Google LLC v. Sonos, Inc.

Background

Google brought a patent-infringement suit against Sonos involving five patents. Sonos’s motion concerned Google’s second cause of action, which asserted infringement of the ‘489 patent, titled “Generating Media Content Availability Notification.” The patent describes determining whether media content is available from different content sources and notifying a user when availability changes. Google alleged infringement of at least claim 15.

Claim 15 describes computer-readable media containing instructions to receive a user’s media selection and content-delivery preferences, request availability information from multiple online content sources using user-account data, receive that information, and generate a notification when the media is available to at least one account.

The Parties’ Positions

Sonos argued that the ‘489 patent was ineligible under 35 U.S.C. § 101 because it claimed the abstract idea of collecting information about media availability, analyzing that information, and notifying the user. Google argued that the patent solved problems specific to the Internet and large networks, including searching across geographically distributed sources with different release times, formats, and access restrictions. Google also identified targeted searching and notifications about newly available content as alleged inventive concepts.

Legal Standard

The court considered the issue under Rule 12(b)(6), which allows dismissal when a complaint does not state a legally sufficient claim. Patent eligibility under § 101 is a legal question, although factual questions can sometimes arise about whether claimed activities were well understood, routine, and conventional. The court applied the two-step test from Alice Corp. v. CLS Bank International: first, determine whether the claim is directed to an abstract idea; second, determine whether the claim contains an “inventive concept”—something more than the abstract idea and routine, conventional activity.

Court’s Analysis

At step one, the court concluded that the ‘489 patent was directed to collecting information, analyzing it, and presenting the results through a notification. Relying principally on Federal Circuit decisions concerning information collection, analysis, and presentation, the court treated those activities as an abstract idea. The court rejected Google’s argument that addressing an Internet-related problem alone made the patent eligible. It found that Google had not adequately explained how the patent improved computer functionality, as opposed to using computers to overcome people’s limitations in manually searching for media.

At step two, the court found no inventive concept. It concluded that selecting information based on content sources and generating a notification were not enough to transform the abstract idea into a patent-eligible invention. The patent provided few specifics about how its steps—receiving, requesting, receiving, and using information—were performed. The court therefore found that the claim relied on routine computer functions rather than a specific, nonconventional technological arrangement.

The court also rejected Google’s argument that deciding eligibility at the motion-to-dismiss stage or before claim construction was premature. Google did not identify a specific claim-construction dispute that would affect the eligibility analysis, and it presented no factual issue requiring resolution. The court further stated that differences between the patent and the prior art did not show an improvement in computer functionality and cautioned that patent eligibility should not be confused with novelty.

Disposition

Judge Edward M. Chen granted Sonos’s motion to dismiss. The order states that the motion disposed of Docket No. 39.