NantWorks, LLC v. Niantic, Inc.

Background

NantWorks sued Niantic for allegedly infringing U.S. Patent No. 10,664,518, titled “Wide Area Augmented Reality Location-Based Services.” The patent concerns mapping augmented-reality objects and displaying them on a device. The accused applications were Niantic’s Pokémon Go and Harry Potter: Wizards Unite games, which use a mobile device’s camera, location system, and augmented-reality platform to show virtual objects in the user’s real-world surroundings.

The asserted claims describe a device that obtains a user’s location, identifies an area of interest and a relevant portion of a tiled map, loads augmented-reality content associated with that portion, and displays the content based on the user’s view. NantWorks’ remaining asserted claims were 7, 14, 16, 19, 26, and 31, along with claims 1, 13, 15, 18, and 30, from which some of those claims depend.

The court had construed several claim terms. Among other things, it construed “augmented reality” as presenting virtual objects in a scene alongside real-world elements, “AR content object” as the virtual object presented to the user, “area of interest” as a real-world space, area, or setting, and “tessellated tiles” as tiles fitted together to cover an area without gaps.

Motion and legal standard

Niantic moved for judgment on the pleadings under Federal Rule of Civil Procedure 12(c). The court explained that this procedure uses the same standard as a motion under Rule 12(b): the court accepts the complaint’s factual allegations as true and views them in the light most favorable to the nonmoving party. Judgment on the pleadings is proper when, even accepting those allegations, the moving party is entitled to judgment as a matter of law.

Patent eligibility under 35 U.S.C. § 101 is generally a legal question, although factual allegations can sometimes prevent deciding it at the pleading stage. The court applied the two-step test from Alice Corp. v. CLS Bank International. First, it asked whether the claims were directed to an abstract idea. If so, it then asked whether the claim elements, individually or together, supplied an “inventive concept”—something significantly more than the ineligible idea itself.

Analysis

At step one, Niantic characterized the claims as “providing information based on a location on a map.” The court agreed. It described the claims as performing four basic steps: obtaining location information, determining a relevant map area, obtaining content for that area, and displaying the content on the map.

The court rejected NantWorks’ argument that the claims were directed to a specific technical improvement in augmented-reality technology. NantWorks argued that loading content by area, rather than downloading all content in advance, allowed more precise placement and avoided overwhelming the device’s memory and computing capabilities. The court held that this alleged improvement was not reflected in the claim language. Instead, the claims recited generic concepts involving a location, a map area, content, and displayed content.

The court relied on Federal Circuit decisions treating location-based information collection, map-area selection, and location-tailored content as abstract ideas. It also distinguished authority involving specific improvements to computer functionality, concluding that the ’518 claims did not identify a comparable improvement. The court said that details in the patent specification could not supply an improvement that the claims themselves did not recite.

At step two, the court held that the claims did not contain an inventive concept. They applied the abstract idea to generic computer components, and NantWorks’ factual allegations established at most that the claimed subject matter was novel. The court emphasized that novelty alone does not make a claim patent-eligible.

Disposition

The court granted Niantic’s motion for judgment on the pleadings. It ruled that the asserted claims of the ’518 patent were invalid under 35 U.S.C. § 101. The order states that this resolved ECF No. 140.