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., 08/07/2026
• Case Name: IQX Corp. v. Salesforce, Inc.
• Venue Allegations: Venue is alleged to be proper in the Western District of Texas because Defendant Salesforce resides in the District and/or has committed acts of infringement and maintains a regular and established place of business in the District.
• Core Dispute: Plaintiff alleges that Defendant's text message marketing systems infringe four U.S. patents related to secure, customized messaging, user authentication, and the resumption of abandoned online user journeys.
• Technical Context: The technology relates to secure and personalized mobile messaging for e-commerce, aiming to improve user engagement and transaction security by delivering customized content and using silent authentication methods.
• Key Procedural History: This action was initiated via a First Amended Complaint, which alleges that the filing of the original complaint in the same action placed Defendant on notice of the asserted patents and its alleged infringement.

Case Timeline

Date	Event
2018-09-27	Priority Date for '924, '165, '799, '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
2026-08-07	Complaint Filing Date

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

U.S. Patent No. 11,876,924 - "Secure transactions using customized webpages"

• Issued: January 16, 2024.

The Invention Explained

• Problem Addressed: The patent's background section describes the security risks and cumbersome user experience of conventional online transaction systems (Compl. ¶9). It notes that networks lacked a secure mechanism to synchronize user identity and transaction states across different domains, and that static, one-size-fits-all webpages resulted in a negative user experience (Compl. ¶9; '924 Patent, col. 1:29-41).
• The Patented Solution: The invention describes a computer system that facilitates transactions by responding to a user's expression of interest from a third-party document (e.g., a website). The system receives the user's telephone number, dynamically generates a "customized second document" (e.g., a webpage) with information relevant to that user, and sends a message containing a link to this customized document ('924 Patent, abstract). This process allows the user to directly access relevant, actionable content in a secure manner ('924 Patent, col. 4:56-col. 5:20).
• Technical Importance: This approach aimed to solve technical challenges in multi-domain network communication by creating a secure, personalized path for e-commerce transactions initiated from third-party platforms (Compl. ¶9).

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶12).
• Essential elements of claim 1, a computer-implemented method, include:
  • Configuring a service subscriber to receive additional content upon determining the subscriber has previously provided authentication information.
  • Activating one or more customized webpages with a customized actionable item for an e-commerce transaction, where the item corresponds to prior actions by the subscriber.
  • Generating secure access information for the transaction.
  • Generating a third-party message for the subscriber that includes the actionable item.
  • Causing transmission of the message to the subscriber.
• The complaint does not explicitly reserve the right to assert dependent claims.

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

• Issued: January 14, 2025.

The Invention Explained

• Problem Addressed: The patent addresses the need for new and useful methods for secure access and authentication when using mobile devices for e-commerce, noting the security risks and cumbersome user experience of conventional systems ('165 Patent, col. 1:36-58).
• The Patented Solution: The invention describes a system that uses a "silent network authentication protocol" to authenticate a user's client device. The protocol involves generating a security code packet with the user's network credential and a device carrier identifier, transmitting it to an authentication service provider (e.g., a mobile telephone service provider), and receiving an indication of whether the credentials match the provider's existing records ('165 Patent, FIG. 18, steps 1810-1818). This silent verification allows the user to securely perform transactions without needing to manually re-authenticate ('165 Patent, col. 2:24-43).
• Technical Importance: This technology sought to provide a frictionless yet secure authentication method for mobile transactions by leveraging the user's existing relationship with their cellular carrier for identity verification.

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶24).
• Essential elements of claim 1, a computer-implemented method, include:
  • Receiving a request to provide content to an authorized recipient.
  • Generating a customized message with an action associated with the content.
  • Causing transmission of the message to the recipient's mobile device.
  • In response to the action being selected, requesting and receiving authorization data.
  • Verifying the authorization data correlates to the recipient's identity.
  • Determining a classification for the recipient.
  • Generating a Rich Communication Service (RCS) message with the content.
  • Scheduling the delivery of the RCS message using a machine learning model based on the classification.
• The complaint does not explicitly reserve the right to assert dependent claims.

Multi-Patent Capsule

• Patent Identification: U.S. Patent No. 12,368,799, "Automated silent network authentication protocol," issued July 22, 2025.
• Technology Synopsis: The patent addresses the security and convenience problems of conventional document linking for transactions (Compl. ¶34). It proposes a "two-document solution" where a user indicates interest in a first document, and a second document containing a link for a transaction is then provided, addressing security challenges in multi-domain network communication (Compl. ¶34).
• Asserted Claims: The complaint asserts independent claim 12 (Compl. ¶37).
• Accused Features: The "Salesforce text message marketing system" is accused of infringing by satisfying the claim limitations (Compl. ¶¶36-37).

Multi-Patent Capsule

• Patent Identification: U.S. Patent No. 12,438,978, "Systems and methods for resuming online abandoned journeys," issued October 7, 2025.
• Technology Synopsis: The technology appears to focus on re-engaging users who have abandoned an "online journey," such as an e-commerce checkout process. The patent describes methods for resuming these abandoned journeys, presumably through targeted messaging and secure access links.
• Asserted Claims: The complaint asserts independent claim 1 (Compl. ¶49).
• Accused Features: The "Salesforce text message marketing system" is accused of infringing the patent's claims for resuming these online journeys (Compl. ¶¶48-49).

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentality as Defendant's "text message marketing systems," specifically including the "Salesforce text message marketing system" (Compl. ¶11; Compl. ¶23; Compl. ¶36; Compl. ¶48).

Functionality and Market Context

The complaint alleges these systems are used for marketing via text message (Compl. ¶11). The infringement allegations suggest these systems provide functionalities for sending messages that link to customized webpages for e-commerce, employ authentication protocols, and facilitate the resumption of user activities, such as abandoned online transactions (Compl. ¶9; Compl. ¶¶23-24; Compl. ¶34; Compl. ¶48).

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that claim charts demonstrating infringement are attached as exhibits; however, these exhibits were not provided with the complaint document (Compl. ¶12; Compl. ¶24). Therefore, the following is a prose summary of the infringement allegations based on the narrative provided in the complaint.

'924 Patent Infringement Allegations

The complaint alleges that the Accused Instrumentalities infringe the '924 Patent by implementing a system that solves the same problem identified in the patent: the insecurity and inconvenience of conventional third-party messaging for e-commerce (Compl. ¶9). The complaint asserts that the accused systems provide for "secure access to customized webpages" and generate "secure access information for performing an e-commerce transaction," thereby mapping to the patent's claimed solution for overcoming the technical challenges of multi-domain network communication (Compl. ¶9). The infringement theory appears to rest on the allegation that the Salesforce system, like the claimed invention, creates a secure and customized transaction path initiated via a text message (Compl. ¶¶9-12).

'165 Patent Infringement Allegations

The complaint's infringement allegations for the '165 Patent are more general. It asserts that the Accused Instrumentalities satisfy all limitations of the claims, including claim 1, which relates to "automated silent network authentication protocol security, verification, and access control" (Compl. ¶¶20-21; Compl. ¶24). The infringement theory suggests that the Salesforce system employs an authentication and messaging framework that corresponds to the patent's claimed method of receiving a content request, generating a customized message, verifying the recipient's identity upon interaction, classifying the recipient, and then scheduling a Rich Communication Service (RCS) message using a machine learning model ('165 Patent, claim 1).

Identified Points of Contention

• Scope Questions: The analysis may raise questions about the scope of key terms. For the '924 Patent, a question is whether the accused system's webpages meet the patent's requirements for a "customized second document" that is "dynamically generate[d]" in response to a specific trigger. For the '165 Patent, a central question will be whether the authentication methods used in the accused system perform the specific steps of the claimed "silent network authentication protocol" and "machine learning model"-based scheduling.
• Technical Questions: A key factual question will be what evidence demonstrates that the accused system performs the specific sequences of operations required by the claims. For instance, for the '924 Patent, what is the evidence that activation of a "hosted field" on a third-party site triggers the generation of a customized page? For the '165 Patent, what proof will be offered that the accused system performs the claimed multi-step process of verification, classification, and scheduled RCS delivery?

V. Key Claim Terms for Construction

The Term: "customized second document" ('924 Patent, claim 1)

• Context and Importance: This term is central to the '924 Patent's inventive concept. The degree of "customization" required will be a key point of dispute. Practitioners may focus on this term because the infringement argument depends on whether the accused system's landing pages are merely personalized with generic data or are "customized" in the specific manner envisioned by the patent, potentially based on prior user actions.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the document as including "information about one or more transactions...of interest to an individual" ('924 Patent, col. 2:54-58), which could support a broad interpretation covering any page with user-relevant information.
  • Evidence for a Narrower Interpretation: The specification also states the customized webpage may be "updated based on user habits, history, preferences, information from third-party application programming interfaces (APIs), etc." ('924 Patent, col. 10:52-56). This could support a narrower construction requiring a specific level of dynamic curation based on a user's historical data.

The Term: "silent network authentication protocol" ('165 Patent, claim 1 is silent on this term, but the patent is titled with it and the concept is central)

• Context and Importance: This term defines the core security mechanism of the '165 Patent. The case may turn on whether the authentication process in the accused system meets the specific technical requirements of this protocol.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term "silent" itself could be argued to broadly cover any authentication that occurs in the background without direct user input, such as entering a password.
  • Evidence for a Narrower Interpretation: The detailed description and Figure 18 of the '165 patent detail a specific multi-step protocol involving the generation of a "security code packet" with a "subscriber network credential" and a "client device carrier identifier," which is then transmitted to an "authentication service provider" for matching against "existing records" ('165 Patent, FIG. 18, steps 1810-1818). This detailed embodiment may be used to argue for a narrow construction requiring these specific technical steps.

VI. Other Allegations

Indirect Infringement

The complaint alleges that Salesforce induces infringement by providing "user manuals and instruction materials" that actively encourage and instruct its customers on how to use the Accused Instrumentalities in a way that directly infringes the patents-in-suit (Compl. ¶13; Compl. ¶25; Compl. ¶38; Compl. ¶50).

Willful Infringement

The willfulness allegations are based on post-suit knowledge. The complaint asserts that Salesforce has had knowledge of the asserted patents and their infringement since "the filing and service of the original Complaint in this action" and has "knowingly, willfully, recklessly, egregiously and wantonly" continued its allegedly infringing activities (Compl. ¶17; Compl. ¶29; Compl. ¶42; Compl. ¶54).

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

1. A core issue will be one of definitional scope: can patent terms rooted in specific technical processes, such as "customized second document" and "silent network authentication protocol", be construed to cover the potentially more general-purpose features of the accused Salesforce text message marketing platform?
2. A key evidentiary question will be one of functional correspondence: what evidence will be presented to prove that the accused system performs the specific, ordered sequence of operations required by the asserted claims-such as dynamically generating a webpage in direct response to a specific trigger, or executing the multi-step silent authentication process by communicating with a mobile carrier-versus merely achieving a similar commercial result through different technical means?
3. A third question relates to patentability overlap: given the thematic similarities across the four asserted patents regarding secure, customized messaging and authentication, the case may involve significant disputes over how the claim scope of each patent is distinct from the others and from the prior art, potentially leading to validity challenges.