Riggs Technology Holdings, LLC v. Vagaro, Inc.

Background

Riggs Technology Holdings, LLC brought a complaint against Vagaro, Inc. Vagaro moved to dismiss, arguing that U.S. Patent No. 7,299,067 was invalid under 35 U.S.C. § 101, the patent-law provision governing patent-eligible subject matter. The patent describes methods and systems for providing education, instruction, and training remotely through handheld wireless devices.

The patent describes transmitting training information from a handheld device to a server, identifying and authenticating the user, recording training information, and providing records about the training. The parties agreed that claim 1 represented the patent’s claims for purposes of the analysis, and neither party argued that the court needed to interpret the patent’s terms before deciding patent eligibility.

Court’s Analysis

The court applied the two-step test from Alice Corp. v. CLS Bank. First, it asked whether the claims were directed to an abstract idea. The court characterized the claims as directed to managing remote training. In the court’s view, the claimed activities—verifying identity, keeping records, and providing training records—were longstanding business activities and methods of organizing human activity.

The court rejected Riggs’s argument that the patent was instead focused on remote communications or accessing training anytime and anywhere. The court noted that the claims did not expressly require training to be available at all times or everywhere. It also concluded that using handheld devices did not avoid abstraction because those devices were preexisting technology, and the claims used them for their ordinary purpose.

Second, the court asked whether the claims included an inventive concept—an additional feature sufficient to transform an abstract idea into a patent-eligible invention. The court concluded that they did not. In its view, the claims merely applied the idea of managing remote training to a handheld device, a server, data storage, network communication, and user authentication—equipment and capabilities that were generic or close to generic.

Ruling

The court held that every claim in the ’067 patent was invalid under Section 101. Judge Thomas S. Hixson granted Vagaro’s motion to dismiss and dismissed the complaint without leave to amend. The court also vacated the scheduled hearing because it found oral argument unnecessary.

Classification Note

This order is classified as a procedural order under the stated convention because it disposed of the case through a motion to dismiss, even though the court addressed the patent’s eligibility under Section 101.