NetSoc, LLC v. Quora, Inc.
- Vince Chhabria
- 3:19-cv-06518
- U.S. District Court · Northern District of California
- 2
In NetSoc v. Quora, Judge Chhabria held the asserted patent invalid under Section 101, granted dismissal, and denied amendment as moot.
NetSoc, LLC and Quora, Inc.; the ruling invalidated the ’591 patent and resolved NetSoc’s asserted infringement claim described in the order.
What happened
NetSoc, LLC sued Quora, Inc., asserting infringement of the ’591 patent, which described a social network for helping people with life issues. Quora asked the court to dismiss the case.
Judge Chhabria ruled that the patent was directed to the abstract idea of a social network. He also ruled that its claimed features—such as user ratings, directing questions by geography or expertise, and referrals—did not improve computer technology enough to make the claims patent-eligible.
In NetSoc, LLC v. Quora, Inc., Judge Vince Chhabria granted Quora’s motion to dismiss. He denied NetSoc’s request to amend its complaint as moot because the proposed complaint asserted infringement of no other patents.
The detailed version
- NetSoc, LLC v. Quora, Inc. · No. 3:19-cv-06518
- Vince Chhabria
- Jan. 27, 2020
Background
NetSoc asserted infringement of the ’591 patent against Quora. The patent was titled “Method and System for Establishing and Using a Social Network to Facilitate People in Life.” Quora moved to dismiss. NetSoc also sought leave to amend its complaint.
Patent-eligibility ruling
The court held that the ’591 patent was invalid under 35 U.S.C. § 101. Section 101 defines what types of inventions may receive patent protection, subject to judicial exceptions including abstract ideas.
First, the court concluded that the patent was directed to the abstract idea of a social network. The court rejected NetSoc’s position that implementing a social network on a computer kept the claims outside the abstract-idea exception.
Second, the court considered whether the patent’s claimed improvements transformed that abstract idea into a patent-eligible invention. The claims described features allowing users to gain credibility when their answers received positive ratings, directing inquiries to users based on geography or expertise, and making referrals. The court held that these features were also abstract. Although using them on the internet required computer technology, the claims did not improve the technology itself and instead relied on generic network components and functions.
Disposition
The court granted Quora’s motion to dismiss. Because the ’591 patent was invalid and NetSoc’s proposed amended complaint asserted infringement of no other patents, the court denied the motion for leave to amend as moot. Judge Vince Chhabria signed the order on January 27, 2020.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.