Authentixx LLC v. Data World Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Authentixx LLC (Delaware)
  • Defendant: Data World, Inc. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 7:25-cv-00282, W.D. Tex., 06/20/2025
• Venue Allegations: Venue is asserted based on Defendant maintaining an established place of business within the Western District of Texas and having committed alleged acts of infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified products and services infringe a patent related to methods for verifying the authenticity of electronic content, such as web pages.
• Technical Context: The technology addresses the problem of online fraud and phishing by providing a system to embed and verify a unique authenticity marker in electronic content, assuring the recipient of the content's true origin.
• Key Procedural History: The asserted patent claims priority back to a 1999 provisional application and is subject to a terminal disclaimer, which may suggest a protracted prosecution history and could be relevant to arguments regarding claim scope or validity. The complaint does not mention any prior litigation or licensing history.

Case Timeline

Date	Event
1999-09-09	'863 Patent Earliest Priority Date (Provisional)
2019-07-16	'863 Patent Issue Date
2025-06-20	Complaint Filing Date

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

U.S. Patent No. 10,355,863 - "System and method for authenticating electronic content"

Issued July 16, 2019

The Invention Explained

• Problem Addressed: The patent describes the risk of internet users being defrauded by malicious actors who create counterfeit web pages or emails that mimic legitimate ones by copying logos or using similar URLs. (’863 Patent, col. 1:24-40). The background notes that conventional security protocols like HTTPS do not, by themselves, guarantee to a user that the content of a page or email actually originates from the purported source. (’863 Patent, col. 2:1-9).
• The Patented Solution: The invention proposes a system where an "authenticity stamp" is embedded into electronic content to allow a user to validate its source. (’863 Patent, Abstract). The system architecture involves a user’s computer (with a browser plug-in), a web server, and a separate authentication server. (’863 Patent, FIG. 4). When a user requests a page, the web server forwards it to the authentication server, which inserts an "authenticity key." (’863 Patent, col. 2:15-18). The user’s plug-in then verifies this key to confirm authenticity and displays a pre-configured, user-defined "authenticity stamp," such as a custom icon or text. (’863 Patent, col. 4:10-24).
• Technical Importance: This approach seeks to provide a content-level, user-verifiable authentication mechanism that is independent of the underlying communication channel's security, thereby directly addressing the threat of spoofed content. (’863 Patent, col. 3:45-51).

Key Claims at a Glance

• The complaint alleges infringement of one or more claims without specifying them, instead referring to an unprovided exhibit. (’863 Patent, ¶11, 13). Independent claim 1 is representative of the asserted method.
• Independent Claim 1 recites a multi-step method, the essential elements of which include:
  • storing an "authenticity stamp" in a "preferences file" that is accessible by one or more designated servers;
  • creating, at the servers, an "authenticity key" with information to locate the preferences file;
  • receiving a page request from a client, followed by a separate request for the authenticity key;
  • sending formatted data to the client, and providing the authenticity key for "manipulation" by the client;
  • at the client, manipulating the key to locate the preferences file and retrieve the stamp; and
  • enabling the display of the authenticity stamp with the formatted data. (’863 Patent, col. 14:46-15:4)
• The complaint reserves the right to assert additional claims. (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not specifically name any accused products, methods, or services in its main body. It refers to them as the "Exemplary Defendant Products" and states they are identified in charts contained in an unprovided "Exhibit 2." (Compl. ¶¶ 11, 13).

Functionality and Market Context

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

IV. Analysis of Infringement Allegations

The complaint alleges direct infringement, stating that the "Exemplary Defendant Products practice the technology claimed by the '863 Patent" and that claim charts in Exhibit 2 demonstrate that these products "satisfy all elements of the Exemplary '863 Patent Claims." (Compl. ¶13). As Exhibit 2 was not provided with the complaint, a detailed claim-element-by-element analysis of the infringement allegations is not possible based on the filed document. No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: Based on the language of claim 1, a central question may be whether the architecture of the accused products maps onto the patent's specific client-server model. The analysis may focus on whether the accused system uses a "preferences file" that is both client-side and "accessible by one or more designated servers," as the claim requires. The interpretation of "accessible" in this context could be a significant point of dispute.
• Technical Questions: Claim 1 recites a specific protocol involving a page request followed by a distinct, separate request for an "authenticity key." A key technical question will be whether the accused products perform authentication using this specific two-step request-and-response sequence, or if they employ a different, more integrated authentication method. The complaint provides no evidence on this point.

V. Key Claim Terms for Construction

The Term: "authenticity stamp"

• Context and Importance: This term defines the ultimate indicator of authenticity for the end-user. Its construction will determine whether the accused products provide an equivalent feature, which is critical to the infringement analysis.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests the "stamp" can be more than a simple icon, encompassing "personal information relating to the user's account" such as an "account balance, last deposit date, [or] previous transaction amount." (’863 Patent, col. 2:35-37). It also contemplates a "computer-generated fractal design." (’863 Patent, col. 3:45-46).
  • Evidence for a Narrower Interpretation: The patent’s figures and corresponding description heavily feature examples of user-configured visual stamps, such as a diamond shape with text (FIG. 2) or the text "A-OKAY" embedded in an image (FIG. 3), which are defined by the user during a setup process. (’863 Patent, col. 4:10-24).

The Term: "preferences file"

• Context and Importance: The location and accessibility of this "file" are recited limitations in claim 1. Practitioners may focus on this term because modern web architectures may not use a discrete "file" in the manner described, potentially creating a mismatch with the claim language.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent does not provide an explicit definition that would broaden the term beyond its ordinary meaning.
  • Evidence for a Narrower Interpretation: The specification states that "the preferences file is stored on the user's 110 file system" and "is placed in a random directory to help obscure the location." (’863 Patent, col. 6:37-38; col. 12:64-65). This points toward a physical file stored on the client machine, which raises the question of how it is also "accessible by one or more designated servers" as required by the claim.

VI. Other Allegations

Indirect Infringement

The complaint does not include counts for indirect or contributory infringement. It alleges direct infringement through Defendant's own making, using, and selling, as well as through internal testing by its employees. (Compl. ¶¶ 11-12).

Willful Infringement

The complaint does not formally allege willful infringement. However, in its prayer for relief, it requests that the case be "declared exceptional" and seeks an award of attorneys' fees under 35 U.S.C. § 285. (Compl. ¶E.i). The complaint pleads no specific facts to support pre-suit or post-suit knowledge of infringement.

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

• Architectural Mapping: A core issue will be one of technical and architectural alignment: can Plaintiff demonstrate that the accused products, which likely operate on a modern web or cloud infrastructure, practice the specific, multi-component architecture of the asserted claims, which requires a client-side "preferences file" that is also server-accessible and located via a separate "authenticity key" transaction?
• Evidentiary Sufficiency: As the complaint relies entirely on an unprovided exhibit to substantiate its infringement theory, a primary hurdle for the Plaintiff will be to produce sufficient factual evidence to support its conclusory allegations and survive early dispositive motions.
• Definitional Scope: The case may turn on a question of definitional scope: can terms like "authenticity stamp" and "preferences file," which are described in the patent with examples rooted in late-1990s computing (e.g., user-configured icons, local file system storage), be construed broadly enough to read on the potentially different data structures and authentication mechanisms used in contemporary systems?