Street Spirit IP LLC v. Meta Platforms, Inc.

Background

Street Spirit IP LLC asserted U.S. Patent No. 9,282,090, which concerns identity verification and management. The patent claims describe controlling user access based on identity-verification ratings and thresholds. Street Spirit alleged that Meta Platforms, Inc. and Facebook, Inc. in one action, and Meta Platforms, Inc. and Instagram LLC in the other, directly, indirectly, and willfully infringed one or more patent claims through social-network products and services.

The actions involved the same patent, the same lawyers, and associated accused products and services. The court related the actions and consolidated them for hearings and discovery, but not necessarily for trial. The defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), arguing that the patent claims were ineligible under Section 101 of the Patent Act.

Patent-eligibility framework

The court applied the two-step test from Alice Corp. v. CLS Bank International. At the first step, the court asks whether the claims are directed to an abstract idea or another category of patent-ineligible subject matter. At the second step, if the claims concern an abstract idea, the court asks whether the claim elements contain an inventive concept—something that transforms the abstract idea into a patent-eligible application rather than merely using well-understood, routine, and conventional activity.

A court may decide patent eligibility at the motion-to-dismiss stage when the complaint contains no factual allegations that would prevent resolving eligibility as a matter of law.

Representative claim

Each complaint alleged infringement of “one or more” of claims 1 through 28 but provided specific infringement allegations only for claim 19. The defendants treated claim 19 as representative. Street Spirit objected that the patent included multiple independent claims with features not shared by all the claims.

The court nevertheless evaluated eligibility through claim 19 because Street Spirit did not meaningfully identify or explain the separate significance of limitations in the other claims. The court also stated that it would briefly explain why the other claims did not change the result.

Claim 19 describes a method of providing security against cybercrimes using an identification-secured network. In simplified form, it involves creating member profiles, generating and updating identity ratings, setting access thresholds, and restricting communication with or access to another member based on those ratings and thresholds.

Alice step one

The court agreed with Meta that the claims were directed to the abstract idea of controlling access to resources based on verification of a user’s identity. It compared the claimed process to ordinary practices such as requiring a library card to borrow a book or a passport to cross a border. The court also relied on Federal Circuit decisions characterizing similar identity-verification and access-control processes as abstract ideas.

The court rejected Street Spirit’s argument that the claims were sufficiently technological because they used a network, an identity-management server, multiple user devices, and real-time rating updates. In the court’s view, using identity verification in an internet or computer environment did not make the underlying idea nonabstract. The court also found that the claims did not describe a specific technological improvement like the invention discussed in DDR Holdings, LLC v. Hotels.com, L.P. Instead, the claims applied identity verification through routine online activity to accelerate and expand access control.

Alice step two

The court found that the claims used only generic computer components and functions, including networks, servers, processors, devices, accounts, ratings, thresholds, and access restrictions. Street Spirit did not dispute that characterization or meaningfully address whether the elements formed an inventive combination.

The court considered whether real-time processing and dynamic ratings supplied an inventive concept. It concluded that restricting access based on an evolving evaluation of a user was not a technological improvement and was standard functionality at the time of the invention. According to the court, the patent merely accelerated and expanded familiar identity-verification practices in social networks.

The court also rejected Street Spirit’s arguments that the claims addressed a new problem, operated in real time, or had been found novel by the United States Patent and Trademark Office. The court explained that novelty and patent eligibility are different inquiries and that a new abstract idea remains abstract.

Disposition

The court concluded that the patent claims were directed to an abstract idea at the first step and lacked an inventive concept at the second step. It therefore held the claims ineligible under Section 101. The court granted each motion to dismiss and dismissed Street Spirit’s complaints without leave to amend because it found amendment would be futile.