NetSoc, LLC v. LinkedIn Corporation
- Vince Chhabria
- 3:20-cv-00483
- U.S. District Court · Northern District of California
- 1
In NetSoc v. LinkedIn, Judge Chhabria granted LinkedIn’s motion to dismiss because the asserted patents were invalid under section 101.
NetSoc, LLC and LinkedIn Corporation; the ruling concerned the validity of NetSoc’s ’107 and ’344 patents.
What happened
NetSoc, LLC sued LinkedIn Corporation, alleging that LinkedIn infringed two patents. The patents shared the same title and description as another patent that the court had previously held invalid.
The court said the two patents covered the abstract idea of a social network and did not contain an inventive concept that turned that idea into a patent-eligible invention. It relied on its earlier ruling and the Supreme Court’s decision in Alice Corp. v. CLS Bank International.
Judge Vince Chhabria granted LinkedIn’s motion to dismiss and held that the ’107 and ’344 patents were invalid under section 101 of the Patent Act.
The detailed version
- NetSoc, LLC v. LinkedIn Corporation · No. 3:20-cv-00483
- Vince Chhabria
- June 26, 2020
Background
NetSoc alleged that LinkedIn infringed two patents, identified in the opinion as the ’107 and ’344 patents. LinkedIn filed a motion to dismiss. The opinion states that the two patents shared the same title and specification—the patents’ written description—with Patent No. 9,218,591, which the court had invalidated in an earlier related proceeding.
Legal issue and reasoning
Under section 101 of the Patent Act, a patent must claim patent-eligible subject matter. The court applied the framework described in Alice Corp. v. CLS Bank International, asking whether the claims were directed to an abstract idea and, if so, whether they included an inventive concept that transformed that idea into a patent-eligible application.
The court concluded that the ’107 and ’344 patents were directed to the abstract idea of a social network. It further concluded that, for the same reasons given in the earlier related proceeding, the patents lacked an inventive concept. The court therefore held that both patents were invalid under section 101.
Disposition
The court granted LinkedIn’s motion to dismiss. The opinion does not state whether the dismissal was with or without prejudice. The order was signed by United States District Judge Vince Chhabria.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.