Samsung Electronics Co, Ltd. v. Blaze Mobile, Inc.

Background

Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. brought an action seeking a declaration that they did not infringe eight patents owned by Blaze Mobile, Inc. and Michelle Fisher. Blaze answered and filed counterclaims alleging infringement.

The patents concern various mobile-device functions. The three patents at issue in this order were the ’849, ’556, and ’612 Patents, which the court called the “Advertising Patents.” Blaze alleged that these patents improved the reliability and performance of non-browser mobile applications used to deliver advertisements, including advertisements that could be displayed when a mobile device was offline.

Samsung moved under Federal Rule of Civil Procedure 12(c), which allows judgment on the pleadings when the pleadings show that the moving party is entitled to judgment as a matter of law. Samsung argued that the Advertising Patents were invalid under 35 U.S.C. § 101 because they claimed an abstract idea and lacked an inventive concept.

The court’s analysis

The court rejected Blaze’s argument that Samsung’s motion was premature because the parties had not completed claim construction. Blaze identified disputed terms including “non-browser based application,” “secure element,” and “secure element application,” but did not explain how construing those terms would change the Section 101 analysis.

The court also rejected Blaze’s general argument that factual disputes prevented the court from deciding patent eligibility on the pleadings. It explained that, at this stage, the court had to accept the allegations as true and view them favorably to Blaze, but that patent eligibility could still be resolved on a Rule 12(c) motion when the allegations did not prevent a legal determination.

Applying the two-step framework from Alice Corp. v. CLS Bank, the court first asked whether the claims were directed to patent-ineligible subject matter. It concluded that the Advertising Patents’ claims were directed to the abstract idea of targeted advertising on a mobile device. The claims described maintaining an advertisement on a remote server, selecting it based on targeting information and user input, sending it to a non-browser application, and displaying it on the mobile device. The use of computer and mobile-device components did not, by itself, make the claims non-abstract.

At the second step, the court considered whether the claims contained an “inventive concept”—an element or combination of elements that transformed the abstract idea into a patent-eligible application. The court recognized that the claims used generic computing components and conventional activities such as storing, selecting, receiving, sending, and displaying information.

Nevertheless, the court found Blaze’s alleged inventive concept plausible at the pleading stage. Blaze alleged that selecting individualized advertisements at a remote server and delivering them to a single non-browser application could reduce memory use, improve mobile-device performance, and allow advertisements to be displayed when the device lost its internet connection. The patent specification described related memory and offline-access advantages. The court held that these plausible and specific allegations were sufficient to defeat Samsung’s motion at this stage.

Disposition

The court denied Samsung’s motion for judgment on the pleadings as to the Advertising Patents. The order did not decide Samsung’s motion as to the other Patents-in-Suit; the court stated that it would issue a separate order addressing them. Judge Edward J. Davila signed the order.