April 27, 2023
Authored and Edited by Alexander M. Boyer; Caitlin E. O'Connell; Elizabeth D. Ferrill
In Sanderling Management LTD. v. Snap, Inc., No. 2021-2173 (Fed. Cir. Apr. 12, 2023), the Federal Circuit affirmed a Central District of California decision dismissing Sanderling’s patent infringement suit because the asserted claims were directed to patent-ineligible subject matter under 35 U.S.C. § 101.
Sanderling accused Snap of infringing three patents related to methods of loading digital image branding functions—used to transform digital images by an icon or filter—to user mobile devices using distribution rules when certain conditions are met. Snap filed a motion to dismiss, asserting that Sanderling’s claims were directed to an abstract idea. The district court granted Snap’s motion and denied leave to amend.
On appeal, under Alice step one, the Federal Circuit agreed with the district court that the claims were not directed to a specific improvement in computer functionality, but instead, to the abstract idea of “identify[ing] when a condition is met and then to distribut[ing] information based on satisfaction of that condition.” Under Alice step two, the Court found that the claims lacked an inventive concept because they simply implemented the abstract idea using common computer components. The Court dismissed Sanderling’s arguments that claim construction and factual disputes precluded dismissal, and that leave to amend should have been granted. The Court found that Sanderling failed to provide proposed constructions or identify any specific facts in dispute. Finally, the Court found that the district court did not err in denying leave to amend because amendment would have been futile—“[n]o amendment to a complaint can alter what a patent itself states.”
Copyright © 2023 Finnegan, Henderson, Farabow, Garrett & Dunner, LLP.
DISCLAIMER: Although we wish to hear from you, information exchanged in this blog cannot and does not create an attorney-client relationship. Please do not post any information that you consider to be personal or confidential. If you wish for Finnegan, Henderson, Farabow, Garrett & Dunner, LLP to consider representing you, in order to establish an attorney-client relationship you must first enter a written representation agreement with Finnegan. Contact us for additional information. One of our lawyers will be happy to discuss the possibility of representation with you. Additional disclaimer information.
June 10-12, 2024
San Francisco
Lecture
Patent Protection for Software-Related Inventions in Europe and the USA Training Course
June 5, 2024
Hybrid
10th Annual Georgia Asian Pacific American Bar Association Gala
May 29, 2024
Atlanta
Webinar
Obviousness of Biologics Inventions: Strategies for Biologics Claims in the U.S., Europe, and China
May 28,2024
Webinar
Due to international data regulations, we’ve updated our privacy policy. Click here to read our privacy policy in full.
We use cookies on this website to provide you with the best user experience. By accepting cookies, you agree to our use of cookies. Please note that if you opt not to accept or if you disable cookies, the “Your Finnegan” feature on this website will be disabled as well. For more information on how we use cookies, please see our Privacy Policy.
Finnegan is thrilled to announce the launch of our new blog, Ad Law Buzz, devoted solely to breaking news, developments, trends, and analysis in advertising law.