LaVoult.com, LLC v. Meta Platforms, Inc.

Background

LaVoult.com, LLC alleged that Meta Platforms, Inc., Instagram LLC, and WhatsApp, Inc. infringed Patent No. 8,751,594, which LaVoult alleged it owned by assignment. The patent describes a messaging system with two modes. In regular mode, messages are saved in memory. In confidential mode, messages are temporarily stored, displayed, and automatically deleted when either user exits that mode.

LaVoult alleged that Instagram’s “vanish mode” and WhatsApp’s “disappearing messages” feature infringed Claim 1. The defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which allows dismissal when a complaint does not state a legally sufficient claim. They argued that the patent was ineligible under 35 U.S.C. § 101.

Patent-Eligibility Analysis

The court applied the two-step framework from Alice Corp. v. CLS Bank. At the first step, the court asks whether a patent claim is directed to an abstract idea. At the second step, it asks whether the claim contains an “inventive concept” that transforms that abstract idea into a patent-eligible invention.

Because LaVoult did not dispute that Claim 1 was representative, the court analyzed Claim 1 rather than each claim separately. The court described Claim 1’s focus as a communication system that switches between regular and confidential messaging, temporarily stores confidential messages, and automatically deletes them when a user exits confidential mode.

At the first Alice step, the court held that Claim 1 was directed to an abstract idea. The court reasoned that people could perform the claimed process manually—for example, by marking handwritten messages as private and shredding them after they were read. The computer-related steps, including automatic deletion, did not make the idea nonabstract. The court also found that the claimed dual-mode messaging and deletion process did not improve how computers functioned; computers were used as tools to implement the process.

At the second Alice step, the court held that Claim 1 lacked an inventive concept. The ordered sequence of receiving and sending regular messages, switching to confidential mode, receiving and sending confidential messages, and deleting those messages was part of the abstract idea itself. The references to a server, memory, temporary storage, and automatic deletion were generic or conventional computer components and functions. The court concluded that the patent was ineligible for protection under Section 101.

Amendment and Disposition

The court also considered whether LaVoult should be allowed to amend its complaint. LaVoult did not identify a proposed claim construction or additional factual allegations that would cure the problem. Its proposed clarification that the patent used permanent and temporary memory would not change the court’s analysis because memory was a generic computer component.

The court found amendment futile and therefore granted the defendants’ motion to dismiss with prejudice and without leave to amend. The order disposed of Docket No. 21.