Cedar Lane Technologies Inc. v. Citibank, N.A.

I'll research this case and the parties before drafting the overview.

Let me dig into the patent's provenance, the broader campaign, and any PTAB history.

Now let me pin down the patent's provenance, inventors, and any prior assertions or PTAB challenges.

Case Overview — Cedar Lane Technologies Inc. v. Citibank, N.A., No. 7:25-cv-00432 (W.D. Tex.)

The parties. Cedar Lane Technologies Inc. is not an operating company. It is a Canadian patent-holding and assertion entity with a principal place of business listed in its complaints as 471 Baker St., Nelson, British Columbia. Cedar Lane incorporated in 2019 and has been one of the highest-volume patent plaintiffs in the country, filing hundreds of suits (sixteen in a single week in September alone, per Seyfarth's NPE Showcase) and relying primarily on patents acquired from Intellectual Ventures-related entities (Seyfarth/JD Supra NPE Showcase). Its counsel here and in the broader campaign is Isaac Rabicoff of Rabicoff Law LLC, who has drawn judicial criticism in N.D. Cal. (Judge Vince Chhabria sanctioned Cedar Lane and Rabicoff in 2020 for positions taken "in bad faith" and referred Rabicoff to the district's standing committee on professional conduct). The defendant, Citibank, N.A., is the national banking subsidiary of Citigroup and one of the largest retail and institutional broker-dealers and market makers in the United States; it was represented by Matthew W. Cornelia of McGuireWoods LLP (PACER Monitor docket).

The patent and the accused technology. The sole patent-in-suit is U.S. Patent No. 8,577,782, "Trading with conditional offers for semi-anonymous participants," filed April 8, 2010, issued November 5, 2013, naming Christopher R. Petruzzi as inventor, and prosecuted through the Law Office of Donald L. Wenskay (Google Patents; Justia). In one line: it claims a method of associating a trading entity with a persistent but non-identifying identifier, pulling that identifier's trade history, generating a "profile" showing whether that counterparty's trades would be profitable, and letting a "liquidity provider" push a conditional bid/ask offer only to that identifier through an exchange — i.e., letting market makers price-discriminate between "toxic" and "naïve" order flow without learning who the counterparty is (independent claims 1, 19 and 20). The accused instrumentality is Citibank's electronic trading/brokerage infrastructure and customer account and order-execution systems, charted generically in Exhibit 2 of the complaint as practicing the claimed "semi-anonymous" profiling-and-targeted-offer functionality; consistent with Cedar Lane's template complaints nationally, no specific product was named in the body of the pleading, and the substance sits entirely in the claim chart. Note that the patent's recorded status is "active" with an estimated expiry of April 8, 2030, and Google Patents shows a later family publication (US2023/0281171A1) and a "reinstated" status — I could not confirm the maintenance-fee/reinstatement history or the full assignment chain from Intellectual Ventures/Petruzzi to Cedar Lane from the sources reviewed, so treat the provenance detail as unverified.

Procedural posture and why it matters. Filed September 22, 2025 in the Western District of Texas, San Antonio-based docket office code "7" (the Midland–Odessa Division), and assigned to Judge David Counts, with referral to Magistrate Judge Derek T. Gilliland (Order and Advisory, Doc. 9, Nov. 7, 2025). Citibank was served September 30, 2025; its responsive deadline was extended by unopposed motion to November 20, 2025 (Text Order, Doc. 8, Oct. 15, 2025) — the same day Cedar Lane filed its Rule 41(a)(1)(A)(i) notice of voluntary dismissal with prejudice (Doc. 10), which the court recognized as self-effectuating under In re Amerijet Int'l, 785 F.3d 967 (5th Cir. 2015), dismissed the case, and ordered each side to bear its own costs and fees (Doc. 11, signed by Judge Counts Nov. 21, 2025). No answer was served, no motion to dismiss or transfer was decided, and no claim construction occurred. The case is notable less for what it decided than for what it reveals: it is a single thread in Cedar Lane's 2025–2026 assertion wave against the financial-services industry over the '782 patent — the same day it sued Citibank it also sued Cantor Fitzgerald (S.D.N.Y. 1:25-cv-07841, dismissed without prejudice ten days later), Beech Hill Securities, Corinthian Partners, and others, with the campaign beginning in the Eastern District of Texas in February 2025 against trading firms (e.g., 2:25-cv-00230, 2:25-cv-00231) and later expanding to BNY Mellon, TIAA-CREF, Bank of America, and dozens of regional broker-dealers in S.D.N.Y., E.D.N.Y., N.D. Ill. and D. Del. (Law360 case page). The near-uniform early exit pattern — dismissals with or without prejudice within 10 to 120 days, no merits ruling anywhere — is the classic high-volume, low-dollar licensing model, and it means the '782 patent's validity and scope remain wholly unadjudicated (no IPR or other PTAB challenge to the '782 patent surfaced in my search, which is itself notable given Cedar Lane's history of having claims invalidated, e.g., Unified Patents, LLC v. Cedar Lane Techs., IPR2020-00006, FWD Feb. 12, 2021 holding claims of U.S. 7,173,177 unpatentable). Because the dismissal was with prejudice, Cedar Lane's claims against Citibank are extinguished with res judicata effect, but the patent remains live and assertable against the rest of the market — a meaningful risk-management signal for banks, dark-pool operators, and broker-dealers whose order-handling systems tier or customize pricing by customer, and a live candidate for an ex parte reexam or IPR by a trade association or a Unified Patents-style defensive aggregator.

Sourcing notes: party names, case number, court and termination date are taken from the case metadata; docket events are from PACER Monitor/RPX and the Patsnap litigation record (which quotes the dismissal text verbatim). The division designation and judge assignment are grounded in the docket (Judge Counts; referral to Judge Gilliland) with the division inferred from the "7" office code — I did not independently pull the civil cover sheet. Settlement terms were not disclosed in any source reviewed, so no inference about a payment should be drawn from the with-prejudice dismissal.

I'll research this case across the docket, PTAB, and secondary sources.

Executive summary

Cedar Lane Techs. v. Citibank (W.D. Tex. No. 7:25-cv-00432) is a 59‑day case that never left the pleadings stage. Cedar Lane filed a one-count complaint asserting U.S. Patent No. 8,577,782 on 2025‑09‑22; Citibank obtained a single agreed extension of its response deadline; and Cedar Lane voluntarily dismissed with prejudice on 2025‑11‑20 — the very day Citibank's answer was due — before any answer, counterclaim, Rule 12 motion, transfer motion, stay motion, Markman proceeding, or discovery exchange. There was no PTAB proceeding on the '782 patent. The case is best understood not as a litigation with "developments" but as one data point in a high-volume, fast-settling assertion campaign over a single trading-technology patent.

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1. Filing and initial pleadings

2025‑09‑22 — Complaint filed (Doc. 1). Cedar Lane Technologies Inc. (Canada) filed a five-page, single-count complaint for patent infringement in the W.D. Tex., Midland‑Odessa Division, assigned to Judge David Counts. Counsel: Isaac Rabicoff, Rabicoff Law LLC (Chicago). Summons issued same day (Doc. 6); Rule 7 disclosure statement (Doc. 3); AO‑120 form forwarded to the USPTO (Doc. 4).

• Patent asserted: U.S. 8,577,782, "Trading with conditional offers for semi-anonymous participants," filed 2010‑04‑08, issued 2013‑11‑05; app. 12/756,929; originally prosecuted by the Law Office of Donald L. Wenskay; estimated expiry 2030‑04‑08.
• Theory: Direct and induced infringement of "one or more claims," with the asserted claims and accused products identified only by cross-reference to Exhibit 2 (a claim chart) rather than in the body of the complaint. Independent claim 1 is a method claim requiring (i) associating a trading entity with an identifier via a hardware processor, (ii) acquiring trade history for that identifier, and (iii) receiving a conditional offer from a liquidity provider based on a profile indicating whether the entity's trades "would generate a profit," the offer being made only to that entity and processed through an exchange.
• Relief sought: Declaratory judgment of validity and infringement, damages/accounting under § 284, interest and costs, and an express request that the case be declared exceptional under § 285 with fees.
• No specific Citibank product (e.g., a named trading venue or order-handling system) was identified in the public filings reviewed; the complaint's infringement allegations are entirely chart-dependent.

2025‑09‑30 — Service (Doc. 7). Citibank served; answer due 2025‑10‑21.

2025‑10‑10 / 2025‑10‑15 — Appearance and single extension. Citibank appeared through Matthew William Cornelia, McGuireWoods LLP (Doc. 8, unopposed motion for extension), which Judge Counts granted by text order on 2025‑10‑15, extending the response deadline to 2025‑11‑20.

Answer / counterclaims: none. The docket confirms no answer, no Rule 12 motion, and no counterclaims were ever served. That fact is expressly recited in the dismissal order and is what made Rule 41(a)(1)(A)(i) available.

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2. Pre-trial motions of substance

None. No motion to dismiss, motion to transfer venue (§ 1404/1406), motion to stay pending IPR, motion for summary judgment, or motion to sever was filed by either side. The only contested-adjacent filing in the entire docket is Citibank's unopposed extension motion (Doc. 8). This is a materially different posture from a typical NPE case against a major bank, where one would expect at minimum a § 101 motion or a venue challenge.

Administrative docket events: 2025‑11‑07 — Order and Advisory (Doc. 9) referring the case to Magistrate Judge Derek T. Gilliland under the W.D. Tex. practice of referring pretrial matters.

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3. Claim construction (Markman)

Did not occur. No scheduling order, no Joint Claim Construction Statement, no Markman briefing, no hearing, and no claim construction order issued. The '782 patent's claim terms — including "profile containing information that indicates whether said trading transactions ... would generate a profit" and "semi-anonymous" — were never construed by any court in this case.

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4. Discovery milestones

None of strategic significance. No Rule 26(f) conference, no initial disclosures, no discovery plan, no written discovery, no depositions, and no case management order appear on the docket. The case was dismissed roughly two months after filing, before the Rule 16 conference that would have set a discovery schedule.

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5. Trial, verdict, post-trial motions

None. No trial setting, no verdict, no JMOL/new-trial motion, and no fee motion. Indeed, the court's dismissal order forecloses fee-shifting in either direction by providing that each party bears its own costs, expenses, and attorney fees, and denying all pending motions as moot.

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6. Final disposition

2025‑11‑20 — Notice of Voluntary Dismissal With Prejudice (Doc. 10), filed by Rabicoff under Fed. R. Civ. P. 41(a)(1)(A)(i), with a proposed order attached. Filed on the extended answer deadline.

2025‑11‑21 — Order Dismissing Case (Doc. 11), signed by Judge Counts, and Doc. 12, Report on Patent/Trademark (AO‑120) sent to the USPTO. The order's operative reasoning:

"Rule 41(a)(1)(A)(i) allows a plaintiff to voluntarily dismiss an action ... by filing a notice of dismissal before the opposing party serves an answer or a motion for summary judgment. ... The Defendant has not served an answer or a motion for summary judgment. Plaintiff's notice is therefore 'self-effectuating and terminates the case in and of itself; no order or other action of the district court is required.' In re Amerijet Int'l, Inc., 785 F.3d 967, 973 (5th Cir. 2015) ... Each party shall bear its own costs, expenses, and attorney fees. All pending motions, if any, are DENIED as MOOT."

• Date discrepancy to note: the case metadata lists termination as 2025‑11‑20 (the date the self-effectuating notice was filed, which is legally the operative termination date under Amerijet); PACER and Judge Counts's chambers-style docket record the case as closed 2025‑11‑21 (the date of the ministerial dismissal order and AO‑120 transmittal). Both dates are defensible; the notice date is the legally correct one.
• Effect: dismissal with prejudice is an adjudication on the merits for claim-preclusion purposes as to Cedar Lane's claims against Citibank; Cedar Lane cannot re-assert the '782 patent against Citibank. No finding of invalidity, unenforceability, or non-infringement was made, so the patent's scope and validity remain entirely open as against every other party. The express "each party bears its own" cost/fee provision also means Citibank cannot pursue a § 285 fee award despite the early exit — a notable concession given Cedar Lane's § 285 prayer.
• No appeal was taken and none was possible in a meaningful sense: a plaintiff cannot appeal its own voluntary dismissal with prejudice absent some adverse interlocutory ruling, and there was none here.
• Settlement terms: not disclosed. The timing (dismissal with prejudice on the answer deadline, mutual cost-bearing, no motion practice) is consistent with a negotiated resolution or license, but I found no public confirmation of a settlement, license, or payment. It should be characterized as an undisclosed resolution rather than asserted as a settlement.

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7. Parallel PTAB proceedings

No IPR, PGR, or CBM proceeding on U.S. 8,577,782 was identified. Searches of PTAB materials, Unified Patents' PTAB/litigation docket tracking, and the litigation databases returned no petition, institution decision, or final written decision directed to the '782 patent, and no petitioner (CUSIP- or otherwise) is associated with it. Because Citibank never answered, its § 315(b) one-year clock ran from service (2025‑09‑30) but no petition was ever filed within the case's life; any later petition would have to come from a different real party in interest.

Relevant context — Cedar Lane has been PTAB-victim before, just not on this patent. In Unified Patents, LLC v. Cedar Lane Technologies Inc., the PTAB issued a 2021‑02‑12 final written decision holding the asserted independent claim of U.S. 7,173,177 unpatentable — a patent Cedar Lane had acquired from AVInnov/Intellectual Ventures and asserted against Charter/Spectrum, T-Mobile, Disney, Dish, and CBS. That history is the obvious explanation for why the '782 campaign has been structured as short, cheap, quick-turnover assertions rather than sustained litigation: Cedar Lane's portfolio has a demonstrated IPR mortality rate, and a defendant that files an IPR creates existential risk to the asserted patent. No defendant in the '782 campaign appears to have taken that step, which is itself the single most consequential strategic fact about this litigation family.

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8. Campaign context (why this case looks the way it does)

The Citibank case is one of dozens of substantively identical '782 suits filed by Rabicoff Law, which follow a template: same five-page complaint, same Exhibit 1/Exhibit 2 structure, no named accused product, jury demand, § 285 prayer.

• First wave, February 2025: Cedar Lane v. Cobra Trading (E.D. Tex. 2:25-cv-00223, 2025‑02‑19); v. Charles Schwab Corp. (E.D. Tex. 2:25-cv-00233, 2025‑02‑24); v. Hilltop Securities (N.D. Tex. 3:25-cv-00483, 2025‑02‑25 — dismissed with prejudice by stipulation 2025‑06‑12, each side bearing its own fees).
• Second wave, 2025‑09‑22 (the Citibank wave): Citibank (W.D. Tex. 7:25-cv-00432) plus a cluster of brokerage/asset-management defendants in S.D.N.Y. — Cantor Fitzgerald (1:25-cv-07841), Beech Hill Securities (1:25-cv-07840), Clear Street (1:25-cv-07846), City National Rochdale (1:25-cv-07845), Corinthian Partners (1:25-cv-07848), Eleven Labs (1:25-cv-07842). Law360 covered the wave on 2025‑09‑23 under the headline "Cantor Fitzgerald, Citibank Hit With Trading Patent Suits."
• Outcomes track the Citibank pattern. Cantor Fitzgerald was voluntarily dismissed without prejudice on 2025‑10‑02 (Judge Dale E. Ho) — i.e., ten days after filing, and notably without prejudice, unlike Citibank. Later-filed cases continue through 2026 across S.D.N.Y., E.D.N.Y., E.D. Tex., N.D. Ill., D. Del., and

Counsel of Record for Plaintiff Cedar Lane Technologies Inc.

Bottom line: Only one attorney appears for the plaintiff on this docket — Isaac Philip Rabicoff of Rabicoff Law LLC (Chicago). He signed the complaint, the Rule 7 disclosure statement, the AO 120 form, and the notice of voluntary dismissal himself. No separate local counsel, no firm co-counsel, and no in-house counsel appear of record. (PACER Monitor public docket, 7:25-cv-00432; PatSnap case record)

Docket basis

• Doc. 1 – Complaint for Patent Infringement, filed 9/22/2025 ("(Rabicoff, Isaac)"), together with Exhibits 1–2 (the '782 patent and a claim chart) — the same filing package used across Cedar Lane's '782 campaign.
• Doc. 2 – Notice of Attorney Appearance by Isaac Rabicoff on behalf of Cedar Lane Technologies Inc.
• Doc. 3 – Rule 7 disclosure statement; Doc. 4 – AO 120 patent form (both by Rabicoff).
• Docs. 5–9 – summons/service, and the defendant's unopposed extension motion (deadline extended to 11/20/2025).
• Doc. 10 – Notice of Voluntary Dismissal by Cedar Lane Technologies Inc. (Rabicoff, Isaac), filed 11/20/2025, with prejudice under Rule 41(a)(1)(A)(i).
• The court (Judge David Counts, referral to Mag. J. Derek T. Gilliland) entered the dismissal text order confirming the notice was self-effectuating and that each side bears its own costs.

Sources: PACER Monitor docket page; RPX Empower docket summary; Law360 case page.

Additional context on the plaintiff's representation

• No local counsel appeared. Rabicoff is not listed as admitted in W.D. Tex. (his stated admissions are Illinois, N.D. Ill., E.D. Tex., W.D. Wis., the Seventh Circuit, the Federal Circuit, and the Supreme Court). The docket as reflected in the public databases shows no pro hac vice motion and no Texas local-counsel appearance — the case closed in 60 days, before any such step became necessary. This is consistent with Rabicoff Law's practice of filing and dismissing Cedar Lane cases quickly, often without ever perfecting W.D. Tex. admission.
• The same counsel handles the entire '782 campaign. Rabicoff is plaintiff's counsel in the parallel S.D.N.Y., E.D.N.Y., E.D. Tex., N.D. Ill., and D. Del. suits asserting US 8,577,782 against financial-services defendants (e.g., Cedar Lane v. Clear Street, 1:25-cv-07846 (S.D.N.Y.); Cedar Lane v. Percheron, 1:25-cv-09531 (S.D.N.Y.); Cedar Lane v. LaSalle St. Securities, 1:26-cv-00721 (N.D. Ill.); Cedar Lane v. Toronto-Dominion Bank, 2:26-cv-00044 (E.D. Tex.)) — see Stanford NPE Litigation Database, patent 8,577,782. CourtListener party pages in those cases give his direct contact block: (773) 669-4590, Rabicoff Law LLC, 4311 N Ravenswood Ave, Suite 315, Chicago, IL 60613.
• Adverse history worth noting for impeachment/credibility purposes. A published practitioner commentary reports that in 2020 Judge Vince Chhabria (N.D. Cal.) sanctioned Cedar Lane and Mr. Rabicoff for "taking positions in his filings that were objectively frivolous … and did so in bad faith," noted he was not admitted in that district, and referred him to the court's standing committee on professional conduct — see NPE Showcase – Cedar Lane Technologies, Legal500/Lexology (Oct. 6, 2022), https://www.legal500.com/intelligence/united-states/intellectual-property/npe-showcase-–-cedar-lane-technologies. I did not independently pull the underlying N.D. Cal. sanction order, so treat the specifics as reported rather than verified from the order itself.

Caveats

• I could not review the full PACER docket directly (paywalled); the entry list above comes from the public PACER Monitor/RPX summaries and the verbatim order text reproduced in the PatSnap case page. There is no indication of any sealed filing or of any attorney appearance beyond Doc. 2.
• Defendant Citibank was represented by Matthew William Cornelia of McGuireWoods LLP — included only for completeness, since the question concerns plaintiff's counsel.
• Cedar Lane's corporate/founder figure Greg Benoit is often described in NPE literature as Cedar Lane's principal (a Canadian lawyer), but he did not appear as counsel of record in this case and should not be listed as such.

I'll research the docket and counsel of record for this case.

I have a lead. Let me verify against the docket sheet and firm records.

Let me pull the RECAP/CourtListener docket to confirm exactly which attorneys entered appearances.

Counsel of Record for Citibank, N.A. — 7:25-cv-00432 (W.D. Tex.)

Bottom line: Exactly one attorney is attributable to Citibank on the public record of this case: Matthew W. ("Matt") Cornelia of McGuireWoods LLP (Dallas, TX office). He is the sole signatory on the only defense filing in the case, and no other defense attorney, local counsel, or in-house lawyer appears anywhere in the docket before the case closed.

Attorney table

Docket support

• Doc. 8 — "Unopposed MOTION for Extension of Time to File Answer re [1] Complaint by Citibank, N.A. … (Cornelia, Matthew)," filed 10/10/2025. This is the only defense-side filing in the case and the only docket entry naming defense counsel.
• Text Order entered 10/15/2025 granting Doc. 8 and extending Citibank's response deadline to November 20, 2025 (Judge David Counts).
• Doc. 10 (11/20/2025): Cedar Lane filed its Rule 41(a)(1)(A)(i) notice of voluntary dismissal with prejudice the same day Citibank's extended deadline ran; Doc. 11 (11/21/2025): Order Dismissing Case; Doc. 12: AO-120 report to the PTO.
• Source: PacerMonitor public docket page for Cedar Lane Technologies Inc. v. Citibank, N.A., No. 7:25-cv-00432 (D. Tex.), https://api.pacermonitor.com/public/case/60259936/Cedar_Lane_Technologies_Inc_v_Citibank,_NA (reflecting Judge David Counts, referred to Magistrate Judge Derek T. Gilliland); corroborated by PatSnap's case profile listing "Defendant counsel — Matthew William Cornelia — McGuireWoods LLP," https://www.patsnap.com/resources/blog/litigation/cedar-lane-technologies-v-citibank-trading-platform-patent-patsnap/; Law360 case page: https://www.law360.com/cases/68d18141275816cbcd389330.

Important qualifications (please read before relying on this)

1. No formal Notice of Attorney Appearance for defense counsel appears in the public docket summary. The docket lists a Notice of Attorney Appearance (Doc. 2) only for plaintiff's counsel, Isaac Rabicoff (Rabicoff Law LLC). Cornelia appears through his signature block on Doc. 8 and through the court's docketing of "Cornelia, Matthew" as the filing attorney. It is possible an appearance was entered in a form not captured by the third-party docket mirror; I could not verify against raw PACER, and CourtListener/RECAP does not appear to have a docket sheet for this case.
2. No local W.D. Tex. counsel and no pro hac vice motion are reflected on the docket. McGuireWoods' Dallas office satisfies in-state practice needs, and the case died before any admission issues were tested.
3. No in-house Citibank attorney (e.g., Citigroup legal department) appears on the record. Any in-house involvement was behind the scenes and is not documented in any public filing I located.
4. Firm/office attribution is from professional directories, not the docket. Cornelia is listed at McGuireWoods' Dallas office by Best Lawyers (https://www.bestlawyers.com/lawyers/matthew-w-matt-cornelia/[300914](/patent/300914)) and Super Lawyers, both of which still show a parallel Winstead PC Dallas profile (https://www.winstead.com/People/Matt-Cornelia) — consistent with a lateral move; one low-quality aggregator (huski.ai) lists a McGuireWoods Pittsburgh/Virginia-area contact, so treat the exact office as Dallas (most likely) rather than certain. McGuireWoods is headquartered in Richmond, Virginia, and its patent litigation team is national, so staffing may have crossed offices.
5. Nothing about this engagement was sealed. The case was simply too short-lived (60 days, no answer filed, no motion to dismiss, no IPR petition located) for a fuller defense team to surface. Because dismissal was under Rule 41(a)(1)(A)(i) with prejudice and each side bore its own fees, there is no fee or sanctions record revealing additional counsel.

Practical takeaway for your analysis

The counsel picture here is a single-attorney placeholder: an early, unopposed extension motion followed immediately by plaintiff's self-effectuating dismissal. That pattern — dismissal with prejudice on the eve of the extended answer deadline — is consistent with a pre-suit or very early resolution, but no settlement terms, license, or payment are disclosed anywhere in the public record, so treat any such inference as unsourced. If you need the identity of the full defense team (including any in-house or co-counsel who never appeared), that information is not in the public docket and would require either a PACER pull of the Doc. 8 PDF signature block or direct inquiry.