Iqx Corp v. Salesforce Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: IQX Corp. (Wyoming)
  • Defendant: Salesforce, Inc. (Delaware)
  • Plaintiff's Counsel: Russ August & Kabat
• Case Identification: 7:26-cv-00213, W.D. Tex., 05/28/2026
• Venue Allegations: Venue is alleged to be proper as Defendant has committed acts of infringement and maintains a regular and established place of business within the Western District of Texas.
• Core Dispute: Plaintiff alleges that Defendant's text message marketing systems infringe four patents related to secure mobile transactions, customized webpage generation, and automated network authentication.
• Technical Context: The technology at issue addresses security and user experience in mobile e-commerce, a domain critical for customer engagement and online sales, by creating secure, personalized transaction pathways.
• Key Procedural History: The asserted patents are part of a continuing patent family, all claiming priority to a 2018 provisional application. The complaint does not reference any prior litigation, inter partes review (IPR) proceedings, or licensing history concerning these patents.

Case Timeline

Date	Event
2018-09-27	Priority Date for '924, '165, '799, and '978 Patents
2024-01-16	U.S. Patent No. 11,876,924 Issues
2025-01-14	U.S. Patent No. 12,200,165 Issues
2025-07-22	U.S. Patent No. 12,368,799 Issues
2025-10-07	U.S. Patent No. 12,438,978 Issues
2026-05-28	Complaint Filed

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

U.S. Patent No. 11,876,924 - "Secure transactions using customized webpages" (Issued Jan. 16, 2024)

The Invention Explained

• Problem Addressed: The patent's background describes that conventional online transactions can be cumbersome and are vulnerable to fraud, which undermines user trust and willingness to transact online ʼ924 Patent, col. 1:23-28 Furthermore, static webpages often present a poor user experience by forcing visitors to navigate through irrelevant information ʼ924 Patent, col. 1:33-41
• The Patented Solution: The invention proposes a computer-implemented method where a user interacts with a "hosted field" on a third-party's document (e.g., a webpage) to provide their telephone number and consent to receive messages ʼ924 Patent, col. 2:48-53 In response, the system dynamically generates a "customized second document" containing information about transactions relevant to that specific user (e.g., event tickets) and sends a link to this document to the user's phone via a message ʼ924 Patent, col. 2:53-64 This creates a secure and direct pathway for the user to complete a transaction.
• Technical Importance: This approach aimed to enhance e-commerce security and user engagement by replacing generic, multi-step navigation with a direct, personalized, and secure link to a transaction Compl. ¶9

Key Claims at a Glance

• The complaint asserts independent claim 1 Compl. ¶12
• Claim 1 of the '924 Patent is a computer-implemented method comprising the essential elements of:
  • Configuring a service subscriber to be subscribed to receive additional content.
  • Activating one or more customized webpages with a customized actionable item for an e-commerce transaction.
  • The activation includes generating secure access information for the transaction.
  • The actionable item corresponds to prior actions associated with prior transactions performed by the subscriber.
  • Generating a third-party message for the subscriber associated with the customized webpages.
  • Causing transmission of the generated third-party message to the subscriber.
• The complaint does not explicitly reserve the right to assert dependent claims but makes general allegations against "one or more claims" Compl. ¶12

U.S. Patent No. 12,200,165 - "Automated silent network authentication protocol security, verification, and access control for cellular handheld devices" (Issued Jan. 14, 2025)

The Invention Explained

• Problem Addressed: The patent identifies a need for new and useful systems for providing secure access and authentication when using mobile devices, suggesting that conventional methods are insufficient '165 Patent, col. 1:59-62
• The Patented Solution: The invention describes a method for providing secure access to content on a mobile device. The system receives a request for content, generates a customized message with an associated action, and transmits it to a recipient '165 Patent, abstract Upon receiving authorization data from the recipient, the system verifies that the data correlates to the recipient's identity or device, determines a classification for the recipient, and generates and schedules a Rich Communication Service (RCS) message containing the content using a machine learning model '165 Patent, abstract '165 Patent, Fig. 17
• Technical Importance: This technology represents an advanced authentication framework that leverages network-level data and machine learning to provide secure, seamless access control on mobile devices, improving upon traditional password or link-based security Compl. ¶21

Key Claims at a Glance

• The complaint asserts independent claim 1 Compl. ¶24
• Claim 1 of the '165 Patent is a computer-implemented method comprising the essential elements of:
  • Receiving a request to provide content to at least one authorized recipient.
  • Generating a customized message with at least one action associated with the content.
  • Causing transmission of the customized message to the recipient's mobile device.
  • In response to receiving authorization data, verifying the data correlates to the recipient's or device's identity.
  • Determining a classification for the recipient.
  • Generating a Rich Communication Service (RCS) message with the content.
  • Scheduling delivery of the RCS message using a machine learning model based on the classification.
• The complaint alleges infringement of "one or more claims" Compl. ¶24

Multi-Patent Capsule: U.S. Patent No. 12,368,799

• Patent Identification: U.S. Patent No. 12,368,799, "Automated silent network authentication protocol," issued July 22, 2025.
• Technology Synopsis: The patent describes a two-document solution to solve security problems in conventional systems Compl. ¶34 Activation of a hosted input field in a first document provides user information, leading to the generation of a link to a second document that allows the user to securely execute a transaction Compl. ¶34
• Asserted Claims: The complaint specifically alleges infringement of independent claim 12 Compl. ¶37
• Accused Features: The "Salesforce text message marketing system" is accused of infringing the '799 Patent Compl. ¶36

Multi-Patent Capsule: U.S. Patent No. 12,438,978

• Patent Identification: U.S. Patent No. 12,438,978, "Systems and methods for resuming online abandoned journeys," issued October 7, 2025.
• Technology Synopsis: The patent relates to systems and methods for allowing users to resume online activities, such as e-commerce transactions, that were previously abandoned '978 Patent, title This involves using customized messages and secure authentication to re-engage the user.
• Asserted Claims: The complaint specifically alleges infringement of independent claim 1 Compl. ¶49
• Accused Features: The "Salesforce text message marketing system" is accused of infringing the '978 Patent Compl. ¶48

III. The Accused Instrumentality

Product Identification

The accused products are identified as "text message marketing systems," including, without limitation, the "Salesforce text message marketing system" Compl. ¶11 Compl. ¶23

Functionality and Market Context

The complaint alleges that these are systems used for text message marketing Compl. ¶11 The complaint does not provide specific technical details regarding the operation of the accused systems. It makes general allegations that Defendant "makes, uses, offers for sale, sells, and/or imports" these systems, and also engages in their "development, testing, and certification" Compl. ¶11 Compl. ¶12

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint. The complaint incorporates by reference claim chart exhibits for each asserted patent but does not attach them Compl. ¶12 Compl. ¶24 Compl. ¶37 Compl. ¶49 The infringement theory is therefore summarized in prose based on the available allegations.

For both the '924 and '165 Patents, the complaint alleges that the "Accused Instrumentalities satisfy all claim limitations of one or more claims" of the respective patent, including the lead independent claims Compl. ¶12 Compl. ¶24 The allegations are conclusory and do not explain how the accused system purportedly meets each claim element. The narrative theory suggests that the ordinary operation of Salesforce's text message marketing system performs the steps of the patented methods, thereby directly infringing the patents.

• Identified Points of Contention:
  • Factual and Evidentiary Questions: A primary point of contention will be factual. The complaint provides no public-facing evidence (such as screenshots, product documentation, or technical descriptions) to demonstrate how the accused Salesforce system performs the steps recited in the asserted claims. The dispute will likely center on evidence produced during discovery regarding the actual architecture and functionality of the Salesforce system.
  • Scope Questions ('924 Patent): The infringement analysis will raise questions about whether Salesforce's marketing system is triggered by a "hosted field" on a "third party" document and whether it "dynamically generates a customized second document" containing user-specific transaction information, as those terms are understood in the context of the patent.
  • Technical Questions ('165 Patent): The analysis will question whether the security and messaging features of the Salesforce system constitute the specific "silent network authentication protocol" and scheduling "using a machine learning model" as required by the claims, or if they operate on a different technical principle.

V. Key Claim Terms for Construction

For U.S. Patent No. 11,876,924 (Claim 1):

• The Term: "customized webpages" / "customized actionable item"
• Context and Importance: This term is central to the invention's novelty. The degree of "customization" required will be a key issue. If any webpage generated for a specific user qualifies, the claim is broad. If it requires incorporating specific user transaction histories or preferences, the claim is narrower and potentially harder to prove infringement of. Practitioners may focus on this term because the scope of infringement will depend on whether a standard marketing template qualifies as "customized."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself does not specify the degree of customization.
  • Evidence for a Narrower Interpretation: The specification suggests a higher degree of customization, stating the document includes "information about one or more transactions... of interest to an individual associated with the telephone number" ʼ924 Patent, col. 2:54-58 The abstract also links the customization to "one or more transactions... of interest to an individual" '924 Patent, abstract This suggests the customization is based on specific user data, not just a generic template.

For U.S. Patent No. 12,200,165 (Claim 1):

• The Term: "silent network authentication protocol"
• Context and Importance: This term defines the core security mechanism of the invention. Defendant will likely argue its standard security protocols do not meet the specific requirements of a "silent network authentication protocol." The viability of the infringement claim depends on construing this term to read on the accused system's functionality.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term itself is not explicitly defined in a glossary, potentially allowing for a broader application to various background authentication processes.
  • Evidence for a Narrower Interpretation: The abstract describes a specific sequence: "verifying that the authorization data correlates to an identity of the at least one authorized recipient or an identity of the mobile computing device" '165 Patent, abstract The detailed figures, such as Figure 11 ("Silent network Authentication Protocol (SNAP) Access & Security automation layer"), depict a multi-step process involving a "cellular carrier silent network authentication protocol" (1100f), suggesting a specific, network-level verification process beyond simple credential checks '165 Patent, Fig. 11

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Salesforce encourages and instructs its customers to use the accused systems in an infringing manner through "user manuals and instruction materials on its website and/or otherwise provided to customers" Compl. ¶13 Compl. ¶25 Compl. ¶38 Compl. ¶50 Intent is alleged based on knowledge of the patents from "at least the filing and service of this Complaint and/or earlier" Compl. ¶13
• Willful Infringement: The complaint alleges willful infringement for all asserted patents, claiming that Salesforce acted knowingly, willfully, and recklessly with knowledge that its activities infringe the patents-in-suit Compl. ¶17 Compl. ¶29 Compl. ¶42 Compl. ¶54 The basis for knowledge appears to be, at a minimum, post-suit knowledge from the filing of the complaint.

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

The resolution of this dispute will likely depend on the answers to three central questions:

1. An evidentiary question of operation: Given the complaint's lack of specific factual allegations, a threshold issue will be what discovery reveals about the actual technical operation of the Salesforce text message marketing system. Does it, in fact, perform the specific steps of generating customized documents from third-party triggers or employ a silent, network-level authentication protocol?

2. A definitional question of scope: Can the patent term "customized webpage," which the specification links to user-specific transaction data, be construed broadly enough to encompass the types of marketing messages and landing pages generated by the accused Salesforce system?

3. A technical question of equivalence: Does the accused system's security and scheduling functionality perform the specific, multi-step "silent network authentication protocol" and scheduling "using a machine learning model" as required by the '165 patent claims, or is there a fundamental mismatch in the technical processes employed?