Cedar Lane Tech Inc v. Raymond James Financial Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cedar Lane Technologies Inc. (Canada)
  • Defendant: Raymond James Financial, Inc. (Florida)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 7:26-cv-00022, W.D. Tex., 01/22/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant maintains an established place of business in the district.
• Core Dispute: Plaintiff alleges that Defendant’s financial trading systems and services infringe a patent related to generating conditional, customized trade offers for semi-anonymous market participants based on their specific trading histories.
• Technical Context: The technology operates within the domain of high-frequency and electronic securities trading, where market-making entities seek to manage risk by differentiating pricing for counterparties based on their inferred trading strategies and historical profitability.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 8,577,782 - "Trading with conditional offers for semi-anonymous participants"

The Invention Explained

• Problem Addressed: The patent’s background section notes that the rise of electronic trading has led to increased anonymity, meaning buyers and sellers typically do not know the identity of their counterparties, which can prevent pricing based on the specific characteristics of that counterparty (ʼ782 Patent, col. 1:11-15).
• The Patented Solution: The invention describes a system that allows for "informed, semi-anonymous, trading" by using a trader's history without revealing their actual identity (ʼ782 Patent, col. 2:59-63). A trading entity, or "Taker," is associated with a persistent identifier. A "Liquidity Provider" can then acquire the Taker's transaction history linked to that identifier, analyze it to create a "profile" assessing their trading behavior (e.g., whether they are a sophisticated "toxic trader" or a "naive" one), and generate a conditional trade offer with customized pricing that is directed specifically to that identified Taker (ʼ782 Patent, col. 2:64-col. 3:4; Fig. 1).
• Technical Importance: This approach allows market makers to mitigate risk and potential losses from trading with highly informed participants while potentially offering more favorable terms to others, which may enhance overall market efficiency and liquidity (ʼ782 Patent, col. 6:46-58).

Key Claims at a Glance

• The complaint does not specify which claims are asserted, referring generally to "one or more claims" (Compl. ¶11). Independent claim 1 is representative of the patented method.
• The essential elements of independent claim 1 include:
  • Associating a trading entity with an identifier.
  • Acquiring the trading transaction history associated with that identifier.
  • Receiving an offer from a liquidity provider that is based on a "profile" generated from that history.
  • The profile contains information indicating whether the entity's past transactions would "generate a profit."
  • The offer is "only made to" the trading entity associated with the identifier.
  • The offer is processed through an exchange that handles transactions with a bid/offer spread.
• The complaint alleges infringement of "at least the exemplary claims" identified in an attached chart, suggesting the right to assert additional claims is reserved (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific products, methods, or services. It refers generically to "Exemplary Defendant Products" that are identified in an external document, Exhibit 2, which is incorporated by reference (Compl. ¶¶11, 16).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality. It makes the conclusory allegation that the accused products "practice the technology claimed by the '782 Patent" and "satisfy all elements of the Exemplary '782 Patent Claims" by referencing the non-provided Exhibit 2 (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint's substantive infringement allegations are made entirely by incorporating an external claim chart (Exhibit 2) by reference (Compl. ¶17). The body of the complaint itself does not contain a narrative theory explaining how any specific feature of the accused products meets the limitations of the patent claims. As the referenced exhibit was not provided, a detailed analysis of the infringement allegations is not possible based on the complaint alone. No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

The Term: "profile"

• Context and Importance: The generation and use of a "profile" is the basis for the conditional offers that are central to the invention. The scope of this term—whether it requires a specific type of quantitative analysis or can be a more general classification—will be critical to the infringement analysis.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests "trading history," the basis for the profile, can mean "any relevant information relating to the trader, including information relating to the past trades of the trader, the identity of the trader, a classification of the trader, etc." ('782 Patent, col. 2:65-col. 3:2). This could support a broad interpretation of what constitutes a profile.
  • Evidence for a Narrower Interpretation: The patent provides specific examples of profile generation based on quantitative profitability analysis, such as comparing a trade's execution price to the price one minute later or calculating the actual profit a provider earned from past trades with the entity ('782 Patent, col. 4:50-col. 5:10). This could support an argument that the term is limited to such profit-centric calculations.

The Term: "only made to said trading entity" (from claim 1) / "only directed to said taker" (from claim 10)

• Context and Importance: This limitation defines the exclusive and conditional nature of the claimed offers. Practitioners may focus on this term because its construction will determine whether the claim requires a private, point-to-point communication or could read on offers visible on a public feed but programmatically restricted for acceptance.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: System claim 15 describes an offer generator sending an offer to a "trade offer feed unit" where the offer "may only be accepted by the trading entity associated with the identifier" ('782 Patent, col. 12:14-17). This language may support an interpretation where the offer is technically broadcast but is only actionable by the intended recipient.
  • Evidence for a Narrower Interpretation: The plain meaning of "only made to" could be argued to require a communication channel that is inherently private and not visible to any other market participants, precluding a broadcast-style architecture.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement, asserting that since the filing of the complaint, Defendant has had knowledge of the '782 Patent and induces infringement by distributing "product literature and website materials" that instruct end users on how to use the accused products in an infringing manner (Compl. ¶¶14-15).
• Willful Infringement: The complaint does not use the term "willful infringement." It alleges that service of the complaint constitutes "actual knowledge of infringement" (Compl. ¶13), which may form the basis for a claim of post-filing willfulness or enhanced damages. The complaint does not allege any pre-suit knowledge.

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

Given the limited factual detail provided in the pleading, the case will initially turn on fundamental evidentiary and legal questions.

• A primary evidentiary question will be: What specific functionalities within Defendant's trading platforms will Plaintiff identify as corresponding to the key claim elements, particularly the creation of a trader "profile" based on historical profitability and the subsequent generation of "conditional offers" available only to that trader?
• A core issue will be one of definitional scope: Can the claim limitation "only made to said trading entity" be satisfied by a system where an offer is visible on a general market data feed but is programmatically restricted so that only a single, targeted entity can accept it, or does it require a truly private, non-broadcast offer? The court's construction of this term may be dispositive.