Secure Matrix LLC v. ROKA Sports Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Secure Matrix LLC (DE)
  • Defendant: ROKA Sports, Inc. (DE)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 7:25-cv-00122, W.D. Tex., 03/12/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because 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 infringes a patent related to systems and methods for user authentication and verification, particularly those utilizing a mobile device to interact with a separate computer system.
• Technical Context: The technology at issue addresses secure user authentication for online services and electronic payments, a critical component of e-commerce and secure data access.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit. The patent claims priority from two provisional applications filed in 2012 and 2013.

Case Timeline

Date	Event
2012-11-21	'116 Patent Priority Date (Prov. App. 61/729,266)
2014-03-18	'116 Patent Issued
2025-03-12	Complaint Filed

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 identifies a "growing need to authenticate users" for accessing secured internet portals or real-world devices, as well as a need for "a secure and fast online electronic payment capability" as e-commerce transactions increase ('116 Patent, col. 1:20-29).
• The Patented Solution: The invention describes a multi-party authentication method involving a user's electronic device (e.g., a smartphone), a computer providing a secured capability (e.g., a web server), and a separate verification server ('116 Patent, Fig. 2). The computer provides a "reusable identifier" (e.g., a QR code); the user's device captures this identifier and sends it along with "user verification information" to the verification server. The server then evaluates this data and, if authorized, transmits an authorization signal to the computer and/or the user's device to grant access ('116 Patent, col. 1:30-49, col. 6:3-33).
• Technical Importance: The use of a "reusable identifier" that does not contain user-specific or transaction-specific information is described as an advantage, simplifying the process and making the identifier safer to use without complex encryption ('116 Patent, col. 6:34-62).

Key Claims at a Glance

• The complaint asserts "one or more claims" of the '116 Patent without specifying them (Compl. ¶11). Independent claim 1 is representative of the core method.
• Independent Claim 1 requires:
  • using a computer system to receive a first signal from a computer providing a secured capability, the signal comprising 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, the signal comprising a copy of the reusable identifier and "user verification information";
  • using a processor to evaluate, based on the first and second signals, whether the user is authorized; and
  • transmitting a third signal with authorization information to the electronic device and/or the computer in response to a successful evaluation.

III. The Accused Instrumentality

Product Identification

The complaint does not specifically name the accused products or services. It refers to them as the "Exemplary Defendant Products" identified in charts that are incorporated by reference as Exhibit 2 (Compl. ¶11, 16). This exhibit was not provided with the filed complaint.

Functionality and Market Context

The complaint alleges that the unspecified "Exemplary Defendant Products" practice the technology claimed by the '116 Patent and that they have been made, used, sold, imported, and offered for sale by the Defendant (Compl. ¶11, 16). The complaint does not provide sufficient detail for analysis of the accused instrumentality's specific functionality or market context.

IV. Analysis of Infringement Allegations

The complaint alleges direct infringement by stating that Defendant's products "practice the technology claimed by the '116 Patent" and "satisfy all elements of the Exemplary '116 Patent Claims" (Compl. ¶16). It incorporates by reference "charts comparing the Exemplary '116 Patent Claims to the Exemplary Defendant Products" contained in an external Exhibit 2, which was not provided with the complaint (Compl. ¶16-17). Without this exhibit, a detailed claim chart analysis is not possible based on the complaint's text alone.

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Evidentiary Questions: A primary issue will be establishing the specific functionality of the accused products. The court will need to assess the evidence, presumably contained in the referenced Exhibit 2, that demonstrates how Defendant's products perform each step of the asserted claims.
  • Scope Questions: The analysis will likely focus on whether the operations of the accused products fall within the scope of the patent's claims. For instance, questions may arise as to what constitutes a "reusable identifier" and "user verification information" in the context of the accused products' authentication flow.

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for analysis of specific claim construction disputes. However, based on the technology and the language of representative independent claim 1, certain terms are likely to be central.

• The Term: "reusable identifier"
• Context and Importance: This term is the core of the invention's purported novelty. Its construction will determine whether the identifier used in the accused system—which must be used "more than once" and not be "unique to one particular user or transaction" ('116 Patent, col. 9:6-11)—meets the claim limitation. Practitioners may focus on this term because the patent contrasts it with "one-time-use" identifiers from conventional systems.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests the term is not limited to a specific format, encompassing "an encoded visual or auditory identifier" such as a QR code, static images, sounds, or radio signals ('116 Patent, col. 9:11-14, 10:34-51).
  • Evidence for a Narrower Interpretation: The definition emphasizes that the identifier "does not contain user-specific or interaction-specific information" ('116 Patent, col. 9:11-13). An accused system where the initial identifier contains any user or session data could be argued to fall outside this narrower construction. The requirement that it is "assigned for use by the secured capability for a finite period of time" could also support a narrower reading ('116 Patent, col. 33:24-25).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that direct and instruct end users to use the accused products in a manner that infringes the '116 Patent (Compl. ¶14-15).
• Willful Infringement: The complaint alleges that Defendant has actual knowledge of its infringement from the service of the complaint itself (Compl. ¶13). The willfulness claim is therefore based on alleged post-suit continuation of infringing activities (Compl. ¶14).

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

1. An Evidentiary Question of Operation: The central issue at the outset is factual: what are the "Exemplary Defendant Products," and does the evidence (currently absent from the public record) demonstrate that they perform a three-party authentication process involving the specific signal exchanges required by the asserted claims?
2. A Definitional Question of Scope: The case will likely turn on the construction of the term "reusable identifier". A key question for the court will be whether the identifier used in Defendant's system functions as a non-unique, transaction-agnostic token as described in the patent, or if it contains session- or user-specific data that places it outside the claim scope.
3. A Question of Knowledge and Intent: For the claims of indirect and willful infringement, the focus will be on the sufficiency of the allegations regarding Defendant's knowledge. Specifically, whether distributing "product literature and website materials" is sufficient to show an intent to induce infringement, and whether post-suit conduct rises to the level of willfulness.