Cedar Lane Technologies Inc. v. Hilltop Securities Inc

I'll research this case and its parties, patent, and procedural context.

Now let me dig into the parties, the patent's provenance, and the broader assertion campaign.

Let me verify the patent's provenance and check for PTAB/IPR activity.

Case Overview: Cedar Lane Technologies Inc. v. Hilltop Securities Inc., No. 3:25-cv-00483 (N.D. Tex.)

The parties. Cedar Lane Technologies Inc. is a Canadian patent-holding entity with a stated principal place of business in Nelson, British Columbia (the boilerplate party paragraph in Cedar Lane's complaints; the same language appears across the campaign). It is a classic non-practicing entity: the Stanford NPE Litigation Database categorizes Cedar Lane as a patent asserter sourcing its suits from acquired patents, and its docket history spans hundreds of assertions on unrelated technologies — e.g., U.S. 10,346,105 (remote printer/server communication) and 6,516,147 (scene recognition) — before it pivoted to financial-technology patents in 2025. Its filings are driven by Isaac Philip Rabicoff of Rabicoff Law LLC (Chicago), with DNL Zito (Washington, D.C.) also appearing in the litigation databases. Hilltop Securities Inc., by contrast, is a genuine operating company: a Dallas-based full-service broker-dealer and municipal investment bank, wholly owned by publicly traded Hilltop Holdings Inc. (NYSE: HTH), formed in 2015 from the combination of Southwest Securities, First Southwest Company and SWS, with lineage to 1946. It underwrites and trades municipal bonds, runs fixed-income and structured-finance desks, provides retail wealth management and correspondent clearing, and holds Federal Reserve primary-dealer status. At year-end 2025, per Hilltop Holdings' Form 10-K, Hilltop Securities reported $2.9 billion in total assets and $220.6 million in net capital, with roughly 790 employees across 39 offices in 16 states. Per litigation-database records (not independently confirmed on PACER), Hilltop was represented by Amy E. LaValle of Frost Brown Todd.

The patent and the accused technology. One patent was asserted: U.S. 8,577,782, "Trading with conditional offers for semi-anonymous participants" (Appl. No. 12/756,929, filed April 8, 2010; issued November 5, 2013; G06Q 40/00; expiration c. April 2030). In one line: it claims a computer-implemented method in which a trading entity is tagged with a persistent (but not fully identifying) identifier, its transaction history is captured against that identifier, a profile is generated indicating whether trading with that entity would be profitable, and a liquidity provider then issues a conditional, targeted offer that is made only to that entity and executed through an exchange handling instruments with a bid/offer spread. The specification frames the problem in terms of market makers' exposure to "toxic traders" in anonymous electronic markets and proposes differentiated, counterparty-specific pricing without revealing identity. Independent claim 1 requires each step be performed by "a processor implemented at least partly in hardware" — a limitation tailored to the §101 era. The complaint itself pleads infringement only generically: it names no accused product in the body, instead incorporating by reference an "Exhibit 2" claim chart and referring to "Exemplary Defendant Products" — the same five-page, template complaint Cedar Lane used across the campaign. Per the Patsnap case record, the accused functionality is described as "trading with conditional offers for semi-anonymous participants," and no validity challenge is recorded. Note that the ’782 patent does not appear to have been litigated, construed, or subjected to an AIA review before February 2025 — I could not locate any PTAB proceeding on it, and the complaints themselves reference none.

Procedural posture, venue, and why it matters. Filed February 25, 2025 in the Northern District of Texas and assigned to Judge Karen Gren Scholer (the "3:" docket prefix denotes the Dallas Division, which is where Hilltop's 6565 Hillcrest Avenue headquarters sits). Both sides demanded a jury, and Hilltop answered and asserted counterclaims, which appear on the docket as Hilltop as counter-claimant. The case lasted 107 days: it closed June 12, 2025 on a Rule 41(a)(1)(A)(ii) stipulation providing that "the Parties hereby stipulate to dismiss this action, including all of Plaintiff's claims against Defendant and all of Defendant's counterclaims against Plaintiff, with prejudice," each side bearing its own costs, expenses and fees. No claim construction, no §101 ruling, no damages award, and no merits decision on infringement or validity issued. Venue matters here for two reasons. First, post-TC Heartland an NPE must sue where the defendant resides or has a regular place of business, so Hilltop's Dallas HQ made N.D. Tex. the natural forum; N.D. Tex. is also a materially less plaintiff-friendly and generally faster docket than the Eastern District of Texas that Cedar Lane used for other defendants in the same wave. Second, the district choice looks like forum-matching rather than forum-shopping: Cedar Lane filed against defendants' home districts nationwide (S.D.N.Y., E.D.N.Y., N.D. Ill., D. Del., W.D. Wis., and Texas divisions). The case is most notable as the opening shot of a coordinated 2025–26 campaign on a single 2013 finance-method patent. Cedar Lane filed on the ’782 patent starting February 24–25, 2025 against a broad set of broker-dealers, banks, custodians and fintech platforms — Charles Schwab (E.D. Tex. 2:25-cv-00233, filed one day before this case), Doo Technology (2:25-cv-00231), Alterna Securities, LaSalle St. Securities, Beech Hill Securities, Cantor Fitzgerald, Clear Street, Citibank, BNY Mellon, TIAA-CREF, Bank of America, BTG Pactual, AlpacaDB, Horace Mann and others — and the resolution pattern mirrors this one: rapid stipulated dismissals (with and without prejudice) within roughly 50–120 days, typically before any substantive motion practice, with no adjudication of the patent's validity. That uniformity suggests a licensing/settlement-driven monetization program rather than litigation over trading technology, and it means the ’782 patent's core validity and eligibility questions remain untested even after dozens of suits. The market context sharpens the point: the claims reach ordinary market-making and order-handling mechanics (profiling, targeted quotes, exchange execution), so the patent functions as a toll on routine electronic-trading infrastructure, with roughly five years of term remaining to expiry. Third-party commentary (PatSnap) speculates that §101 and IPR exposure would make the patent vulnerable if a well-resourced defendant chose to fight, but that is analyst opinion, not a court finding.

Sourcing and confidence notes. Docket data (filing/termination dates, judge, counterclaims, jury demand) is corroborated by the Justia docket summary (last retrieved April 24, 2025) and the Patsnap litigation record, which also supplies the verbatim stipulation text; I did not pull the PACER record directly, so intervening 2025 entries beyond the Justia snapshot are unverified. Party counsel attributions (Rabicoff/DNL Zito for Cedar Lane; Frost Brown Todd for Hilltop) come from litigation-database aggregation rather than confirmed PACER appearances. Hilltop's corporate profile and financials are from Hilltop Holdings' SEC filings and the company's own releases. The Dallas Division inference rests on the "3:" docket prefix. No IPR/PTAB petition on the ’782 patent was located, but my PTAB-specific search was cut short, so treat "no IPR" as unconfirmed rather than established.

I'll research this case and its context. Let me start with searches on the docket, the patent, and Cedar Lane's litigation campaign.

Cedar Lane Techs. Inc. v. Hilltop Securities Inc., No. 3:25-cv-00483 (N.D. Tex.)

Bottom line: this was a short, early-exit NPE suit — 107 days from complaint to a stipulated dismissal with prejudice. It never generated a substantive ruling: no motion to dismiss, transfer, or stay; no Markman; no discovery fight surfaced in the docket; no PTAB proceeding on the patent. Its significance is almost entirely as a data point in Cedar Lane's rolling '782 broker-dealer campaign, not as a merits precedent.

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1. Filing and initial pleadings

Cedar Lane's counsel of record: Isaac Philip Rabicoff (Rabicoff Law LLC) and Benjamin C. Deming (DNL Zito).

Sourcing caveat: the last docket snapshot I could retrieve from a free mirror (Justia) runs through 2025-04-24. The complaint-level detail above is corroborated by litigation-database summaries (Patsnap, Ex Parte AI Lab, DocketNexus) rather than by my own PACER pull, and the specific grounds pleaded in Hilltop's counterclaim (e.g., § 101, § 102/103, non-infringement) are not confirmed in the sources I was able to reach. I would not assert them without the ECF 13 PDF.

2. Pre-trial motions of substance

None. No Rule 12(b)(6) § 101 motion, no § 1404(a) transfer motion, no motion to stay pending IPR, no summary judgment briefing. The only pretrial motion was the uncontested answer extension (ECF 11–12). This is worth flagging analytically: the most obvious defense vehicles in a financial-method patent case (Alice/§ 101 and § 1404(a) to a defendant's home district — here, largely academic because Hilltop is Dallas-headquartered) were never brought to a ruling.

3. Claim construction (Markman)

Did not occur. No scheduling order, no Joint Claim Construction Statement, no Markman hearing, no claim construction order. The case closed roughly three months after the answer, well before the N.D. Tex. local patent rules' typical Markman track.

4. Discovery milestones of strategic significance

None recorded. No motion to compel, no protective order dispute, no discovery stay. The only "discovery-like" event of note is procedural: Cedar Lane's infringement theory was carried entirely by an Exhibit 2 claim chart incorporated by reference into the complaint, and service of the complaint plus charts was pleaded as the act giving rise to actual knowledge and post-suit induced infringement — a standard Rabicoff-complaint mechanic that front-loads notice and, correspondingly, starts the § 315(b) one-year IPR clock for the defendant.

5. Trial, verdict, post-trial motions

None. No trial setting, no verdict, no JMOL/Rule 59 motion, no § 285 fee motion. Notably, the dismissal stipulation expressly provides that each party bears its own costs, expenses, and attorneys' fees, which forecloses a later fee petition by either side.

6. Final disposition

• 2025-06-12 — stipulated dismissal with prejudice under Fed. R. Civ. P. 41(a)(1)(A)(ii), dismissing all of Cedar Lane's claims and all of Hilltop's counterclaims with prejudice, each side bearing its own costs and fees. Case closed same day.
• No appeal; no judgment; no consent judgment or license filed on the docket.
• Practical effect: claim preclusion bars Cedar Lane from re-asserting the '782 patent (or any claim it could have brought) against Hilltop on the same transactional facts. Because the dismissal was with prejudice, it also moots the Click-to-Call/§ 315(b) question as to Hilltop — Cedar Lane cannot re-sue to resurrect leverage, and the dismissal itself does not reset anything for other defendants.
• The "each side bears its own fees" term, combined with a 107-day lifecycle and zero motion practice, is the usual signature of a confidential, no-cash (or nominal) resolution — likely a license or a walk-away — but no settlement document is public. Treat the payment term as inference, not fact.

7. Parallel PTAB proceedings

None identified on the '782 patent. I found no IPR, PGR, or reexamination petition challenging U.S. 8,577,782 by Hilltop or anyone else. This contrasts with Cedar Lane's history in its earlier campaigns: Unified Patents successfully invalidated the independent claim of Cedar Lane's U.S. 7,173,177 in Unified Patents, LLC v. Cedar Lane Techs., IPR2020-00006 (PTAB Final Written Decision 2021-02-12). The absence of any '782 challenge is a meaningful strategic fact — the patent has emerged from ~18 months of assertion activity without a PTAB validity test, so it retains full presumed validity in every pending case.

8. Campaign context (why this case matters)

Hilltop was in the first wave of the '782 campaign, filed one day after Cedar Lane sued Charles Schwab:

Two structural takeaways: (a) Hilltop's dismissal is the template the campaign has since repeated — BNY Mellon resolved in 78 days on nearly identical terms, suggesting defendants are pricing a nuisance-value exit rather than litigating Alice; (b) the venue drift is telling — Cedar Lane started in N.D. Tex./E.D. Tex. in Feb. 2025 and had migrated to S.D.N.Y., N.D. Ill., and D. Del. by late 2025–2026, consistent with § 1400(b) pressure after the Federal Circuit's venue tightening. The '782 patent does not expire until ~2030-04-08, so the campaign has runway and no validity ruling has yet been forced.

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Verification note: the with-prejudice dismissal language above is quoted from a litigation-database transcription of the Rule 41(a)(1)(A)(ii) stipulation, which matches the case metadata's "dismissed with prejudice" status and the 2025-06-12 termination date. If you need cite-grade confirmation, pull ECF 13 (Answer/counterclaim) and the June 2025 stipulation/order from PACER — those are the only two documents in this case with any analytical content, and the counterclaim's invalidity theories are the one open factual question I could not close.

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

Let me dig into the docket entries and the plaintiff's counsel appearances.

Plaintiff's Counsel of Record — Cedar Lane Techs. Inc. v. Hilltop Sec. Inc., No. 3:25-cv-00483 (N.D. Tex.)

Bottom line: The record identifies two plaintiff-side attorneys — Isaac Philip Rabicoff (Rabicoff Law LLC, Chicago) as the filer/lead, and Benjamin C. Deming (DNL Zito, Dallas) as the Texas-side attorney appearing in the complaint signature block and per PACER-derived counsel records. The case was short-lived (107 days, filed 2025-02-25, dismissed with prejudice 2025-06-12), so the plaintiff's appearance list is thin and no additional local counsel ever appeared.

Sourcing and caveats

• Docket basis: Justia's docket sheet for No. 3:2025cv00483 (last retrieved 2025-04-24) shows Docs. 4 and 5 filed by "(Rabicoff, Isaac)" for Cedar Lane; Docs. 10–14 are defense filings by Amy E. LaValle (Frost Brown Todd LLP, Dallas) for Hilltop. Justia docket
• Deming's role — flag: The Patsnap PACER-derived case record lists plaintiff's counsel as "Benjamin C. Deming · Isaac Philip Rabicoff" with firms "DNL Zito, Rabicoff Law LLC," and the complaint analysis on Ex Parte likewise lists "Rabicoff Law LLC; DNL Zito." Patsnap case record That is consistent with Deming appearing in the complaint's signature block. However, I could not retrieve a standalone ECF "Notice of Attorney Appearance" by Deming in this case — the publicly mirrored docket text I could access does not show one, and PACER's full document images were not available to me. Treat his title as "counsel listed on the complaint" rather than as a confirmed separate appearance.
• No sealed-material issue at the party-representation level, but the complaint's infringement-contentions exhibit (referenced as "Exemplary '782 Patent Claims") was not attached to the publicly available filing, per the complaint analysis.
• No other counsel identified. I found no separate Texas local-counsel firm, no in-house counsel for Cedar Lane, and no of-counsel designations in the record. Given the case was resolved by Rule 41(a)(1)(A)(ii) stipulation of dismissal with prejudice on 2025-06-12 (each side bearing its own fees and costs), no further appearances were needed.
• One caution on the parallel-case research: Cedar Lane filed a large wave of materially identical '782 suits against broker-dealers in 2025–2026 in S.D.N.Y., E.D.N.Y., E.D. Tex., W.D. Tex. and N.D. Ill., nearly all of which were dismissed or settled within weeks; counsel composition varies by district, and Deming's DNL Zito Dallas office is the recurring Texas-side pairing rather than a fixture in the New York filings.

If you need certainty on Deming's appearance, the check is a PACER pull of the docket text for entries 1–3 and the complaint's signature page in No. 3:25-cv-00483.

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

Let me dig into the docket details and Attorney LaValle's background.

Counsel of Record for Defendant Hilltop Securities Inc.

Bottom line: Only one attorney appears on the docket for Hilltop Securities in this case — Amy E. LaValle of Frost Brown Todd LLP, Dallas, Texas. She is simultaneously lead counsel, local counsel (Texas-barred, Dallas office), and the sole filer on every defense-side submission before the case was dismissed with prejudice on 2025-06-12. No second defense attorney, no pro hac vice sponsor, and no in-house appearance is documented in the docket as retrieved.

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1. Amy E. LaValle — Lead counsel of record; also serves as local counsel

Relevant patent litigation experience (for context on defense posture):

• mCom IP, LLC v. Hilltop Holdings Inc. & PlainsCapital Bank, W.D. Tex. No. 6:23-cv-00437 — defended Hilltop Securities' corporate parent and its bank affiliate in a banking-systems patent suit. (Most directly analogous prior matter: same corporate family, same sector.)
• InnoMemory, LLC v. PlainsCapital Bank, W.D. Tex. No. 6:22-cv-00761, and Dynapass IP Holdings LLC v. PlainsCapital Bank, E.D. Tex. No. 2:22-cv-00213 — defended PlainsCapital in banking-system and authentication-system patent suits.
• Traxcell Technologies, LLC v. Huawei Technologies USA, E.D. Tex. No. 2:17-cv-00042 — defended Huawei in a wireless-networking patent case.
• Lexos Media IP, LLC v. Neiman Marcus Group, E.D. Tex. No. 2:15-cv-02100; Somaltus LLC v. Cadex Electronics, E.D. Tex. No. 2:15-cv-00203; Acantha LLC v. NuVasive, E.D. Mich. No. 4:19-cv-10656; Dynamic Hosting Co. v. Sprint Solutions, E.D. Tex. No. 2:14-cv-01137.
• PTAB experience: lead counsel for petitioner Coalition for Affordable Drugs VII (Hayman Capital) in Pozen IPRs (e.g., IPR2015-01241, IPR2015-01718); represented Ericsson as petitioner in IPR2014-01149 (Intellectual Ventures wireless patents).
• Firm move: joined FBT's Dallas office as a partner in the Intellectual Property group in August 2023, from Munck Wilson Mandala; previously at Wick Phillips Gould & Martin. Recognized in Texas Super Lawyers (IP Litigation) in 2023 and 2024.

Sources: FBT attorney profile (frostbrowntodd.com / fbtgibbons.com mirrors); FBT press release, Aug. 21, 2023; Law360 firm/attorney page for Amy E. LaValle listing this case; TTAB correspondence of record (Vue No. 91296528) confirming Dallas address and bar numbers.

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2. Attorneys who did not appear (explicitly)

• No pro hac vice counsel: The retrieved docket (Justia's PACER-derived sheet, last pulled 2025-04-24) contains no application for admission pro hac vice, no designation of lead/backup counsel, and no additional FBT attorney appearance — notable because FBT is a multi-office firm and the Answer/Counterclaim asserted invalidity and non-infringement counterclaims that typically draw a broader team.
• No in-house counsel of record: Nothing on the docket identifies a Hilltop Securities legal-department attorney appearing under Fed. R. Civ. P. 83 / local rule.
• No termination-stage counsel entries confirmed: The docket text I could verify ends at ECF 14 (2025-04-24). The Rule 41(a)(1)(A)(ii) stipulation of dismissal that closed the case on 2025-06-12 (per the recorded termination text, dismissing both Cedar Lane's claims and Hilltop's counterclaims with prejudice, each side bearing its own fees and costs) is reported by litigation-data aggregators but I could not retrieve the actual stipulation signature block. I cannot confirm whether an additional FBT attorney co-signed the stipulation.

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Verification / confidence notes

Recommended verification step: pull the full PACER docket sheet for 3:25-cv-00483 (D. Tex. N.D., Dallas Division) for entries after ECF 14 to confirm the stipulation's signatories, and check the N.D. Tex. CM/ECF attorney list for any withdrawn appearances.