Authentixx LLC v. Udemy Inc

A new patent infringement lawsuit filed by the prolific non-practicing entity (NPE) Authentixx LLC targets Udemy, Inc., a major operator in the online education market. Filed on April 22, 2026, the case accuses Udemy's core online course platform of infringing on a patent related to verifying the authenticity of electronic content. Authentixx is a Delaware LLC that has engaged in numerous prior litigation campaigns, asserting patents against a wide range of companies. Udemy is a publicly-traded company that operates a massive open online course (MOOC) marketplace, connecting instructors with students for on-demand learning. The plaintiff is represented by Rabicoff Law LLC, a firm noted for its high volume of patent litigation on behalf of patent assertion entities.

The lawsuit asserts a single patent, U.S. Patent No. 10,355,863, titled "System and method for authenticating electronic content." With a priority date stretching back to 1999, the patent describes a method to combat phishing and spoofing by having a server insert a unique, user-verifiable "authenticity key" or "stamp" into web content before it is sent to the end-user. Authentixx alleges that Udemy's entire online platform—which delivers educational content from its servers to authenticated, logged-in users—infringes upon this patented method. While the complaint itself lacks specific details, referring to an unfiled exhibit for its infringement contentions, the theory appears to target the fundamental architecture of how Udemy authenticates users and serves them content.

The case is procedurally notable due to its venue and assigned judge. It was filed in the Midland-Odessa division of the U.S. District Court for the Western District of Texas and assigned to Judge David Counts. The Western District of Texas became the nation's top patent venue under Judge Alan Albright in Waco, who attracted plaintiffs with patent-friendly rules and fast trial schedules. After a 2022 court order began randomly assigning Waco patent cases, curbing Judge Albright's dominance, Judge Counts emerged as a new preferred judge for patent plaintiffs. As the sole district judge in the Midland-Odessa division, plaintiffs can file there with near certainty of their case being assigned to him. Judge Counts has adopted standing orders for patent cases that are similar to Judge Albright's, making his court an attractive alternative for NPEs like Authentixx. This case is significant as part of a broader Authentixx campaign against numerous online platforms and highlights the ongoing strategic maneuvering for favorable venues in patent litigation.

As of May 1, 2026, the patent infringement litigation between Authentixx LLC and Udemy Inc. is in its earliest procedural stages, with only the initial complaint having been filed. The timeline is exceptionally short, with less than two weeks having passed since the case was initiated.

Chronological Developments

2026-04-22: Complaint Filed
Authentixx LLC filed its patent infringement complaint against Udemy, Inc. in the U.S. District Court for the Western District of Texas, Midland-Odessa Division. The case was assigned to District Judge David Counts. The complaint asserts that Udemy's online course platform infringes U.S. Patent No. 10,355,863, which covers a "system and method for authenticating electronic content." The filing alleges that venue is proper in the district because Udemy maintains an established place of business there. The complaint itself lacks detailed infringement contentions, referring instead to an "Exhibit 2" which was not available on the public docket at the time of filing.

Pending Actions & Outlook

• Answer and Counterclaims: As of May 1, 2026, Udemy has not yet filed its answer or any counterclaims in response to the complaint. Under the Federal Rules of Civil Procedure, a defendant typically has 21 days to respond after being served with the summons and complaint, meaning its deadline has not yet passed.
• Pre-trial Motions: No substantive pre-trial motions, such as motions to dismiss, transfer venue, or stay proceedings, have been filed by either party. It is anticipated that Udemy, a Delaware corporation headquartered in San Francisco, California, may file a motion to transfer the case to a more convenient forum like the Northern District of California. Such motions are common for defendants sued in the Western District of Texas.
• Parallel PTAB Proceedings: A search of the U.S. Patent and Trademark Office's Patent Trial and Appeal Board (PTAB) records reveals no inter partes review (IPR) or other post-grant proceedings filed by Udemy challenging the validity of U.S. Patent No. 10,355,863. It is too early in the litigation for such a filing to be expected, as defendants often wait until after initial pleadings to decide on a PTAB strategy.
• Current Posture: The case remains in its infancy. The next expected development is the filing of an appearance by counsel for Udemy, followed by either an answer to the complaint or pre-answer motions challenging the sufficiency of the complaint or the chosen venue. Given the recent filing date, no other significant legal developments have occurred, and the case has not progressed to claim construction or discovery.

Plaintiff's Counsel of Record

Based on the civil cover sheet and complaint filed on April 22, 2026 (Dkt. 1), the following attorneys have appeared on behalf of the plaintiff, Authentixx LLC. As the case is less than two weeks old, no counsel for the defendant, Udemy Inc., has yet made an appearance.

• Zachary H. Rabicoff | Lead Counsel

  • Firm: Rabicoff Law LLC (Chicago, IL)
  • Note: Rabicoff is a high-volume patent litigator who frequently represents non-practicing entities (NPEs) in campaigns across the country; his firm was noted by Lex Machina as one of the most active in patent litigation. He has led licensing and litigation campaigns against major tech companies including Amazon, Apple, Google, and Samsung.

• David J. Scompart | Local Counsel

  • Firm: Scompart Law PC (Runnels County, TX)
  • Note: Scompart frequently serves as local counsel in the Western District of Texas for out-of-state law firms filing patent infringement lawsuits, partnering with firms like Rabicoff Law that manage large litigation campaigns. His role is to handle local procedural matters and admissions in the district.

Defendant Representatives

As of May 1, 2026, nine days after the complaint was filed, no counsel has made an appearance on the public docket for the defendant, Udemy Inc. A review of the docket for case 7:26-cv-00166 in the U.S. District Court for the Western District of Texas shows only filings from the plaintiff, Authentixx LLC.

Udemy has not yet filed an answer, a waiver of service, or any other responsive pleading that would name its legal representatives for this matter. Typically, a defendant has 21 days after service of the summons and complaint to respond, a deadline which has not yet passed. The next expected filing will likely be a notice of appearance from Udemy's chosen counsel.