Secure Matrix LLC v. Landrys LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Secure Matrix LLC (Delaware)
  • Defendant: Landry's, LLC (Delaware)
  • Plaintiff's Counsel: Rabicoff Law LLC
• Case Identification: 4:26-cv-02568, S.D. Tex., 03/31/2026
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains an established place of business in the Southern District of Texas and has committed alleged acts of infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to systems and methods for user authentication and verification, typically involving a user's mobile device interacting with a web service.
• Technical Context: The patent addresses methods for securely authenticating a user to a digital service (such as a website or payment portal) by using a separate personal device (like a smartphone) to mediate the authentication process, a common paradigm in modern multi-factor authentication.
• Key Procedural History: The complaint does not allege any prior litigation, licensing history, or other procedural events relevant to the patent-in-suit.

Case Timeline

Date	Event
2012-11-21	'116 Patent Priority Date
2014-03-18	'116 Patent Issue Date
2026-03-31	Complaint Filing Date

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

U.S. Patent No. 8,677,116 - "Systems and methods for authentication and verification"

The patent-in-suit is U.S. Patent No. 8,677,116, issued March 18, 2014 (the "'116 Patent").

The Invention Explained

• Problem Addressed: The patent describes a "growing need to authenticate users" for both secure internet portals (e.g., websites) and real-world secured devices, as well as a need for secure and fast online electronic payment capabilities '116 Patent, col. 1:20-29
• The Patented Solution: The invention proposes a three-party authentication system to solve this problem. First, a computer providing a service (e.g., a web server) generates a "reusable identifier" '116 Patent, col. 2:31-33 Second, a user's separate electronic device (e.g., a smartphone) captures this identifier (e.g., by scanning a QR code) and sends it, along with "user verification information," to a third-party verification computer '116 Patent, col. 2:33-36 This verification computer then evaluates the signals from both the service computer and the user's device to determine if the user is authorized, and if so, sends back an authorization signal '116 Patent, col. 2:38-49 '116 Patent, Fig. 2
• Technical Importance: This architecture separates the user verification process from the primary service provider, which could reduce the need for users to manage separate passwords for every website and potentially centralize security functions '116 Patent, col. 6:35-40

Key Claims at a Glance

The complaint does not specify which claims are asserted, referring generally to "one or more claims" Compl. ¶11 Independent claims 1 and 11 are representative of the patented method and system, respectively.

• Independent Claim 1 (Method):

  • Using a computer system to receive a first signal from a computer providing a secured capability, the signal comprising a "reusable identifier."
  • Receiving a second signal from a user's electronic device, the signal comprising a copy of the reusable identifier and "user verification information."
  • Using a processor to evaluate, based on the first and second signals, whether the user is authorized.
  • In response to an authorization, transmitting a third signal with authorization information to the electronic device and/or the computer.

• Independent Claim 11 (System):

  • A first input configured to receive first signals (with reusable identifiers) from a plurality of computers.
  • A second input configured to receive second signals (with copies of reusable identifiers and user verification information) from a plurality of user electronic devices.
  • A storage device associating secured capabilities with identifiers and user information with verified users.
  • A processor configured to evaluate the signals to determine if a user is authorized.
  • An output to transmit a third signal containing authorization information.

The complaint reserves the right to assert infringement under the doctrine of equivalents Compl. ¶11

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products or services Compl. ¶11 It refers generally to "Exemplary Defendant Products" that are identified in charts incorporated into the complaint as Exhibit 2 Compl. ¶11 Compl. ¶16 This exhibit was not publicly filed with the complaint.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the functionality of the accused instrumentalities. Based on the defendant's business as a hospitality company, the accused instrumentalities may relate to customer login portals, online ordering systems, or loyalty program platforms.

IV. Analysis of Infringement Allegations

The complaint's substantive infringement allegations are contained entirely within claim charts in Exhibit 2, which was not provided with the filed complaint Compl. ¶16 Compl. ¶17 The complaint asserts in a conclusory manner that the "Exemplary Defendant Products practice the technology claimed by the '116 Patent" and "satisfy all elements of the Exemplary '116 Patent Claims" Compl. ¶16 Without access to the claim charts or a description of the accused functionality, a detailed infringement analysis is not possible.

• Identified Points of Contention: Based on the patent's claims, a future dispute may center on several key technical and legal questions:
  • Scope Questions: A likely point of contention will be whether the term "reusable identifier," as described in the patent, can be construed to cover conventional web technologies such as session cookies or authentication tokens that may be used in the accused systems. The patent suggests this identifier does not contain user-specific information, which could be a key distinction '116 Patent, col. 9:8-15
  • Technical Questions: A central factual question will be whether the architecture of the accused systems maps onto the three-party structure (service computer, user device, and a separate verification computer system) required by the independent claims. The analysis may explore whether the defendant's systems perform authentication within a traditional two-party client-server model, which may not align with the claim limitations.

V. Key Claim Terms for Construction

• The Term: "reusable identifier" (Claim 1; Claim 11)

• Context and Importance: This term is the central component exchanged between the systems and is foundational to the claimed invention. Its construction will be critical to determining infringement, as it defines the object that initiates the authentication process. Practitioners may focus on this term because its scope will determine whether it reads on a wide variety of modern authentication tokens or is limited to the specific type of non-user-specific identifier described in the patent.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification states the identifier "can be reused for multiple users and multiple transactions" '116 Patent, col. 9:14-15, which could support an argument that any persistent or semi-persistent token falls within its scope.
  • Evidence for a Narrower Interpretation: The patent repeatedly distinguishes the invention by noting the identifier "does not contain user-specific or transaction-specific information" '116 Patent, col. 9:12-14 This could support a narrower construction that excludes identifiers containing any session or user data.

• The Term: "user verification information" (Claim 1; Claim 11)

• Context and Importance: This information is sent from the user's device and is used by the verification server to confirm the user's identity. The definition of this term is important because it is the element that provides the security layer.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent provides a wide range of examples, including information "specific to the user (e.g., the user's first name, family name, email address, phone number)" or information "specific to the first electronic device 20 (e.g., a device identification character string, hardware-specific information)" '116 Patent, col. 12:7-14 This could support a broad reading covering many forms of credentials or device fingerprinting.
  • Evidence for a Narrower Interpretation: A defendant might argue that this information must be distinct from the "reusable identifier" and evaluated in a separate step by the verification server, potentially excluding systems where a single encrypted token contains all necessary data.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes" ('116 Patent, Compl. ¶14).
• Willful Infringement: The complaint appears to base its infringement allegations on post-suit knowledge. It states that "service of this Complaint, in conjunction with the attached claim charts... constitutes actual knowledge" and that Defendant has induced infringement "[a]t least since being served by this Complaint" Compl. ¶13 Compl. ¶15

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

• A core issue will be one of architectural mapping: a key evidentiary question will be whether the Defendant's accused authentication systems operate using the three-distinct-entity architecture (service computer, user device, verification computer) recited in the asserted claims, or if they employ a conventional two-party client-server model that may not meet the claim limitations.
• A second core issue will be one of definitional scope: the outcome may depend on the court's construction of the term "reusable identifier." The central question will be whether this term is limited to the non-user-specific codes described in the patent's preferred embodiments or can be read broadly enough to cover common web-based authentication tokens.