Vilox Technologies, LLC v. Salesforce, Inc.

Background

Vilox Technologies, LLC sued Salesforce, Inc. based on claims involving U.S. Patent Nos. 6,760,720 and 7,188,100. The ’720 Patent concerned a computer-implemented method for searching a database, retrieving results, truncating results exceeding a specified limit, and displaying the results. The ’100 Patent concerned generating search results, creating a template from those results, and providing links to data categories.

Salesforce moved to dismiss under the patent-eligibility requirement in 35 U.S.C. § 101 and argued that Vilox had not adequately pleaded infringement.

Patent Eligibility

The court held that the claims in both patents were directed to abstract ideas and therefore were not patentable subject matter under § 101. The court characterized the claims as using computers to perform database searching, display search results, and truncate results. It rejected Vilox’s arguments that the claims reflected technological improvements, reduced central processing unit use, or had no known earlier equivalent.

The court also held that the claims lacked an inventive concept—an element or combination of elements sufficient to transform an abstract idea into a patent-eligible application. It found that the claimed truncation, query-tweaking, and template-creation features did not establish the required inventive concept because the alleged improvements in speed or efficiency resulted from applying an abstract idea on a computer.

Pleading of Infringement

The court separately found that Vilox’s allegations were insufficient to state a claim for direct infringement. Direct infringement of a method claim requires all steps of the claimed method to be performed by, or attributable to, one entity. The court concluded that Vilox’s use of different screenshots, features, and products did not adequately identify a single product meeting all claim elements.

Because Vilox had not plausibly alleged direct infringement, the court also dismissed its claims for induced infringement and contributory infringement.

Disposition

Judge Araceli Martinez-Olguin granted Salesforce’s motion to dismiss. The order dismissed Vilox’s direct, induced, and contributory infringement claims and granted Vilox leave to file an amended complaint within 30 days. The court vacated the June 6, 2024 hearing and denied as moot the parties’ request to appear by Zoom.