DCT

7:25-cv-00478

Synchrofi LLC v. Salesforce Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 7:25-cv-00478, W.D. Tex., 10/21/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains an established place of business in the Western District of Texas and has committed acts of patent infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendant infringes a patent related to methods and systems for single-use password authentication.
  • Technical Context: The technology at issue addresses secure user authentication in a networked environment, a critical component for enterprise software and online services that aims to improve security over traditional static passwords.
  • Key Procedural History: The complaint does not reference any prior litigation, licensing history, or post-grant proceedings involving the patent-in-suit.

Case Timeline

Date Event
2004-10-12 ’919 Patent Priority Date
2009-11-03 ’919 Patent Issue Date
2025-10-21 Complaint Filing Date

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

U.S. Patent No. 7,613,919 - "Single-use password authentication"

  • Patent Identification: U.S. Patent No. 7,613,919, "Single-use password authentication", issued November 3, 2009 (’919 Patent).

The Invention Explained

  • Problem Addressed: The patent’s background section describes the security risks inherent in conventional username/password systems, such as susceptibility to eavesdropping and brute-force attacks, and the practical difficulties of more complex systems like public key infrastructure (PKI) for widespread use (’919 Patent, col. 1:21-30, col. 2:11-23).
  • The Patented Solution: The invention discloses a three-party authentication architecture consisting of a client, a service provider, and a centralized authentication service (’919 Patent, Fig. 1A). A user (client) provides a "client moniker" to the authentication service, which in turn provides the user with a one-time password. The user presents this one-time password to the service provider, which validates it with the authentication service. Upon successful validation, the authentication service sends a unique "authentication service identifier" to the service provider, completing the process and authenticating the user without the service provider ever knowing the user's underlying "moniker" (’919 Patent, Abstract; col. 3:28-51).
  • Technical Importance: This system was designed to enable strong, one-time password security for users accessing multiple online services without requiring pre-existing trust relationships between all parties, thereby simplifying the user experience and centralizing the core authentication function (’919 Patent, col. 2:50-65).

Key Claims at a Glance

  • The complaint alleges infringement of "one or more claims" and "exemplary claims" identified in an exhibit that was not attached to the publicly filed document (Compl. ¶11, ¶16).
  • As the first independent claim directed to the core system, Claim 1 is representative. Its essential elements require an "authentication service" to perform the steps of:
    • generating an authentication service identifier for the client;
    • receiving a client moniker from the client;
    • sending a one-time password to the client;
    • receiving a one-time password from the service provider;
    • if the received password matches the sent password, sending the authentication service identifier to the service provider to authenticate the client (’919 Patent, col. 19:42-col. 20:2).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies the accused products as "Exemplary Defendant Products" listed in an external chart (Exhibit 2), which was not provided with the complaint (Compl. ¶11, ¶16).

Functionality and Market Context

  • The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality. It makes a conclusory allegation that the accused products "practice the technology claimed by the '919 Patent" (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint’s infringement allegations are made entirely by reference to an unattached exhibit (Exhibit 2) and lack specific factual assertions within the body of the complaint itself (Compl. ¶16, ¶17). The complaint alleges that the "Exemplary Defendant Products" satisfy all elements of the asserted claims (Compl. ¶16). No probative visual evidence provided in complaint.

Identified Points of Contention

  • Due to the limited detail, the primary points of contention will likely emerge during claim construction and discovery. Based on the patent’s architecture, several foundational questions are apparent:
    • Architectural Question: A central question may be whether Salesforce's integrated platform can be mapped onto the patent’s three-party model. The analysis may focus on whether Salesforce operates a distinct "authentication service" and "service provider" as contemplated by the claims, or if its system is a unitary architecture that does not align with the claimed structure.
    • Technical Question: The complaint does not identify which features of the accused products correspond to key claim elements like the "client moniker" and the "authentication service identifier." A likely point of contention will be whether any feature in the accused Salesforce products performs the specific roles assigned to these elements in the ’919 Patent.

V. Key Claim Terms for Construction

The Term: "authentication service"

  • Context and Importance: The definition of this term is fundamental to the scope of the claims. Practitioners may focus on this term because its construction will determine whether the claims require a logically or commercially separate entity from the "service provider," or if both roles can be performed by different components within a single integrated system.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claims do not explicitly state that the "authentication service" and "service provider" must be operated by different entities. The patent’s discussion of single sign-on to access "affiliated providers" could suggest the entities may be related (’919 Patent, col. 2:65).
    • Evidence for a Narrower Interpretation: The patent’s figures and detailed description consistently depict the "authentication service" (120) and "service provider" (130) as separate, distinct boxes connected by a communication link, suggesting they are independent participants in the system (’919 Patent, Fig. 1A; col. 6:56-65). This may support an argument that the terms refer to distinct systems.

The Term: "client moniker"

  • Context and Importance: This term defines the initial credential provided by the user. Its construction is critical to determining what type of user input (e.g., a username, a password, or another identifier) meets this limitation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the term as "analogous to a username" and a "username of sorts," which may support construing it to cover standard user IDs (’919 Patent, col. 3:32; col. 8:6-7).
    • Evidence for a Narrower Interpretation: The specification also describes the moniker as "ideally the client's everyday preferred 'password' known only to themselves" and a "proxy password," suggesting it is a secret credential rather than a public identifier (’919 Patent, col. 3:32-37). This could support a narrower construction requiring a password-like secret.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, asserting that Defendant distributes "product literature and website materials" that instruct and encourage end users to use the accused products in an infringing manner (Compl. ¶14).
  • Willful Infringement: The complaint alleges that service of the complaint itself provides Defendant with "actual knowledge" of infringement and that Defendant’s continued infringement thereafter is intentional, forming a basis for post-suit willful infringement (Compl. ¶13-14). No allegations of pre-suit knowledge are made.

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

  • A core issue will be one of architectural mapping: Can Plaintiff plausibly allege and prove that Salesforce's authentication system, which is likely highly integrated, conforms to the patent’s tripartite structure of a distinct "client," "service provider," and "authentication service," or does the accused system represent a fundamentally different, non-infringing architecture?
  • A key evidentiary question will be one of factual specificity: Given the complaint's reliance on an unattached exhibit, the case will hinge on whether Plaintiff's subsequent infringement contentions can provide a detailed, element-by-element factual basis showing how specific Salesforce product features perform the functions of claimed elements such as the "client moniker" and "authentication service identifier."