Intellectual Ventures I LLC v. Erie Indemnity Co.

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IV sued insurance companies, alleging infringement of three patents. The insurers moved to dismiss IV’s 581 patent infringement claims for lack of standing and argued that all three patents were directed to ineligible subject matter under 35 U.S.C 101. After concluding that IV did not own the rights to the 581 patent, the district court dismissed those claims for lack of standing, finding that a particular assignor did not assign any rights in or to the then-pending application to the 581 patent, thus breaking a chain in ownership of the patent. The court also found the three patents ineligible under section 101. The Federal Circuit agreed that IV had not been assigned any rights in the 581 patent and lacked standing. The court also agreed that the 434 patent, reciting “no more than routine steps involving generic computer components and conventional computer data processing activities to accomplish the well-known concept of creating an index and using that index to search for and retrieve data” was patent-ineligible. The 002 patent, reciting the abstract idea of remotely accessing user-specific information, identifies a need, but the claims fail to provide a concrete solution to address that need. View "Intellectual Ventures I LLC v. Erie Indemnity Co." on Justia Law