IQX Corp. v. Intuit Inc.

I'll research this case and the asserted patents before drafting.

Case Overview: IQX Corp. v. Intuit Inc., No. 2:26-cv-00351 (E.D. Tex., Marshall Div.)

The parties. Plaintiff IQX Corp. is a Wyoming corporation whose stated place of business is 204 West Spear St., Suite 3982, Carson City, Nevada — a suite-numbered Nevada address, not an operating facility (Compl. ¶ 1). The complaint pleads only ownership of the two patents-in-suit and alleges no product, service, or revenue of its own, and its counsel of record on the April 30, 2026 complaint is Reza Mirzaie, later joined in case activity by Christian Conkle — both associated with the Los Angeles patent-plaintiff firm Russ August & Kabat. IQX filed a second, near-identical campaign suit against Salesforce, Inc. in the Western District of Texas (7:26-cv-00213, filed May 28, 2026), which together with the bare holding-company profile indicates a patent-assertion entity rather than a practicing company. I should flag a conflict in the third-party data here: at least one docket-aggregation site tags the "Patent Owner" in this case as an "Operating Company" (exparte case page), but that field appears auto-populated and is contradicted by the complaint itself, so I would not rely on it. Defendant Intuit Inc. is a Delaware corporation and one of the largest U.S. financial-software and SMB-platform companies; the complaint identifies its place of business as 5601 Headquarters Dr., Plano, TX 75024, which corresponds to Intuit's Plano, Texas campus. Mailchimp — the accused product line — was acquired by Intuit in November 2021 in a transaction valued at roughly $12 billion, making SMS/email marketing a core piece of Intuit's small-business strategy.

The accused technology and the asserted patents. The complaint targets Intuit's "text message marketing systems," specifically Intuit MailChimp (Compl. ¶¶ 12, 25). The pleaded theory is that Mailchimp's commerce features perform a multi-step process: capturing an end-user's consent via a web form element, generating a customized webpage with transaction details for that subscriber, sending a text message containing a link to that page, and serving the page when the recipient taps the link. Two patents are asserted. U.S. Patent No. 11,876,924, titled "Secure transactions using customized webpages," issued January 16, 2024 (Compl. ¶ 7), and Claim 1 turns on activation of a "hosted field" that triggers generation of a customized document — the term most likely to drive claim construction. U.S. Patent No. 12,368,799, titled "Automated silent network authentication protocol," is directed to a method (illustrated by independent Claim 18 / Fig. 18) in which the system generates a "security code packet" containing a subscriber network credential and a client device carrier identifier, transmits it to an authentication service provider (e.g., a mobile carrier), receives a match/no-match indication, and completes the transaction on a match. The complaint attached claim charts as Exhibits 2 and 4 and pleads induced and willful infringement.

Procedural posture, venue, and why it matters. Filed April 30, 2026 and assigned to District Judge Rodney Gilstrap with Magistrate Judge Roy S. Payne in the Marshall Division; a jury trial is demanded and the case is flagged as a jury case (cause of action 35:271). Venue rests on Intuit's Plano, Texas campus as a "regular and established place of business" under 28 U.S.C. § 1400(b) (Compl. ¶ 5) — a closer question than residency would be, since Intuit is Delaware-incorporated and headquartered in Mountain View, California, so the § 1400(b) hook is the Texas facility, not corporate residence. The case remains in the earliest contentions phase: Docket Entry 3 is IQX's Rule 7.1 disclosure statement, and on July 9, 2026 IQX filed a stipulated/corrected motion to extend the P.R. 3-1, 3-2, 3-3, and 3-4 deadlines and the subject-matter eligibility contentions deadline — a notable indicator that the parties already expect a § 101 eligibility fight alongside claim construction. The case is commercially notable for three reasons: it lands on Judge Gilstrap's Marshall docket, which among EDTX judges has historically been the highest-volume, fastest-to-trial patent venue in the country; it sits inside a dense cluster of single-plaintiff NPE filings in the same district in the same week (e.g., LightSure LLC v. Parrot, Encryptawave Technologies v. Vivint/Hisense, VL Collective IP v. Microsoft, Sulaco Enterprises v. Imperva, PulseLink Systems v. Zoom) reflecting the ongoing concentration of assertion activity in Marshall; and the parallel W.D. Tex. action against Salesforce indicates IQX is monetizing this portfolio across the SMS/marketing-automation industry rather than litigating a one-off dispute. The '799 patent in particular raises a divided-infringement/§ 101 question because its asserted claim requires participation of a third-party carrier authentication service that Mailchimp does not itself operate — a defense theory worth watching.

Sourcing caveats and unverified items. Verified: case number, filing date, division, assigned judges, party counsel, patent numbers/titles/issue dates, accused instrumentality, the July 9, 2026 extension motion, and the Salesforce parallel suit (Bloomberg Law docket document for 2:26-cv-00351; PACER Monitor case page; Justia dockets; Docket Alarm case page; Law360 company docket). Not verified, and I have not confirmed: (1) whether any IPR, PGR, or CBM petition has been filed against either patent — my PTAB search did not complete, so treat "no IPR" as unestablished rather than as a finding; (2) the patents' real-party-in-interest chain, priority dates, and original assignee (the complaint names only IQX as owner), which is material to standing and to any prior-assertion/estoppel arguments; (3) Intuit's answer, any motion to dismiss or transfer, and whether a docket control order or Markman date has been set; and (4) whether the Plano facility is Intuit's or a subsidiary's, which would matter to a venue challenge. I also could not independently retrieve the claims charts in Exhibits 2 and 4, and the complaint's infringement allegations are described in available secondary analysis as largely conclusory — if Intuit moves to dismiss or to strike under Iqbal/Twombly or seeks § 101 early disposition, that characterization will be the battleground.

I'll research this case across PACER, court sources, PTAB, and legal news. Let me start with several parallel searches.

Good initial hits. Let me dig into the docket details, the answer/motions, and any PTAB activity.

I'll research the counsel of record for IQX Corp. in this case. Let me run several searches in parallel.

Good — I have initial docket signals (attorneys Reza Mirzaie and Christian Conkle). Let me confirm their firm affiliations and look for local counsel and additional appearances.

Counsel of Record for Plaintiff IQX Corp.

Bottom line: The record I could retrieve shows IQX Corp. is represented by Russ August & Kabat LLP (RAK), Los Angeles, CA, with Reza Mirzaie as the attorney who has signed the operative filings (lead counsel) and Christian Conkle also appearing for the plaintiff. I could not confirm any separate local counsel, in-house counsel, or additional appearances in this docket from the sources available to me. Everything below is tied to a specific docket entry or filing; the gaps are flagged explicitly.

Attorneys identified

Docket support

• Dkt. 1 (Complaint, filed 04/30/2026) — "COMPLAINT FOR PATENT INFRINGEMENT against Intuit Inc. … filed by IQX Corp. (Mirzaie, Reza)." Filing fee receipt ATXEDC-11516108. (PacerMonitor docket page; Bloomberg Law docket)
• Dkt. 3 — "Fed. R. Civ. P. 7.1(a)(1) Disclosure Statement filed by IQX Corp. (Mirzaie, Reza)." (same docket)
• July 9, 2026 entry — "CORRECTED MOTION for Extension of Time to File TO EXTEND P.R. 3-1, 3-2, 3-3, 3-4, AND SUBJECT-MATTER ELIGIBILITY CONTENTIONS DEADLINES (STIPULATED) by IQX Corp. … (Conkle, Christian)." (Law360 docket for IQX Corp. v. Intuit)
• Firm address/signature block for both attorneys confirmed from RAK filings in other matters: Reza Mirzaie (SBN 246953) and Christian Conkle (SBN 306374), RUSS AUGUST & KABAT, 12424 Wilshire Blvd., 12th Floor, Los Angeles, CA 90025, (310) 826-7474.

Related-case corroboration (same counsel, same patents)

• IQX Corp. v. Salesforce, Inc., No. 7:26-cv-00213 (W.D. Tex., filed 05/28/2026) — complaint, Rule 7 disclosure, and summons request all filed by Reza Mirzaie. (PacerMonitor)
• IPR2026-00478, Salesforce Inc. v. IQX Corp. (PTAB, filed 09/24/2026) — parallel IPR in which IQX is patent owner; RAK is IQX's customary PTAB counsel (e.g., in Intent IQ IPRs, RAK listed Mirzaie as lead PTAB counsel with James Milkey and Philip Wang as backup). (exparte.ai PTAB record)

What I could not confirm — and caveats

1. No formal "Appearance of Counsel" form for this case was retrievable. My confirmation of Mirzaie and Conkle rests on the signature blocks of docketed filings (the complaint, the Rule 7.1 statement, and the July 9 stipulated extension motion). Because Conkle's July 9 signature is the only Conkle-sourced event I found, I cannot rule out that additional RAK attorneys (e.g., Marc A. Fenster, Philip X. Wang, James A. Milkey, James Pickens — the firm's standard E.D. Tex. line-up) have also appeared without it surfacing in my sources. Do not treat the two-name list as exhaustive.
2. No local counsel identified. E.D. Tex. (Judge Gilstrap / Mag. Judge Payne) does not impose a separate local-counsel requirement the way some districts do, and RAK's California attorneys are admitted before the court, so the apparent absence of Texas local counsel is plausible rather than an oversight. That said, I found no affirmative negative confirmation.
3. No in-house counsel for IQX identified. IQX Corp. is a Wyoming corporation listing a Carson City, NV address (204 West Spear St., Suite 3982) and appears to be a non-practicing patent-holding entity; no in-house legal contact surfaced.
4. Flag for the case record: The Docket Alarm firm-filter result that returned IQX Corp. v. Intuit Inc. under a Finnegan, Henderson, Farabow, Garrett & Dunner party-firm query suggests defendant Intuit's counsel may be Finnegan — but that inference is from a search-result snippet, not a docket entry, and I did not verify it. Treat as unconfirmed and outside the scope of this task (plaintiff-side counsel).

If you need the appearance list nailed down with certainty, the authoritative step is a PACER docket-sheet pull for 2:26-cv-00351 filtered to "Appearance of Counsel" / attorney filer codes, or a review of Dkts. 4–15 (the early filings between the complaint and the July 9 motion).

I'll research counsel of record for Intuit Inc. in this case using multiple parallel searches.

Let me dig into the docket for appearances and Intuit's filings.