NantWorks, LLC v. Niantic, Inc.
- Laurel Beeler
- 3:20-cv-06262
- U.S. District Court · Northern District of California
- 12
In NantWorks v. Niantic, Judge Beeler granted Niantic summary judgment, ruling asserted augmented-reality patent claims ineligible under 35 U.S.C. § 101.
NantWorks, LLC and Niantic, Inc.; the ruling granted Niantic summary judgment on NantWorks’s asserted ’051 patent claims.
What happened
NantWorks sued Niantic, claiming that Niantic’s Pokémon Go and Harry Potter: Wizards Unite apps infringed the ’051 patent, which concerns displaying virtual objects in digital representations of real-world surroundings.
Niantic argued that the patent claims covered the abstract idea of receiving location information, matching materials to that information, and displaying the materials. NantWorks argued that the claims described specific technological improvements for making augmented reality more realistic.
Judge Laurel Beeler granted Niantic’s motion for summary judgment. She ruled that the asserted claims were directed to an abstract idea and lacked an inventive concept, so they were not eligible for patent protection under Section 101. The court did not reach the other pending motions.
The detailed version
- NantWorks, LLC v. Niantic, Inc. · No. 3:20-cv-06262
- Laurel Beeler
- July 9, 2024
Background
NantWorks sued Niantic for allegedly infringing the ’051 patent through Niantic’s augmented-reality game apps Pokémon Go and Harry Potter: Wizards Unite. The apps use a mobile device’s camera and global-positioning system, along with an augmented-reality platform, to place virtual objects into digital representations of the user’s real-world surroundings.
The ’051 patent, titled “Interference Based Augmented Reality Hosting Platforms,” concerns incorporating virtual objects into a digital representation of an actual scene around a device. NantWorks alleged that the patent improved augmented reality by selecting virtual objects based on surrounding conditions and enhancing or suppressing their presentation based on context.
The remaining asserted claims were claims 7, 22, 23, and 25, all of which depended from claim 1. Claim 1 described an augmented-reality platform with a repository of virtual objects and a server that would obtain information about a device’s environment and location, determine context, identify relevant virtual objects, decide whether to alter their presentation, and cause the device to render them accordingly.
Summary-judgment standard
The court explained that summary judgment is appropriate when there is no genuine dispute about any material fact and the moving party is entitled to judgment as a matter of law. The court must view the evidence in the light most favorable to the nonmoving party and may not weigh conflicting evidence or decide witness credibility.
Patent eligibility under Section 101
Section 101 of the Patent Act permits patents for new and useful processes, machines, manufactures, compositions of matter, and improvements. The court applied the two-step test from Alice Corp. v. CLS Bank International.
At step one, the court asks whether the claims are directed to a patent-ineligible concept, such as an abstract idea. At step two, if the claims are directed to an abstract idea, the court asks whether the claim elements, individually or as an ordered combination, include an “inventive concept”—a feature that makes the claim significantly more than the ineligible concept itself.
Step one: abstract idea
Niantic argued that claim 1 was representative of the asserted claims, and NantWorks did not dispute that point. Niantic characterized claim 1 as three abstract steps: receiving location information, matching material to that information, and displaying the material based on the information.
The court agreed with Niantic. It held that the asserted claims were directed to the abstract idea of receiving information about a location and displaying materials based on that information. The court viewed the claims as filtering or selecting information relevant to a location or context, which it characterized as a human problem rather than a specific improvement to computing technology.
The court rejected NantWorks’s argument that the claims provided a specific technological improvement for making augmented reality more realistic. It noted that NantWorks relied on concepts such as seamless linking of separate augmented realities and interference between scene elements and virtual elements, but the court found those concepts were not included in the asserted claims.
The court also addressed the dependent claims. It found that claim 7’s use of device orientation still involved using location information to display information; claims 22 and 23’s use of time still involved displaying information; and claim 25’s use of money was also abstract.
Step two: inventive concept
At step two, the court held that the claims recited only generic computer components applied to the abstract idea of receiving location information and displaying materials based on it. The court found no specific improvement in computer technology and concluded that the abstract ideas themselves did not supply an inventive concept.
The court also said it did not rely on one of Niantic’s experts in reaching its conclusions.
Disposition
Judge Laurel Beeler granted Niantic’s summary judgment. The court did not reach the other pending motions in light of that ruling.
Read the full 12-page opinion on CourtListener, the free public archive maintained by the Free Law Project.