Software Rights Archive, LLC v. Facebook, Inc.

Background

Software Rights Archive, LLC (SRA) brought a patent-infringement action against Facebook, Inc. The three patents shared the title “Method and Apparatus for Indexing, Searching and Displaying Data” and generally concerned indexing, searching, and displaying data based on relationships among items. The patents described using indirect citation and hyperlink relationships to improve search results.

SRA initially asserted 74 claims from the three patents. The court required SRA to limit its election to 30 claims. The case was later stayed while proceedings occurred before the United States Patent and Trademark Office. After those proceedings, only claims 26, 28, and 31 of the ’571 Patent remained asserted; the opinion states that the other elected claims had been found unpatentable. SRA later filed an amended complaint and sought permission to add nine more claims as contingent claims.

Facebook’s Motion for Judgment on the Pleadings

Facebook moved under Federal Rule of Civil Procedure 12(c), which allows judgment based on the pleadings after the pleadings are closed. Facebook argued under 35 U.S.C. § 101 that the asserted and contingent claims were patent-ineligible because they were directed to an abstract idea and lacked an inventive concept.

The court applied the two-part framework from Alice Corp. v. CLS Bank International. First, it asks whether the claims are directed to an abstract idea. If they are, the court asks whether the claim elements, individually or in combination, contain an “inventive concept”—something significantly more than the abstract idea itself.

Alice Step One

The court held that the asserted claims were directed to the abstract idea of collecting, analyzing, and displaying information, specifically information about relationships between items. The claims used information such as URLs, hyperlinks, and web objects, analyzed relationships among that information, and displayed the results.

The court rejected SRA’s argument that the claims described technological improvements to search methods. It found that the claims did not identify an improvement to the computer’s operation, such as improved memory availability or processing speed. Instead, they described broad functions performed by conventional computers, including identifying, accessing, analyzing, generating, and displaying information.

The court also rejected SRA’s arguments concerning improved data structures and displays. It found that “cluster links” were values produced through statistical analysis and did not improve the computer’s functioning. The claims also did not specify a particular new way to display information. The court concluded that the contingent claims likewise remained directed to the same abstract idea, despite their references to particular relationships, numerical representations, recursive analysis, or website visits.

Alice Step Two

The court held that the claims lacked an inventive concept. SRA identified the use of indirect relationships, cluster links, related data structures, and display arrangements as unconventional improvements. The court found, however, that these features were part of—or merely narrowed—the same abstract idea of collecting and analyzing relationships between items.

The court further found that SRA’s allegations about visual-display improvements relied mainly on the patent specifications rather than on limitations actually recited in the asserted claims. Because the claims did not include the alleged display technology in sufficient detail, those allegations did not establish an inventive concept.

The court therefore concluded that the asserted and contingent claims failed both steps of the patent-eligibility analysis and were invalid under Section 101.

Other Motions and Disposition

The court granted Facebook’s motion for judgment on the pleadings. It denied as futile SRA’s motion for leave to amend its claim election and infringement contentions because the contingent claims would meet the same Section 101 fate as the asserted claims.

The court also granted the parties’ motions to file documents under seal. Applying the lower “good cause” standard because the documents concerned nondispositive motions, the court found that the materials contained confidential and proprietary Facebook business information, including source code and details about its source-code structure.

The clerk was directed to enter judgment in Facebook’s favor and close the case.