In June and July 2015, Plano Encryption Technologies, LLC filed separate lawsuits against three banks located in the Eastern District of Texas: American Bank of Texas (2:15-cv-01273), Citizens National Bank (2:15-cv-01168), and Independent Bank (2:15-cv-01382). Throughout that same time period, according to subsequently filed declaratory judgment actions, Plano Encryption sent letters to multiple banks alleging infringement by the companies’ online and mobile banking applications of several patents purportedly owned by Plano Encryption. Each of the three Texas complaints asserts two patents (5,991,399; 5,974,550) from among the six mentioned in the NPE’s letters against the applications of the defendant banks. The patents generally relate to security in online transactions.