TicketMatrix LLC v. On Location Events LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: TicketMatrix LLC (New Mexico)
  • Defendant: On Location Events, LLC (Delaware)
  • Plaintiff's Counsel: Silverman, McDonald & Friedman; Rabicoff Law LLC
• Case Identification: 1:26-cv-00812, D. Del., 07/06/2026
• Venue Allegations: Venue is alleged to be proper because the Defendant is incorporated in Delaware, has an established place of business in the district, and has committed alleged acts of infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant's unspecified products and services infringe a patent related to systems and methods for providing and managing player-specific tickets for sporting events.
• Technical Context: The technology provides a framework for selling event tickets that are tied to the participation of a specific player or team, rather than a specific date or match, using probabilistic modeling to manage seat inventory.
• Key Procedural History: The complaint references, but does not include, claim chart exhibits (Exhibits 1 and 2) that purportedly detail the infringement allegations. No other prior litigation, licensing history, or administrative proceedings are mentioned.

Case Timeline

Date	Event
2006-01-24	'452 Patent Application Filing Date
2010-11-09	'452 Patent Issue Date
2026-07-06	Complaint Filing Date

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

U.S. Patent No. 7,831,452 - "Systems and methods for providing enhanced player's ticket features"

• Patent Identification: U.S. Patent No. 7,831,452, "Systems and methods for providing enhanced player's ticket features," issued November 9, 2010.

The Invention Explained

• Problem Addressed: The patent addresses the problem faced by sports fans who must purchase tickets for tournament matches (e.g., a tennis semi-final) long before the participating players are known, risking investment in a match of little interest to the fan '452 Patent, col. 1:7-39
• The Patented Solution: The invention proposes a "player's ticket," a new type of ticket that grants admission to any match in which a specific, named player participates, regardless of the round or opponent '452 Patent, abstract '452 Patent, col. 1:56-62 To manage the complex seat allocation challenges this creates, the system uses computer simulations and probabilistic modeling to predict tournament outcomes and determine the number of seats to allocate for various player-ticket holders at different levels of confidence '452 Patent, col. 2:36-57 '452 Patent, FIG. 11
• Technical Importance: This approach transforms static event ticketing into a dynamic, options-based financial system, allowing organizers to monetize fan loyalty to specific players and hedge against the uncertainty of tournament progression '452 Patent, col. 1:40-47

Key Claims at a Glance

• The complaint alleges infringement of one or more "Exemplary '452 Patent Claims" which are identified in an exhibit not provided with the complaint Compl. ¶11 Compl. ¶16 Claim 1 is the first independent method claim of the '452 Patent.
• Essential elements of Independent Claim 1 include:
  • providing, via a server, player's ticket options that reference a player and allow the holder to exercise the option for admission to a match in which the player is playing;
  • acquiring tournament information, including players, a tournament draw, and historical data;
  • determining probabilities of players winning based on the tournament information;
  • determining at least one possible allocation of match admissions for the ticket options based on the options provided and the tournament draw; and
  • allocating match admissions based on the possible allocation, the winning probabilities, and the probability of option holders exercising their options.
• The complaint broadly seeks relief for infringement of "one or more claims" '452 Patent, prayer B, which may include dependent claims.

III. The Accused Instrumentality

Product Identification

• The complaint does not identify any accused product, method, or service by name. It refers only to "Exemplary Defendant Products" that are purportedly identified in attached charts not included with the complaint Compl. ¶11

Functionality and Market Context

• The complaint alleges that the accused products "practice the technology claimed by the '452 Patent" Compl. ¶16 It further alleges that the Defendant makes, uses, sells, and imports these products, and distributes "product literature and website materials" that induce infringement Compl. ¶11 Compl. ¶14 No specific technical functionality or market context for the Defendant's products is described. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references but does not provide the claim charts detailing its infringement theory Compl. ¶16 Compl. ¶17 The following table summarizes a potential infringement theory for Claim 1 based on the general allegations in the complaint and the teachings of the patent.

'452 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
providing, via the player's ticketing server, player's ticket options that: (a) reference at least one player...	The complaint alleges Defendant's system offers for sale products that provide access to sporting events based on player participation.	¶11; ¶14	col. 29:8-19
acquiring, using the player's ticketing server, information about a tournament, including information selected from the group consisting of players, a tournament draw, and historical data;	Defendant's system is alleged to use data related to tournaments, such as player lists and match structures, to operate its ticketing service.	¶11; ¶16	col. 26:30-34
determining, using the player's ticketing server, for at least one match of the tournament probabilities of players winning based on the tournament information;	The infringement theory suggests Defendant's system computationally determines the likelihood of players winning matches as part of its ticketing process.	¶11; ¶16	col. 26:35-43
allocating, using the player's ticketing server, match admissions...based on...the probability of player's ticket option holders exercising the player's ticket options.	The core of the alleged infringement is that Defendant's system allocates seat inventory based on a probabilistic analysis of how likely its customers are to use their purchased options.	¶11; ¶16	col. 30:19-24

• Identified Points of Contention:
  • Scope Questions: A primary question may be one of divided infringement. Does the Defendant's system perform every step of the asserted method claim, or are some steps (e.g., "exercising the player's ticket option") performed by the end-user? The claim's recitation of a "player's ticketing server" performing most steps suggests the plaintiff will pursue a theory of single-actor infringement by the Defendant.
  • Technical Questions: A key evidentiary question will be whether the accused products perform the specific computational steps required by the claims. What evidence does the complaint provide that the Defendant's system performs a probabilistic analysis to "determine...probabilities of players winning" and "allocat[e]...match admissions" based on the probability of options being exercised, as opposed to using a simpler, non-infringing inventory management method?

V. Key Claim Terms for Construction

• The Term: "player's ticket option"

  • Context and Importance: This term defines the instrument at the center of the claimed method. The scope of this term is critical because if the product offered by the Defendant does not meet this definition, there may be no infringement.
  • Evidence for a Broader Interpretation: The specification describes a ticket option simply as giving the holder "the option of purchasing tickets for a match on preferential terms" '452 Patent, col. 2:18-22 This could support a broad reading covering various contingent purchase rights.
  • Evidence for a Narrower Interpretation: The patent's detailed description focuses on highly structured options tied to tournament progression, such as "round-'x'-onwards" tickets '452 Patent, col. 9:34-43 A defendant could argue the term should be limited by these specific embodiments, which involve complex probabilistic calculations not present in simpler ticket offerings.

• The Term: "allocating... based on... the probability of player's ticket option holders exercising the player's ticket options"

  • Context and Importance: This limitation describes the core computational novelty of managing inventory. Infringement may hinge on whether the accused system performs this specific, probability-based calculation.
  • Evidence for a Broader Interpretation: The patent discusses "dampening" the probability distributions, which could be a simple percentage reduction based on historical data of option exercise rates '452 Patent, col. 24:55-67 This might support an argument that any adjustment to seat allocation based on expected option usage meets the limitation.
  • Evidence for a Narrower Interpretation: The specification extensively details complex, multi-iteration computer simulations to generate probability distributions for seat allocation (e.g., running 3,000 iterations) '452 Patent, col. 15:5-15 '452 Patent, FIG. 6 A defendant may argue that "based on the probability" requires this sophisticated, data-intensive modeling, and that simpler estimation methods do not infringe.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that the Defendant provides "product literature and website materials" that direct and encourage customers to use the accused products in a manner that infringes the '452 Patent Compl. ¶14 Compl. ¶15
• Willful Infringement: The complaint alleges that the Defendant has had "Actual Knowledge of Infringement" from the moment of service of the complaint and its attached claim charts Compl. ¶13 The allegations of continued infringement post-filing form the basis for a potential willfulness claim Compl. ¶14 Compl. ¶15

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

• A primary issue will be one of evidentiary sufficiency: Given the complaint's lack of specific factual allegations about the accused products, a key question is what evidence Plaintiff will be able to discover and present to prove that Defendant's system performs the specific, data-driven probabilistic calculations and allocation steps required by the asserted claims.
• A central legal question will be one of definitional scope: How will the term "allocating... based on... probability" be construed? The case may turn on whether this requires proof of a sophisticated, multi-iteration simulation as detailed in the patent's preferred embodiments, or if it can be satisfied by a more general method of estimating and adjusting for demand from option holders.