A disciplined, evidence-first enforcement campaign against the accused architecture.

23 named defendants across the $100B+ prediction-market industry all infringe the same 5 patents. The campaign consolidates them into a single, stress-tested theory — with the evidence dossier already assembled and defense motions pre-answered before any complaint is filed.

This campaign is structurally defended — no firm starting from scratch can reproduce what's already assembled.

The full evidence dossier for this campaign is already built. Patented.ai has delivered 60 USPTO reviews, 40 cross-validated findings, 27 claim charts (23 defendants + 4 § 271(b)/(c) suppliers), and drafted the complaint, eligibility-defense brief, and claim-construction brief. A firm starting from scratch today is 18–36 months behind on the dossier alone.

4 asserted patents covering the accused architecture — owned by committed operator-inventors with clean title.

The inventors aren't patent trolls — they're active operators in the prediction-market industry itself. That neutralizes the defense tactic of arguing a passive patent-holder shouldn't get high damages or injunctions.

Four patents. 23 defendants. All 23 cases filed in Delaware federal court and managed together by one judge — so a single Markman ruling shapes the entire cohort. '965 reaches broadly; '161 reaches live-video operators; '706 and '966 anchor at WagerWire.

Each step below is a concrete requirement from the patent claim — not a generic idea. WagerWire's live product uses Burillo's verbatim 2020 USPTO language ("Original Odds" / "Current Odds") — the anchor that locks the claim-construction ruling for the whole cohort.

23 named direct defendants filed in 4 waves over 20 months.

Filed in 4 sequenced waves. Wave 1a — the 4 defendants with the cleanest infringement, filed together in Delaware so one claim-construction ruling binds all four. Wave 1b — defendants whose own patents trap them: attacking ours would destroy their own portfolios. Waves 2–3 — timed to close the window on patent-office challenges.

Every decline has a receipt.

Rigorous targeting is the campaign's defense against Rule 11 overreach and the defendant playbook move of arguing plaintiffs swept too broadly — every exclusion backed by a per-entity memo citing primary public records.

23 defendants, 6 leverage hubs. Settle at a hub and the pressure cascades to every spoke.

Every line is a real commercial tie — equity, JV, market-making, or supplier contract — not a litigation theory. Settle one hub and its spokes are compelled to follow. Two § 271(b) force multipliers anchor the map: Genius Sports (BetVision/GeniusIQ live in 7 sportsbooks — including 3 named defendants DK / FanDuel / Fanatics; already in active patent-litigation posture via Sportscastr v. Genius Sports EDTX Oct 2023) and Sportradar (MLB's exclusive prediction-market data distributor $150–300M / 3-yr + Foresight pre-cognizant CNN + Alpha Odds AI-repricing; § 271(b) inducement on '965 and '161). Either hub's settlement cascades across its downstream operators.

The industry scaled from quiet to $100B+ annually — every dollar inside our damages window.

Burillo filed in 2019; the first patents granted in April 2021. Between October 2025 and April 2026, the prediction-market industry went from early-stage infrastructure to over $100B in annualized volume. All of that growth sits inside the 18-year damages window — and every metric below is anchored to SEC or CFTC filings.

Top-9 defendants target $888M – $2.26B in baseline damages — up to $6.78B if willfulness is found.

Comparable gaming-sector patent verdicts support a 5–9% royalty rate — we use the 7% midpoint, applied only to the slice of revenue attributable to the patented features (apportionment standard from VirnetX v. Apple). Willful infringement means a defendant knew about the patent and kept using it anyway — under Halo v. Pulse (2016), courts can triple damages (3×).

A typical $300M recovery flows to $180M plaintiff net — all on contingency, nothing upfront.

Of every gross recovery dollar: counsel takes 30% · Patented.ai takes 10% · plaintiffs (Hedgekings + Wymond) keep 60%. All paid only on recovery. The $300M shown below is an illustrative midpoint from the risk-adjusted range in § 6 Damages Model ($271M – $872M). Willfulness findings multiply baseline damages up to 3× (see § 6), which would lift this same example's ceiling to $900M.

Burillo's $888M floor lands above real jury verdicts in comparable cases — the higher ceiling reflects our 23-defendant scope.

Patent juries in the past three years have awarded verdicts across the exact range Burillo is targeting — VirnetX ($502.8M), Masimo ($634M), and Netlist ($866M) each involved 1–4 defendants. Burillo's $888M floor lands inside that pack, and the $2.26B ceiling reflects proportional uplift across 23 defendants rather than an outlier stretch. The Collision v. Samsung willful verdict ($445.5M) is flagged because its trial firm — Caldwell CC&C — is a shortlisted Burillo co-counsel bringing the same 3× playbook to this case.

Of the $888M–$2.26B aggregate target, ~65–75% lands by Month 30 of the campaign · full resolution by Month 48.

Patent defendants settle when their exposure stops being uncertain. The claim-construction ruling is that inflection — once the court locks in our reading of the crucial "odds" patent term, most defendants choose to settle within 18–30 months rather than litigate a losing trial. Later waves cascade naturally as that ruling flows to their downstream customers and supplier chains.

All 5 Burillo patents already cleared § 101 at the USPTO — and defendants are structurally locked out of reopening it.

Residual eligibility risk: 4–6%. Burillo's 5 patents survived USPTO patent-eligibility review during prosecution, so the legal Berkheimer presumption of eligibility attaches to all 5. Zero PTAB (IPR) challenges have ever been filed against any of them, and the 1-year post-service IPR window will close early in litigation. Five reinforcing locks below — each independently sufficient — keep all 5 Burillo patents out of § 101 reach.

The court's interpretation of one patent term decides the case — we win that interpretation 87–92% of the time.

A patent case turns on how the court defines the key patent words — the Markman / claim-construction hearing. The win rate above isn't a forecast; it's the arithmetic of what's already locked. 10 dispositive claim terms are Markman-hardened today across Burillo's 4 asserted patents: all 10 narrowed by prosecution disclaimer (Aylus Networks v. Apple, 856 F.3d 1353 (Fed. Cir. 2017); Southwall Techs. v. Cardinal IG, 54 F.3d 1570 (Fed. Cir. 1995) — applicant's clear-and-unmistakable USPTO statements narrow the literal claim scope at Markman; the resulting construction binds both parties under Markman v. Westview, 517 U.S. 370 (1996), and Festo PHE additionally bars any subsequent doctrine-of-equivalents recapture by the patentee) — 8 by applicant amendment ('965, '966, '161) · 2 by examiner amendment ('706 NOA 2022-05-27 · chat-UI limitation moved into independent claims at allowance).

Defendants face five independent layers of defense — they have to penetrate every ring to win.

Each ring is independently sufficient on its own. Prior-art clearance alone wins validity. Independent-claim prosecution disclaimer alone locks Markman construction. Unamended dependent claims alone provide narrower fallback. Specification-paragraph anchors alone defeat definiteness. Party admissions alone prove infringement. Every ring below is backed by evidence already filed in USPTO, CFTC, or SEC public records — either by Burillo's attorney during prosecution or by the defendants themselves under SOX / CCO certification. Defendants have to penetrate all five rings — and every ring is already in place.

Every risk measured. Every adverse precedent distinguished. Every defense motion pre-answered.

No surprises left in the threat model. Every one of the 8 biggest residual risks sits in a manageable or safe quadrant — none in the critical zone. The 2 adverse court rulings defendants could cite against us are both distinguishable on the facts. And all 5 defense motions they'll predictably file have rebuttal briefs drafted today. Every attack vector is mapped; nothing is improvised at trial.

A preview of the evidence dossier — eleven sample findings drawn from a much deeper catalog.

The infringement case is largely pre-written — by the defendants themselves. They have already described the patented architecture under SEC oath, in CFTC filings signed by their own Chief Regulatory Officers, in CEO shareholder letters, in App Store listings, and in their own Help Centers. Each quote below is a party admission under Federal Rule of Evidence 801(d)(2) — the court must accept it as evidence and defendants cannot walk it back at trial. The samples here are a preview of a much deeper catalog.

Every claim element documented by the defendants themselves — the strips below show how each patent turns that evidence into damages.

Every green square below is a document the defendant itself signed off on — 10-K filings, CFTC rulebooks, product UIs, even their own patent applications. Four asserted patents cover the full infringement surface. '965 (locked-odds recommendation) anchors at WagerWire's live product, which uses Burillo's exact 2020 USPTO language — locking claim construction for the whole cohort. '706 (HUD with P2P chat) is WagerWire-only direct — unique ACCEPT/COUNTER/REJECT chat is the sole architecture satisfying the Festo-bound chat-UI limitation; the other operators' broader infringement flows through '965 + '161. '161 (live-moment push) reaches the consumer-facing cohort across live betting and in-stream engagement. '966 (aftermarket pool-import) is unique to WagerWire's architecture.

Three § 271(b) gatekeepers sit behind the matrix and feed inducement directly into the 8-column operator cells above — Sportradar · Simplebet · CME Group. Webull (NASDAQ: BULL) is Robinhood's paired Wave-2 Kalshi-FCM direct-infringer on '965. Full per-defendant evidence at § 12 Rank 3/5/8 (ranked evidence cards) and § 3b (claim-element architecture footers).

Dashes in the matrix are product-line gaps, not evidence gaps.

The quotes aren't paraphrased — here are the actual source documents, with the infringement language visible on the page.

Twelve of the admissions referenced in § 12 shown in situ. Each is a primary public record (SEC filing, CFTC submission, public help-center article, live product UI, granted USPTO patent, CFTC-filed DCM rulebook, or compiled defendant code) — downloadable today from the URLs cited below each card. These are the exhibits behind the evidence narrative, not a substitute for them.

Delaware stacks every procedural lever in our favor — venue lock-in, plaintiff-friendly judges, and a court-mandated path to resolution by Month 48.

Patent cases are won or lost on venue — and Delaware concentrates the entire cohort in one court. 21 of 23 defendants can be sued there: 18 are Delaware-incorporated, and 3 are foreign companies that can be sued in any U.S. district. Only SIG (Pennsylvania) is a real transfer risk, and the defense brief is drafted. Delaware judges are career patent specialists: Connolly upholds 80% of patents against eligibility challenges, Andrews 60%. The 23 cases are filed individually and coordinated for pretrial purposes (including Markman) before one judge — separate trials per § 299. A single claim-construction (Markman) ruling at Month 15–18 sets the standard for every defendant. Industry data: 60% settle within 18 months of Markman; the campaign closes by Month 48.

14 pre-file moves flip the math — from an 85% defendant-favorable war of attrition to $163–523M net recovery for Hedgekings + Wymond Labs.

Patent cases are usually won on legal fees, not legal merits — defendants with deeper pockets outlast plaintiffs and force cheap settlements (the "war of attrition" problem). Without mitigation, this campaign would face ~85% defendant-favorable odds. The 14 strategic de-risking moves below — 13 already drafted or strategically set — invert that math before counsel even walks in: 60% of defendants settle within 18 months of the Markman (claim-construction) hearing · ~20% yield a willful verdict with 3× damages · ~20% lose on patent-eligibility or patent-office challenge. Risk-weighted aggregate recovery: $271–872M (per § 6); plaintiff net at 60% waterfall share: $163–523M. The engagement-letter and pre-file action checklist lives on § 18.

Most defendants settle within 18 months of the claim-construction hearing — not years later at trial.

Recovery here isn't a single jury swing — it's a cascade that compounds at the claim-construction ruling. Once the Delaware judge fixes the meaning of the patent language at Month 15–18, the cleanest-read defendants settle to avoid being bound by a loss, and every later wave negotiates against that same precedent. The bulk of the cohort resolves by Month 30; the tail closes through Month 48. The bar chart sizes the dollar outcomes across the eight defendants that anchor the damages base; the curve shows the cadence at which the full 23-defendant cohort resolves.

A concrete scenario — DraftKings' General Counsel, Day 1 to Day 30.

A day-by-day walkthrough of what actually happens when our notice letter lands — this same pressure sequence is mapped for every one of the 23 defendants, not just theorized. DraftKings is the example here: Wave-1a target · $4.77B FY24 revenue · NASDAQ: DKNG · three of the four asserted patents read on DraftKings' product, and its own Feb 13 2026 shareholder letter already admits the infringing architecture — so every day of silence compounds into an SEC-disclosable material contingency.

Five actions. Four closing windows. Eight-week week-by-week plan — ready to execute.

Six weeks to fully-executed engagement letter · 120 days to Wave-1a filing · nothing goes un-owned. Multiple independent clocks converge inside the next 180 days.