Matrix Absence Management Inc v. Penguin Benefits Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Matrix Absence Management, Inc. (Delaware) and AC Infotech Inc. (California)
  • Defendant: Penguin Benefits, Inc. (Delaware)
  • Plaintiff’s Counsel: Connolly Gallagher LLP; Sills Cummis & Gross P.C.
• Case Identification: 1:26-cv-00085, D. Del., 01/26/2026
• Venue Allegations: Venue is asserted in the District of Delaware on the basis that the Defendant is a Delaware corporation and is therefore subject to personal jurisdiction in the district.
• Core Dispute: Plaintiffs allege that Defendant’s OneLeave Explorer software infringes patents related to systems and methods for evaluating and displaying compliance standards information.
• Technical Context: The technology at issue involves automated, conversational systems for guiding users, such as employees, through complex, rule-based inquiries to determine their eligibility for benefits like statutory or corporate leave.
• Key Procedural History: The complaint alleges that Plaintiffs’ counsel sent a letter to Defendant on October 8, 2025, identifying the patents-in-suit, which may serve as the basis for a claim of pre-suit willful infringement.

Case Timeline

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

U.S. Patent No. 11,677,706 - "Systems and Methods for Evaluating and Displaying Subject-Specific Compliance Standard Information"

The Invention Explained

• Problem Addressed: The patent’s background section describes the challenge of managing employee benefits and leave programs, which has become increasingly difficult as companies grow across multiple jurisdictions with differing regulatory rules. Conventional automated "bots" are described as failing to satisfactorily address these issues due to the complexity, subtlety of natural language, and sensitive nature of employee information involved ʼ706 Patent, col. 1:12-54
• The Patented Solution: The invention proposes an "automated human interface module" that engages a user in a text-based conversation to determine their eligibility for a benefit. This system uses a "node graph," a hierarchical data structure where a first set of nodes is associated with predetermined compliance questions and a second set is associated with specific compliance standards (e.g., eligibility for a particular type of leave). As the user answers questions, they are progressed through the node graph until they reach a node in the second set, at which point the system generates a report on the availability of the corresponding benefit ʼ706 Patent, Abstract col. 2:4-25
• Technical Importance: The described technology aims to automate and personalize the process of determining an employee's eligibility for various leave benefits, thereby reducing the administrative burden on human resources departments and providing employees with a direct, conversational interface for complex inquiries ʼ706 Patent, col. 1:12-24

Key Claims at a Glance

• The complaint alleges infringement of one or more claims, with specific reference to independent Claim 1 Compl. ¶17
• The essential elements of Claim 1 include:
  • A computer system that receives a message from a subject to engage in a text-based conversation, where the message includes an application programming interface (API) token.
  • Engaging an automated human interface module that comprises a "node graph."
  • The node graph must have a first subset of nodes associated with compliance questions and a second subset associated with distinct compliance standards.
  • Using subsequent messages from the subject to progress them through the node graph based on the "satisfaction of the predetermined compliance question."
  • Repeating this process until the subject reaches a node in the second subset, which deems them to have satisfied the requirements for a benefit.
  • Generating and communicating a report to the subject showing the expected availability of that benefit.

U.S. Patent No. 12,047,343 - "Systems and Methods for Evaluating and Displaying Subject-Specific Compliance Standard Information"

The Invention Explained

• Problem Addressed: As a continuation of the application leading to the ’706 Patent, the ’343 Patent addresses the same technical problem: the complexity of managing individualized employee benefits across jurisdictions and the inadequacy of conventional automated systems in handling nuanced, sensitive conversations required for such tasks ʼ343 Patent, col. 1:18-58
• The Patented Solution: The patent describes a similar automated system that uses a "node-based conversation" to guide a user. The system is built around a "node graph" containing nodes for compliance questions and nodes for compliance standards. The user's answers to the questions dictate their path through the graph, leading to a determination of whether they meet the requirements for a particular benefit, after which information about that benefit is provided ʼ343 Patent, Abstract col. 2:5-30
• Technical Importance: This technology offers a scalable method for automating complex and individualized employee compliance inquiries, particularly focused on the administration of employee leave, which is governed by a patchwork of federal, state, and corporate policies ʼ343 Patent, col. 1:18-30

Key Claims at a Glance

• The complaint alleges infringement of one or more claims, with specific reference to independent Claim 1 Compl. ¶26
• The essential elements of Claim 1 include:
  • A computer system that receives a request from a user to identify benefits.
  • Engaging an interface module to interact via a "node-based conversation" that traverses nodes of a "node graph."
  • The node graph must have a first subset of nodes corresponding to compliance questions and a second subset corresponding to distinct compliance standards.
  • Progressing the user from an initial node in the first subset to the second subset by providing questions and traversing nodes based on the user's answers.
  • Upon progressing to a node in the second subset, determining that the user meets the requirements for a "first distinct compliance standard."
  • Providing information to the user regarding the "first benefit" associated with that standard.

III. The Accused Instrumentality

Product Identification

• The accused instrumentality is Defendant's "OneLeave Explorer" software Compl. ¶14

Functionality and Market Context

• The complaint does not provide specific details on the technical functionality or operation of the OneLeave Explorer software. It is identified as the "Infringing Software Tool" and is alleged to perform the functions of evaluating and displaying compliance standard information Compl. ¶¶9, 14 The complaint does not contain allegations regarding the product's market position or commercial importance.

IV. Analysis of Infringement Allegations

The complaint references, but does not include, claim charts (Exhibits C and D) that purportedly detail the infringement of Claim 1 of each asserted patent Compl. ¶14 In the absence of these exhibits, the infringement theory is based on the narrative allegations in the complaint.

Plaintiffs allege that Defendant’s OneLeave Explorer software directly infringes at least Claim 1 of the ’706 Patent and Claim 1 of the ’343 Patent by making, using, selling, or offering for sale the software in the United States Compl. ¶¶17, 26 The core of the infringement theory appears to be that the OneLeave Explorer software is an automated system that evaluates and displays subject-specific compliance information, thereby embodying the systems and methods claimed in the Asserted Patents Compl. ¶9 The infringement allegation rests on the contention that the software’s functionality for guiding a user to determine benefit eligibility mirrors the patented process of traversing a node graph based on user inputs.

• Identified Points of Contention:
  • Evidentiary Questions: The complaint makes conclusory allegations of infringement without providing specific factual support detailing how the accused software operates. A central issue will be whether Plaintiffs can produce evidence demonstrating that the OneLeave Explorer software practices each element of the asserted claims. This raises the question: What evidence will show that the accused software utilizes a "node graph" with distinct subsets for questions and standards, as opposed to another form of logic or data structure?
  • Scope Questions: The construction of key claim terms will be critical. A potential dispute may arise over the definition of "node graph." This raises the question of scope: Does the term "node graph," as defined and used within the patents, read on the actual software architecture of the OneLeave Explorer software?

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

• The Term: "node graph"

• Context and Importance: This term defines the core data structure of the claimed invention. The infringement analysis will likely depend on whether the architecture of the OneLeave Explorer software falls within the scope of this term. Practitioners may focus on this term because it represents the central technical mechanism that Plaintiffs allege is being infringed.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification provides a general definition, stating the automated human interface module includes a node graph "which includes a plurality of nodes interconnected to form a hierarchical data structure" '706 Patent, col. 9:7-10 This language could support a construction covering various forms of decision trees or logical flow structures.
  • Evidence for a Narrower Interpretation: The patent figures and detailed description illustrate a specific implementation where the node graph is a formal component containing discrete "Node" objects, some explicitly associated with a "Compliance question" and others with a "Compliance standard" '706 Patent, Fig. 2B A party could argue the term is limited to this more structured arrangement rather than any generic conversational logic.

• The Term: "progress the respective subject to another node...in accordance with satisfaction of the predetermined compliance question"

• Context and Importance: This phrase describes the functional mechanism for advancing a user through the system. The dispute may turn on whether the logic within the accused software performs this specific function as claimed. Practitioners may focus on this term to distinguish the operation of the accused product from the claimed method.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language is functional, suggesting that any mechanism that uses a user's answer to advance them to the next logical step in a workflow could be covered. The specification states the system uses "messages received from the subject...to progress the subject in the node graph" '706 Patent, col. 9:20-23
  • Evidence for a Narrower Interpretation: The specification discloses using "one or more classification models" to process user input and "determine if the predetermined compliance question is satisfied" '706 Patent, col. 4:1-5 An opposing party may argue that "satisfaction" requires a specific computational evaluation, as described in the embodiments, rather than a simple branching based on a direct answer.

VI. Other Allegations

• Indirect Infringement: The complaint alleges active inducement of infringement, asserting that "Penguin understands, intends, and encourages end users to use the Infringing Software Tool in the United States" Compl. ¶¶18, 27 The complaint does not specify the particular acts of encouragement, such as user manuals or marketing materials.
• Willful Infringement: The complaint alleges that Plaintiffs provided Defendant with pre-suit notice of the Asserted Patents via a letter dated October 8, 2025 Compl. ¶13 This alleged knowledge forms the basis for the willfulness claim and the request for enhanced damages Compl. ¶¶20, 29

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

• A core issue will be one of architectural equivalence: Will discovery reveal that the accused "OneLeave Explorer" software operates on a "node graph" with distinct subsets for questions and standards, as required by the claims, or does it employ a different logical framework for managing conversational flow that places it outside the patents' scope?
• A central evidentiary question will be one of functional proof: Given the complaint’s lack of technical specifics, what evidence will Plaintiffs present to demonstrate that the accused software performs each functional step of the asserted claims, from processing user messages to progressing a user through a workflow "in accordance with satisfaction of [a] compliance question"?