The complaint

The case is BenedorTSE, LLC v. JPMorgan Chase Bank, N.A., No. 3:26-cv-01340 (M.D. Tenn.), filed September 18, 2026 in the Nashville Division with a jury demand. BenedorTSE is a Delaware limited liability company based in Franklin, Tennessee. It accuses the Chase Mobile and J.P. Morgan Mobile Android applications, together with the bank's authentication, device-trust, transaction-authorization, and payment-provisioning systems, and pleads the infringement in the past tense, during what it calls the relevant damages period.

The patents and asserted claims

All three patents are titled Transactional Security Over a Network and claim priority to an application filed December 1, 2000. U.S. Patent 8,260,723 issued September 4, 2012, U.S. Patent 8,463,713 issued June 11, 2013 from a division of the '723 application, and U.S. Patent 9,400,979 issued July 26, 2016 from a continuation of the '713 application.

Claim 19 of the '979 patent covers a method of reading a hardware identifier from a device, checking that it is valid, then retrieving a stored user agreement identifier, encrypting it together with the hardware identifier into a user code, sending that code to a provider in a transaction request, and receiving the provider's authorization decision and performance of the transaction.

Claim 13 of the '713 patent covers a method of validating a password entered in a device's graphic user interface against permitted passwords, then validating a hardware identifier read from the device against permitted identifiers, retrieving a stored user agreement identifier for an agreement between the user and a verification entity, encrypting it with the hardware identifier into a code valid for only a single authorization request, and sending the code to a provider, which sends it to the verification entity for an authorization decision.

Claim 1 of the '723 patent covers a method of validating a customer's password, reading several hardware identifiers including at least part of a hardware component's serial number and checking them against a permitted list, retrieving a stored customer identifier string, incrementing a count value, encrypting the string, identifiers, and count into a customer code, and sending that code to a merchant in a purchase transaction instead of credit card information. The complaint pleads claim 7 of the '723 patent, a storage medium claim, in the alternative.

Knowledge and willfulness allegations

BenedorTSE alleges that the bank learned of the technology long before the damages period: on information and belief, through a former chairman of two predecessor banks in about 2006 to 2008, through 2009 correspondence about a presentation it attaches as Exhibit D, and through the bank's own patent prosecution, where it says a December 20, 2019 final office action cited the published application in the family. It alleges, on information and belief, that the bank kept using the accused systems with that knowledge and without a license. It also pleads that the bank directed or controlled any steps customers performed, under Akamai Technologies, Inc. v. Limelight Networks, Inc., 797 F.3d 1020 (Fed. Cir. 2015) (en banc).

The prayer asks for damages of no less than a reasonable royalty, a finding of willfulness with damages enhanced up to three times, attorneys' fees under 35 U.S.C. 285, and interest.

What to watch next

The case was referred to Magistrate Judge Luke A. Evans (ECF Nos. 5 and 7), and an initial case management conference by telephone is set for December 9, 2026 (ECF No. 5). The court entered an order on a motion to extend the bank's time to answer on October 14, 2026 (ECF No. 11). Watch for the bank's answer or Rule 12 motion and any motion to transfer.