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S.D.N.Y.Procedural orderFiled Jan. 3, 2025

Linfo IP, LLC v. Trustpilot, Inc.

Judge
Jesse Furman
Docket
1:24-cv-02796
Court
U.S. District Court · Southern District of New York
Pages
2
Intellectual PropertyMotion to DismissCivil Procedure
In one sentence

In Linfo IP v. Trustpilot, Judge Furman dismissed Linfo’s complaint after ruling that the patent claims covered an abstract idea.

Who this affects

Linfo IP, LLC and Trustpilot, Inc.; the complaint was dismissed, judgment was entered in Trustpilot’s favor, and the case was closed.

What happened

Linfo IP, LLC sued Trustpilot, Inc. over claims involving the 428 Patent. The court’s judgment states that those claims were directed to an abstract idea and therefore were not eligible for patent protection.

Trustpilot asked the court to dismiss the complaint, and the court granted that motion. Linfo asked for permission to amend its complaint, but the court found the problem with its claims was substantive and that amendment would be futile.

Judge Jesse Furman’s court denied Linfo’s request for permission to amend, entered judgment for Trustpilot, and closed the case.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Linfo IP, LLC v. Trustpilot, Inc. · No. 1:24-cv-02796
Judge
Jesse Furman
Date
Jan. 3, 2025

Background

The judgment refers to claims in the 428 Patent. It states that the claims were directed to an abstract idea and, on that basis, were not eligible for patent protection.

Motions and Analysis

Trustpilot moved to dismiss Linfo’s complaint. The court granted the motion because the 428 Patent’s claims were not eligible for patent protection.

Linfo requested permission to amend its complaint. The court explained that amendment should generally be allowed when justice requires, but that granting or denying permission is within the district court’s discretion. It found that the problem with Linfo’s claims was substantive, making amendment futile. The court also noted that Linfo’s request did not identify facts that could cure the problems with the claims. In addition, the court had previously allowed Linfo to amend and had warned that Linfo would not receive another opportunity to address issues raised by the motion to dismiss.

Disposition

Judge Jesse Furman’s court granted Trustpilot’s motion to dismiss, dismissed the complaint, denied Linfo’s request for leave to amend, entered judgment in favor of Trustpilot, and closed the case. The judgment does not use the phrase “with prejudice” or “without prejudice.”

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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