Secure Matrix LLC v. Grunt Style LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Secure Matrix LLC (DE)
  • Defendant: Grunt Style, LLC (TX)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 7:25-cv-00136, W.D. Tex., 10/06/2025
• Venue Allegations: Venue is alleged to be proper in the Western District of Texas because Defendant has an established place of business in the District and has committed alleged acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s products and services infringe a patent related to a multi-factor computer authentication system.
• Technical Context: The technology concerns secure user authentication for accessing digital services, a foundational component of e-commerce and online account security.
• Key Procedural History: The complaint notes that an original complaint was filed on March 21, 2025, and alleges that Defendant’s knowledge for the purposes of induced and willful infringement dates from at least the service of that original complaint.

Case Timeline

Date	Event
2012-11-21	’116 Patent - Earliest Priority Date
2013-08-09	’116 Patent - Application Filing Date
2014-03-18	’116 Patent - Issue Date
2025-03-21	Original Complaint Filing Date
2025-10-06	Amended Complaint Filing Date

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 addresses deficiencies in prior art authentication, such as the vulnerability of static username/password systems to compromise, the inconvenience for users of managing multiple complex passwords, and the resulting high costs for businesses providing customer support for password recovery (Compl. ¶9-11; ’116 Patent, col. 32:65-33:2).
• The Patented Solution: The invention proposes a distributed, multi-channel authentication method. A first computer (e.g., a web server providing a "secured capability") sends a "reusable identifier" to a central verification server. Concurrently, a user's electronic device (e.g., a smartphone) sends a copy of that same reusable identifier along with separate "user verification information" to the same verification server. The verification server authenticates the user by correlating these two independent signals, a process intended to be more secure than conventional single-channel credential submission (’116 Patent, Abstract; Compl. ¶16). This architecture is depicted in Figure 2 of the patent (’116 Patent, Fig. 2).
• Technical Importance: The approach aims to enhance security by separating the authentication channels and preventing the primary web server from ever directly handling or storing sensitive user credentials, thereby reducing its vulnerability as an attack target (Compl. ¶16).

Key Claims at a Glance

• The complaint focuses its allegations on independent claim 1 (Compl. ¶12, ¶13, ¶16, ¶26).
• Claim 1 of the ’116 Patent requires, in essence:
  • A computer system receiving a first signal from a computer providing a secured capability, where the signal comprises a reusable identifier assigned for use for a finite period of time.
  • The computer system receiving a second signal from a user's electronic device, where this signal comprises a copy of the reusable identifier and user verification information.
  • A processor evaluating, based on the first and second signals, whether the user is authorized.
  • In response to a positive evaluation, transmitting a third signal with authorization information.
• The complaint does not explicitly reserve the right to assert dependent claims but refers generally to infringement of "one or more claims" (Compl. ¶30).

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products, methods, or services. It refers generically to "Exemplary Defendant Products" and states that they are identified in claim charts incorporated by reference from an "Exhibit 2" (Compl. ¶30, ¶35). This exhibit was not included with the complaint.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the functionality or market context of the accused instrumentalities.

IV. Analysis of Infringement Allegations

The complaint alleges infringement of at least claim 1 of the ’116 Patent but does not provide specific factual allegations mapping claim elements to accused product functionality in the body of the complaint (Compl. ¶30, ¶35). Instead, it states that such analysis is contained in an "Exhibit 2," which was not provided (Compl. ¶36). Therefore, a claim chart summary cannot be constructed.

• Identified Points of Contention: Based on the patent’s claims and the complaint's narrative, the infringement analysis may raise several technical and legal questions for the court:
  • Scope Questions: A central question may be whether the accused system’s architecture meets the two-signal, two-channel structure required by claim 1. For instance, does the accused system receive two distinct signals at a verification server—one from the service provider and one from the user's device—for correlation, or does it utilize a more conventional architecture where the user's device communicates directly with the service provider?
  • Technical Questions: What specific feature in the accused system functions as the claimed "reusable identifier"? The complaint emphasizes that this identifier is not user- or transaction-specific, which may create a point of contention if the accused identifier contains session- or user-specific data (Compl. ¶14). Further, what evidence demonstrates that this identifier is assigned for a "finite period of time" to prevent replay attacks, as the complaint alleges is a key inventive concept (Compl. ¶20-21)?

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

"reusable identifier"

• Context and Importance: This term is the core of the claimed invention. Its construction will determine whether the claim reads on a broad of modern authentication tokens or is limited to the specific types of identifiers disclosed in the patent. Practitioners may focus on this term because the complaint stresses that it does not contain "user specific or transaction specific information," a key distinction from many conventional session tokens (Compl. ¶14).
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claims themselves do not place explicit structural limitations on the identifier beyond it being "reusable" (’116 Patent, col. 33:21-23). The term "reusable" is defined in the specification as an identifier that "can be used more than once" and is "not unique to one particular user or transaction" (’116 Patent, col. 9:6-12). This could support an interpretation covering any non-unique, multi-use token.
  • Evidence for a Narrower Interpretation: The specification repeatedly contrasts the invention with conventional systems and emphasizes the benefits of the identifier not including user-specific information, which simplifies the system (e.g., simpler QR codes) and enhances security (’116 Patent, col. 6:35-50). Embodiments often describe the identifier as a QR code presented on a login page, which could support a narrower construction limited to identifiers that are generic to the login session itself rather than being tied to a specific user's interaction (’116 Patent, col. 10:51-57).

"for a finite period of time"

• Context and Importance: This limitation is presented in the complaint as a key technical solution to the problem of replay attacks (Compl. ¶20-21). The scope of "finite" will be critical, as nearly all modern authentication tokens have some form of expiration. The question will be whether the accused system's token lifecycle meets the specific temporal validation function described in the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification provides a wide range of possible durations, from "one or more minutes, one or more hours, one or more days," suggesting the term is not meant to be narrowly restrictive (’116 Patent, col. 9:42-43).
  • Evidence for a Narrower Interpretation: The specification describes a specific "round robin" system where an identifier, after its time period elapses, can be deleted and reused later (’116 Patent, col. 9:46-54; col. 13:43-47). A defendant may argue that the term should be construed in light of this specific reuse mechanism, potentially narrowing the claim's scope to systems that employ a similar method of recycling identifiers.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement based on Defendant selling the accused products and distributing "product literature and website materials" that allegedly instruct end users on how to use the products in an infringing manner (Compl. ¶33-34).
• Willful Infringement: The complaint bases its willfulness allegation on Defendant's alleged knowledge of the ’116 Patent since at least the service of the original complaint on March 21, 2025 (Compl. ¶34).

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

• A core issue will be one of architectural equivalence: Does the accused authentication system, once revealed, actually implement the distributed, two-channel architecture required by Claim 1? The case may turn on whether the data flows in the accused system can be mapped to the claimed "first signal" and "second signal" being independently received and correlated by a single "computer system."
• A second key issue will be one of definitional scope: Can the term "reusable identifier," as described in the patent to be devoid of user-specific information, be construed to cover the tokens or identifiers used in the accused system? This will likely require a detailed analysis of the data structure of the accused identifiers.
• Finally, given the lack of specific factual allegations in the complaint itself, an initial question for the court will be one of pleading sufficiency: Does the complaint's incorporation by reference of an unprovided exhibit meet the plausibility standards required for patent infringement claims under Federal Circuit precedent?