Secure Matrix LLC v. Alphalete Athletics Ltd Liability Co

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Secure Matrix LLC (Delaware)
  • Defendant: Alphalete Athletics Limited Liability Company (Texas)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 7:25-cv-00135, W.D. Tex., 03/21/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because the Defendant has 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.
• Technical Context: The technology at issue addresses secure multi-factor authentication, typically where a user's mobile device is used to authorize an interaction, such as a login or payment, initiated on a separate computer.
• Key Procedural History: The complaint states that Plaintiff is the assignee of the patent-in-suit. No prior litigation, administrative proceedings, or licensing activities are mentioned in the complaint.

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 (’116 Patent).

The Invention Explained

• Problem Addressed: The patent describes a "growing need to authenticate users" for secure online portals and transactions, noting the need for both security and speed in online electronic payments (’116 Patent, col. 1:19-29).
• The Patented Solution: The invention is a multi-part authentication method. A central verification server receives a first signal from a computer attempting to access a secured resource (e.g., a website) and a second signal from a user’s separate electronic device (e.g., a smartphone). The first signal contains a "reusable identifier" (like a QR code displayed on the website), and the second signal contains a copy of that same identifier (captured by the phone) plus user verification information. The server evaluates these 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; Fig. 2).
• Technical Importance: The system aims to provide enhanced security over traditional password-only logins by requiring a second device for verification, while streamlining the user experience by using "reusable identifiers" that do not contain sensitive user- or transaction-specific data, which purportedly reduces server complexity and processing time (’116 Patent, col. 6:34-62).
• Analogy: The process is analogous to using a mobile banking app to scan a QR code on an ATM screen. The ATM (the computer) tells the bank's server (the verification system) that someone is trying to log in using a specific code. The user's phone (the electronic device) scans that code and sends it along with the user's credentials to the same server. The server confirms both signals match before granting the ATM access to the user's account.

Key Claims at a Glance

• The complaint does not identify specific claims, instead referring to "Exemplary '116 Patent Claims" detailed in an unattached exhibit (Compl. ¶11, 16). For the purpose of analysis, independent method claim 1 is representative of the patent's core teachings.
• Essential elements of Independent Claim 1 include:
  • 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 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 the signals to determine if the user is authorized.
  • Transmitting a third signal with authorization information to the electronic device and/or the computer in response to a successful evaluation.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The complaint does not identify any specific accused products, services, or methods by name. It refers generally to "Exemplary Defendant Products" that are identified in charts within an "Exhibit 2" (Compl. ¶11, 16), which was not attached to the publicly filed complaint.

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality. It makes only the conclusory allegation that the "Exemplary Defendant Products practice the technology claimed by the '116 Patent" (Compl. ¶16). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint incorporates its infringement allegations by reference to claim charts in an unattached exhibit (Compl. ¶17). The narrative theory of infringement is limited to alleging that the Defendant directly infringes by "making, using, offering to sell, selling and/or importing" the accused products and by having its employees "internally test and use" them (Compl. ¶11-12). Without the referenced exhibit, a detailed analysis of the infringement allegations is not possible.

• Identified Points of Contention: Based on the patent and the general nature of the allegations, the infringement analysis may raise several technical and legal questions for the court:
  • Architectural Questions: The infringement case will depend on how the claim elements ("computer system", "computer providing the secured capability", "electronic device") are mapped onto the Defendant's product architecture. A central question will be whether the Defendant's system contains the distinct components and signal flows recited in the claims.
  • Technical Questions: A key factual dispute may be whether the identifier used in the accused system is "reusable" in the manner described by the patent, or if it contains user-specific or transaction-specific information that would distinguish it from the claimed invention (’116 Patent, col. 9:11-14). The specific nature of the accused "user verification information" and how it is transmitted and evaluated will also be a critical area of inquiry.

V. Key Claim Terms for Construction

• The Term: "reusable identifier"

• Context and Importance: This term is central to the patent's asserted novelty over systems using "one-time-use" or unique identifiers. The construction of this term will be critical in determining the scope of the claims and whether the accused system infringes.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification states that a reusable identifier "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 a construction that covers any identifier not strictly limited to a single use by a single user for a single transaction.
  • Evidence for a Narrower Interpretation: The patent repeatedly distinguishes the invention from conventional systems and describes specific embodiments where a "predefined and previously generated list" of identifiers is used sequentially in a "round robin" fashion (’116 Patent, col. 9:23-43). This could support a narrower construction requiring the identifier to be part of a pre-generated, rotating pool, rather than merely being technically capable of reuse.

• The Term: "computer system"

• Context and Importance: Claim 1 describes a method of "using a computer system" to perform the authentication steps, distinguishing it from the "computer providing the secured capability." Practitioners may focus on this term because infringement will depend on whether the Defendant's architecture includes a component that meets the definition of this "computer system" (e.g., a verification server) and whether it is distinct from the component providing the secured service (e.g., a web server).

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The term itself is general. Plaintiff may argue it refers to any server or collection of servers configured to perform the claimed evaluation steps, regardless of its integration with other components.
  • Evidence for a Narrower Interpretation: The figures and associated description consistently depict the "verification server (60)" as a distinct entity from the "computer (50)" that provides the content, suggesting they are separate components (’116 Patent, Fig. 1; col. 5:23-33). While dependent claim 22 recites that the computer system can comprise the computer providing the secured capability, a defendant could argue this implies that in the independent claim, they must be separate.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of 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). The knowledge element for inducement is pleaded as arising from the service of the complaint itself (Compl. ¶15).
• Willful Infringement: The complaint alleges Defendant has "Actual Knowledge of Infringement" based on "the service of this Complaint" (Compl. ¶13). This forms the basis for a claim of post-filing willful infringement. No pre-suit knowledge is alleged.

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

• Evidentiary Sufficiency: A primary issue will be whether the Plaintiff can substantiate its conclusory infringement allegations, currently reliant on an unattached exhibit, with specific evidence demonstrating how the unidentified accused products perform each element of the asserted claims.
• Definitional Scope: The case will likely turn on the claim construction of "reusable identifier". The central legal question will be whether this term, as defined in the patent, can be construed to read on the specific type of identifier used in the Defendant's system.
• Architectural Mapping: A key factual question will be one of technical operation and system architecture. Does the Defendant's accused system possess the distinct components ("computer system," "computer providing secured capability") and signal-flow logic required by the claims, or is there a fundamental mismatch between the patented method and the accused functionality?