Distributing Information Using Common Components Is a Patent-Ineligible, Abstract Idea

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.”