Bluebonnet Internet Media Services, LLC v. Pandora Media, LLC

Background

Bluebonnet alleged that Pandora infringed three patents describing essentially the same computer system for generating media playlists based on user ratings. Some claims also described sharing playlists with another user. For purposes of the motion, the court accepted Bluebonnet's identification of three representative claims: claim 1 of U.S. Patent No. 9,405,753; claim 2 of U.S. Patent No. 9,547,650; and claim 72 of U.S. Patent No. 9,779,095.

Patent eligibility

The court applied the patent-eligibility framework from Alice Corp. v. CLS Bank International. First, it held that the claims were directed to an abstract idea: customizing media playlists according to a user's preferences. The claims described a playback interface that streams media, a rating system that stores user ratings, and a playlist generator that creates playlists based on those ratings. In the court's view, applying this idea to computer-based media playlists did not make it patentable.

The court also held that the claims lacked an inventive concept—an element or combination of elements that adds significantly more to an abstract idea and transforms it into a patent-eligible application. The claims described basic steps such as streaming media, rating media, generating playlists, and sharing playlists at a high level of generality. The computer components were functional and generic, and the claims did not identify a particular technological improvement to playlist generation. The court concluded that the claims were invalid under 35 U.S.C. § 101.

Bluebonnet argued that its expert's assertions about the system's novelty and whether it was well-understood, routine, or conventional created factual issues that prevented judgment on the pleadings. The court rejected that argument, explaining that the patent-eligibility question was one of law and that Bluebonnet's factual assertions did not identify a legally sufficient inventive concept in the claims themselves.

Rulings

The court granted Pandora's motion for judgment on the pleadings. It denied Pandora's motion for leave to file an amended answer and motion for summary judgment as moot. Judge Vince Chhabria signed the order.