured capability"

• Context and Importance: This term defines the scope of the activities to which the patented method applies. Whether the defendant's e-commerce login, "add to cart" function, or checkout process is deemed a "secured capability" will be a key issue.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification provides a broad and varied list of examples, including accessing a "secured internet portal," a "real-world secured device (e.g., lock, door)," and making an "online electronic payment," suggesting the term should be interpreted expansively ('116 Patent, col. 1:20-29).
  • Evidence for a Narrower Interpretation: A defendant might argue that the term should be limited by the context of the patent's problem statement, which focuses on high-security authentication rather than routine website interactions ('116 Patent, col. 1:19-29). The specific examples listed include "opening a lock selectively inhibiting physical access" and "retrieval of information from a secured internet portal" ('116 Patent, col. 3:51-54, col. 3:59-61).

VI. Other Allegations

Indirect Infringement

The complaint alleges induced 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 alleged knowledge of infringement gained from the service of the complaint and the attached claim charts (Compl. ¶¶13, 15). This asserts post-suit knowledge as the basis for ongoing willful infringement.

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

1. Evidentiary Sufficiency: The central threshold issue is factual: what are the "Exemplary Defendant Products," and does the evidence, once produced, demonstrate that they operate in a manner that meets every limitation of the asserted claims? The complaint’s reliance on an unprovided exhibit leaves this entirely open.
2. Architectural Mapping: A key technical question will be one of system equivalence: does the defendant's likely two-party client-server e-commerce architecture map onto the three-party system (e.g., user browser, user mobile device, and a distinct verification server) described and claimed in the '116 Patent?
3. Definitional Scope: The case may turn on a question of claim construction: can the term "reusable identifier", which the patent contrasts with transaction-specific tokens, be construed to read on the session identifiers or cookies likely used in a standard e-commerce platform?