IQX Corp. v. Salesforce, Inc.

I'll research this case across multiple sources.

IQX Corp. v. Salesforce, Inc. — Case Overview

Parties. IQX Corp. (styled "iQX Corp.") is the plaintiff. Per the complaint in its companion case, it is a Wyoming corporation with a business address at 204 West Spear St., Suite 3982, Carson City, NV 89703 — a mail-drop/registered-agent address, not an operating facility (Bloomberg Law docket excerpt of the Intuit complaint, ¶1). IQX traces to an actual operating company: iQX Corp., a Seattle-based SaaS developer that in January 2017 launched "iQX Amplify," a cloud-based direct-text (SMS) sales-and-marketing platform for e-commerce stores, with integrations to WooCommerce, Twilio, Stripe and Plaid; founder/CEO Sacha Spindler is the lead named inventor on the patents (2017 iQX Amplify launch release; inventor profile). That makes IQX an inventor-linked plaintiff monetizing its own former product's patent family — RPX's Q2 data byte grouped it among "inventor-linked plaintiffs" and "familiar monetizers" and noted these are IQX's first-ever infringement complaints (RPX). Counsel is Reza Mirzaie of Russ August & Kabat, a firm that regularly represents patent-assertion plaintiffs (PACER Monitor). Defendant Salesforce, Inc. is the Delaware-incorporated, San Francisco-headquartered CRM/cloud-marketing leader. Notably, the parties' roles here are the mirror image of the typical dynamic in this space: an inventor-founded SMS

I'll research this case across the sources you named. Let me start with broad docket and patent searches.

Good — I have the docket shell and a PTAB lead. Let me dig into the IPRs, docket activity, and any rulings.

Preliminary caveat on coverage

This case is roughly four and a half months old (filed 2026-05-28; today is 2026-10-13), and the record is very thin. Verified below is only what the available sources support. Several of the items you asked about — answer/counterclaims, Rule 12 motions, transfer/stay briefing, summary judgment, Markman, discovery milestones, trial, JMOL/fees, settlement or appeal — have not yet occurred or are not publicly reflected in the sources I could reach. I have flagged each of those gaps explicitly rather than infer them. I also want to note that the deepest "complaint analysis" material I found is an AI-generated summary on a third-party aggregator (ai-lab.exparte.com / azurewebsites mirror), not a primary court document; I treat it as secondary and note where it is uncorroborated.

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Chronology

1. Filing and initial pleadings

2026-05-28 — Complaint filed. IQX Corp. filed a Complaint for Patent Infringement in the U.S. District Court for the Western District of Texas (Waco Division, case no. 7:26-cv-00213), filing fee $405, receipt no. ATXWDC-22036119. Nature of suit 830 (Patent); cause of action patent infringement; sector "Communications." Same-day docket activity (per PACER Monitor, case 64898612):

• D.E. 1 — Complaint (15 pp.), filed by IQX Corp. (counsel of record: Reza Mirzaie).
• D.E. 2 — Notice of Filing of Patent/Trademark Form (AO 120), forwarded to the USPTO Director.
• D.E. 3 — Rule 7 Disclosure Statement (Fed. R. Civ. P. 7.1) filed by IQX Corp.
• D.E. 4 — Request for Issuance of Summons (Mirzaie).

Patents asserted (four):

Named inventors in the IQX portfolio records include Sacha Spindler, Andrew Lewin, and Aidan Wright; IQX's grants cluster in CPC class H04W (wireless). The complaint's asserted independent claims are reported as claim 1 of the '924 and '165, claim 12 of the '799, and an independent claim of the '978.

Accused instrumentality: the "Salesforce text message marketing system" (i.e., the SMS/messaging marketing functionality). The publicly available complaint summary reports that the infringement allegations are pleaded in prose against "one or more claims," with claim-chart exhibits incorporated by reference but not attached — meaning the element-by-element theory is not yet visible on the public docket. Treat that characterization as secondary-source.

Posture: Status is "Open," with judge assignment shown as pending in the aggregator docket shell. Given the 7:xx-cv docket prefix (Waco Division) this is the type of case that would ordinarily be assigned to Judge Alan D. Albright, but I could not confirm an assignment order — do not assume the judge.

2. Answer, counterclaims — NOT YET REFLECTED

I found no answer, no Rule 12 motion, and no counterclaims on the public docket as of this writing. Given a 2026-05-28 filing and the absence of any reflected proof of service or appearance, the most likely posture is that Salesforce's response deadline had not yet matured and/or the parties are in an extension/waiver exchange. I cannot state a responsive-pleading deadline with confidence. Expected counterclaims (non-infringement, invalidity under §§ 101/102/103/112) are a forecast, not a reported fact.

3. Pre-trial motions of substance — NONE REPORTED

No motion to dismiss, motion to transfer venue (e.g., to N.D. Cal., where Salesforce is headquartered), or motion to stay pending IPR appears in the sources. Zero of these have been decided. This is the single most consequential near-term docket gap, because the IPR described below creates a live § 315(b)/stay dynamic (see §7).

4. Claim construction — NOT REACHED

No Markman scheduling order, no joint claim construction statement, no Markman hearing, and no claim construction opinion exist yet. In W.D. Tex. practice, a claim construction order typically would not be expected before roughly mid-2027 at the earliest in a case filed May 2026. Any claim construction "outcome" would be speculative.

5. Discovery milestones — NONE REFLECTED

No scheduling order, no Rule 26(f) conference entry, no initial infringement/invalidity contentions, no discovery motions, and no protective-order entry appear. Nothing strategically significant is on the record yet.

6. Trial, verdict, post-trial motions — NOT REACHED

No trial date, no verdict, and no JMOL / new-trial / fee motions. Not applicable at this stage.

7. Parallel PTAB proceedings — THE ACTIVE DEVELOPMENT

2026-09-24 — Salesforce filed IPR2026-00478, Salesforce, Inc. v. IQX Corp. (USPTO PTAB). Status: pending; institution decision: none; final written decision: none; outcome: none; panel: not yet assigned.

• The proceeding is reported by Patent Lawyer Magazine as a challenge to an IQX patent "covering technology that includes silent network authentication," which maps to the '799 patent — the only one of the four asserted patents whose title is the silent-network-authentication protocol. Caveat: neither the patent-lawyer report nor the PTAB docket shell I retrieved names the challenged patent number explicitly, so the identification of '799 is my inference from the technology description, not a confirmed citation. IPR2026-00478 was filed roughly four months after the complaint.
• Effect on the litigation: none yet, in any formal sense. Under 35 U.S.C. § 315(b), Salesforce's IPR petition avoids the one-year statutory bar because it was filed well within a year of service. Under § 314(a), an institution decision would be due on the order of six months from the September 2026 filing (i.e., ~early 2027), so no § 314(a) Fintiv-style discretionary-denial ruling or stay motion can have been made yet. A stay of the district court case pending IPR is the natural next battleground once institution is decided — but no such motion is on the docket.
• Note that only one IPR is reflected. No parallel PGRs and no IPRs on the '924, '165, or '978 are reflected. Because three of the four patents are quite recent ('165, '799, '978 issued 2025), additional IPRs remain feasible within the statutory windows.

8. Final disposition / present posture

No disposition. The case is active and at its earliest pleading stage as of 2026-10-13, with the only concrete development beyond the initial filings being Salesforce's IPR2026-00478 filed 2026-09-24.

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What to watch next (grounded in the record, not speculation)

1. Judge assignment order and scheduling order — confirm the W.D. Tex. judge and the deadlines for contentions.
2. Salesforce's responsive pleading and counterclaims, including any § 101 eligibility challenge (plausible given the "customized webpage/messaging" subject matter of the '924 and '978).
3. A motion to stay pending IPR2026-00478, especially if the PTAB institutes in early 2027.
4. The institution decision in IPR2026-00478 — and confirmation via the PTAB docket of exactly which claim(s) and patent are challenged.

Source-quality notes

• Court/docket metadata: PACER Monitor case page (cdn.pacermonitor.com/public/case/64898612) and the Ex Parte case shell for 7:26-cv-00213.
• PTAB metadata: Ex Parte PTAB shell for IPR2026-00478 (Source: USPTO); Patent Lawyer Magazine (Issue 60) for the substantive description of the challenge.
• Complaint-level technical detail: AI-generated complaint analysis at ai-lab.exparte.com — secondary, treat as unverified; the underlying complaint exhibits are incorporated but not attached, so no primary claim charts are publicly available.
• Patent bibliographic data: onscope/ipqwery assignee records for IQX Corp.
• Attorneys: only Reza Mirzaie (plaintiff side) is confirmed from the docket. No Salesforce counsel is confirmed — I did not find an appearance, so I am not naming one.

If the case has produced an answer or a stay motion in the last days, those would postdate my search window; a PACER docket pull on 7:26-cv-00213 would confirm.

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

Good — the docket shows the complaint was filed by Reza Mirzaie. Let me verify his firm and check for any other counsel appearances.

Let me check for additional appearances and the full docket sheet, plus whether local counsel has appeared.

Counsel of Record — Plaintiff IQX Corp. (7:26-cv-00213, W.D. Tex.)

Caveat on docket currency: The publicly available docket snapshot for this case reflects only the four opening filings (the complaint and its accompanying documents, all filed 05/28/2026). No answer, motion, or separate notice of attorney appearance by co-counsel is reflected, and the case shows as "Pending Judge Assignment" (Waco Division). That means the appearance list below is derived from the signature block on the initiating filings, not from a formal appearance roster. If additional counsel have since entered appearances, that would not show up in the sources I can reach.

Confirmed counsel

Reza Mirzaie — Lead counsel (plaintiff-side); the only attorney identified on the docket

• Firm: Russ August & Kabat (RAK), 12424 Wilshire Blvd., 12th Floor, Los Angeles, CA 90025
• Docket basis: Mirzaie is the filing attorney on every entry of record: ECF No. 1 (Complaint for Patent Infringement, 15 pp., fee receipt ATXWDC-22036119), ECF No. 2 (Notice of Filing of Patent/Trademark Form AO 120), ECF No. 3 (Rule 7 Disclosure Statement), and ECF No. 4 (Request for Issuance of Summons). See the docket summary at PacerMonitor case 64898612.
• Credentials: Cal. Bar No. 246953 (admitted 12/5/2006); registered patent attorney, USPTO Reg. No. 69,138. USC (B.S., Electrical Engineering); Univ. of Illinois College of Law (J.D.). RAK partner, previously equity partner at Knobbe Martens. RAK bio; Cal. State Bar profile.
• Relevant experience: Prolific patent plaintiff's-side trial lawyer; RAK states he has recovered more than $600M for clients in five years. Notable verdicts: Headwater Research v. Verizon (E.D. Tex. 2025, $175M, RAK trial team); Samsung push-messaging case (E.D. Tex. 2025, $279M verdict / $340M judgment); MR Technologies v. Western Digital (C.D. Cal. 2024, $262M); AlmondNet v. Amazon (W.D. Tex. 2024, $122M); Solas OLED v. Samsung (E.D. Tex. 2021, $62.7M willfulness verdict). Named a Daily Journal Top IP Lawyer in California (2025). He is also the RAK attorney who typically serves as lead counsel for patent owners (including IQX-type NPE plaintiffs) in parallel PTAB proceedings.

Likely but unconfirmed co-counsel

• Qi "Peter" Tong (RAK, Dallas office — 8080 N. Central Expy., Suite 1503, Dallas, TX 75206; USPTO Reg. No. 74,292). RAK's Texas-registered attorney is routinely listed as the Texas-based back-up/post-grant counsel on RAK patent matters (e.g., the PTAB power-of-attorney in IPR2025-00591, Docket Alarm). I have not found a notice of appearance for him in this docket, so treat this as an inference from RAK's standard staffing, not a confirmed appearance. Same caution applies to RAK partners who frequently appear alongside Mirzaie on W.D. Tex. filings (Marc A. Fenster, Neil Rubin, James Milkey, Benjamin Wang, Matthew Aichele) — none are confirmed on this docket.
• Local/Texas counsel under W.D. Tex. practice: I found no separate local-counsel firm on the docket. Note that WDTX does not require a distinct local-counsel firm in the way some districts do if counsel is admitted to the bar of this court or admitted pro hac vice; RAK is a frequent filer in the Waco Division and appears to be proceeding without a separate local firm here. Because no notice of appearance has been docketed, I can't rule out that a Texas firm was later added.

Parallel PTAB proceeding (counsel-relevant)

Salesforce filed IPR2026-00476, Salesforce Inc. v. IQX Corp., on 09/24/2026, challenging an IQX patent described in trade press as covering silent-network authentication (status: pending, no institution decision). See Patent Lawyer Magazine and the PTAB docket summary at Ex Parte. The IPR's counsel roster is not yet reflected in the sources I can access; if IQX follows its usual pattern, Mirzaie would serve as lead counsel for the patent owner there as well.

Bottom line

The only attorney that can be confirmed from the record as counsel for IQX Corp. in this case is Reza Mirzaie of Russ August & Kabat (Los Angeles) — lead and, to date, sole appearing counsel. No local counsel, in-house counsel, or additional firm has been confirmed. If you need a definitive appearance roster, it would have to be pulled directly from PACER (W.D. Tex. 7:26-cv-00213) as of today, since the public aggregators I can reach show only the four initial filings.

I'll search for docket and counsel information on this case.

Let me dig into the docket and look for any defense-side appearances.

The docket so far only shows plaintiff-side filings. Let me check for later docket entries and any defense appearance, plus Salesforce's known patent litigation counsel.

Counsel of Record for Defendant Salesforce, Inc. — Status: Not Yet Appearing (as of the sources I could verify)

I was unable to identify any counsel of record for Salesforce in this case, because no defense-side appearance, answer, or other filing is reflected on the docket in the sources I retrieved. I looked at the docket aggregators carrying 7:26-cv-00213 and searched for defense appearances, the parallel PTAB proceeding, and Salesforce's litigation counsel, and could not source a single attorney appearing for Salesforce in this action. Per your instruction not to invent attorneys, I am reporting the gap rather than filling it.

What the docket actually shows

The docket snapshot I retrieved (PACER Monitor, case ID 64898612; mirrored on Ex Parte's AI-Lab) contains only four entries, all filed by the plaintiff on May 28, 2026, and all signed by IQX's counsel Reza Mirzaie:

The case status field still reads "Pending Judge Assignment," which is consistent with a defendant that has not yet appeared. As of that snapshot there is no Notice of Appearance, no answer, no Rule 12 motion, and no corporate disclosure statement from Salesforce.

• Docket mirror: https://cdn.pacermonitor.com/public/case/64898612/IQX_Corp_v_Salesforce,_Inc
• Docket mirror: https://ai-lab.exparte.com/case/dct/txwd/7:26-cv-00213/iqx-corp-v-salesforce-inc

Important caveats about this conclusion

1. The docket data I could reach is a third-party snapshot, not a live PACER pull, and it appears stale. The case was filed ~4.5 months ago (May 28, 2026) and today is October 13, 2026. It is highly likely Salesforce has appeared by now — four-plus months is ample time for a responsive pleading in W.D. Tex. — but I could not find any record of that appearance in the sources available to me. I therefore cannot confirm that no appearance exists; I can only say I could not verify one.
2. No sealed-filing indication. I found nothing suggesting filings are under seal in this case; the issue is simply that no defense filing surfaced in my searches.
3. Aggregator reliability. The Ex Parte / AI-Lab and PACER Monitor pages are secondary sources. A definitive answer requires the live PACER docket sheet for 7:26-cv-00213 (W.D. Tex.), including the "Attorneys" tab.

Related proceeding where counsel may be identifiable

Salesforce has filed a parallel IPR at the PTAB — IPR2026-00478, Salesforce Inc. v. IQX Corp., filed September 24, 2026 — challenging an IQX patent relating to silent network authentication.

• https://ai-lab.exparte.com/case/ptab/IPR2026-00478/salesforce-inc-v-iqx-corp
• Patent Lawyer Magazine, "Salesforce launches PTAB challenge against IQX automated authentication patent" (Sept. 25, 2026)

I could not retrieve the petition's mandatory notices or power-of-attorney from P-TACTS, so I cannot name the attorneys prosecuting that IPR either. That petition is nevertheless the most promising near-term source for identifying Salesforce's patent counsel, since the same firm(s) usually appear in the district court case.

What I could not verify / did not find

• No lead counsel, local counsel, of counsel, or in-house attorney for Salesforce could be sourced for this case.
• I did find other, unrelated Salesforce matters in passing (e.g., a W.D. Tex. Midland/Odessa case, MO:25-cv-00539-DC, and 3:25-cv-00476-MMD-CLB), and a PTAB filing in which GISH PLLC and Quinn Emanuel appeared for Fortinet, Inc. — neither of which is evidence of counsel in this case. I am flagging them only to make clear I did not treat them as support.

Recommended next steps to close this out

1. Pull the live PACER docket for 7:26-cv-00213 and open the Attorneys tab for all Salesforce entries (Notices of Appearance list lead/local counsel and bar numbers).
2. Check W.D. Tex. standing orders — that district typically requires a local counsel designation, so a "lead + local" pairing is likely once Salesforce appears.
3. Retrieve the IPR2026-00478 petition's mandatory notices / power of attorney via PTAB P-TACTS or the USPTO Patent Center, which will name Salesforce's PTAB counsel (often the same team defending the district court case).
4. If Salesforce has filed a corporate disclosure statement (Rule 7.1 / Local Rule), it will confirm the entity and often the outside counsel signature block.

Bottom line: based on the best sources I could access, Salesforce had not yet appeared and no defense counsel of record exists — but given the elapsed time, treat this as an unverified gap and confirm against live PACER before relying on it.