Linquet Technologies, Inc. v. Tile, Inc.

Background

Linquet Technologies, Inc. sued Tile, Inc. for allegedly infringing U.S. Patent No. 10,163,318, concerning a cloud-based system for detecting the location of an object using a wireless tag and electronic devices. Linquet alleged that the invention improved the efficiency, scalability, and privacy of cloud-based object-location systems. After Tile moved to dismiss the original complaint under 35 U.S.C. § 101, Linquet filed a first amended complaint. Tile then moved to dismiss the amended complaint, arguing that all claims of the patent covered patent-ineligible subject matter.

The parties focused on Claim 1, which describes a wireless tag associated with an object, a first electronic device associated with the tag, and a second electronic device not associated with the tag. The devices detect signals, determine their positions, determine the tag’s status or identifier, and transmit location information to an external device. Claim 2 adds a controller that makes the tag detectable to the second device depending on whether the tag is outside the first device’s predetermined range.

Legal Standard

The court applied the two-step test from Alice Corp. v. CLS Bank International for determining patent eligibility under Section 101. First, the court asks whether the claim is directed to an abstract idea or another excluded category. If it is, the court asks whether the claim contains an inventive concept—an element or combination of elements that adds significantly more than the ineligible concept itself.

The court also explained that patent eligibility can sometimes be decided on a motion to dismiss, before formal interpretation of the patent claims, when the complaint, the patent, and materials subject to judicial notice resolve the issue as a matter of law. The court said that conclusory allegations of inventiveness are not enough to prevent dismissal.

Court’s Analysis

The court held that Claim 1 was directed to the abstract idea of tracking or locating an object. In the court’s view, using markers and identifiers to keep track of belongings was a longstanding practice, and Claim 1 implemented that concept through steps such as detecting signals, determining position, determining status, and transmitting information. Putting those steps on computers or electronic devices did not make the claim non-abstract.

The court rejected Linquet’s argument that the patent provided a technological solution to a technological problem. It found that neither the patent’s specification nor the amended complaint identified a problem specific to computers or computer networks. The court characterized Linquet’s allegations about improved privacy, efficiency, and scalability as conclusory rather than factual allegations showing an improvement in computer functionality.

The court also held that Claim 1 lacked an inventive concept. The claim used conventional components arranged in a conventional way to implement object tracking. The court concluded that the claim did not describe anything beyond the abstract idea of tracking implemented with generic electronic devices.

The court reached the same conclusion for Claim 2. Its added controller and conditional detectability feature remained directed to electronic object tracking. The court found that the added functional steps and generic technology did not make the claim inventive, and that Linquet had not explained how the components operated together in an unconventional way.

Disposition

Because the ’318 patent was directed to an abstract idea and lacked an inventive concept, the court dismissed the first amended complaint under Section 101 and the Alice framework. The court granted leave to amend, permitting Linquet to file an amended complaint by October 8, 2021. The order stated that failure to meet that deadline would result in dismissal with prejudice under Rule 41(b).