Riggs Technology Holdings, LLC v. Relias Learning LLC

Background

Riggs Technology Holdings, LLC alleged that Relias Learning LLC, doing business as ContinuingEducation.com, infringed U.S. Patent No. 7,299,067. The patent concerns methods and systems for managing remote training through electronic data networks.

Riggs had also brought infringement actions involving the same patent against other defendants in the District of Massachusetts and the Northern District of California. The Northern District of California dismissed the related case after finding every claim of the patent invalid under 35 U.S.C. § 101. The District of Massachusetts later reached the same conclusion regarding patent eligibility. Riggs appealed both decisions to the Federal Circuit, and the appeals were being handled as companion cases.

Relias had separately moved for judgment on the pleadings under Federal Rule of Civil Procedure 12(c). Relias argued that the patent claims covered an abstract idea and therefore involved subject matter that patent law does not protect. That argument was the same basic issue addressed in the related cases.

Motion to Stay

Riggs asked the court to stay, or pause, this case while the Federal Circuit considered the related appeals. Riggs argued that a Federal Circuit decision upholding the related dismissals could result in dismissal of this case and that Relias would not be prejudiced by waiting.

Relias opposed the stay, arguing that little would be gained and that the stay’s duration was indefinite. Relias also argued that its pending motion did not depend on the issues before the Federal Circuit, although its motion relied on the argument that the patent claims were directed to an abstract idea and lacked an inventive concept.

The court applied the factors used in the Second Circuit for deciding whether to stay a case, including the parties’ interests, the burden on the defendant, the courts’ interests, the interests of nonparties, and the public interest. The court found significant overlap between this case and the related appeals because all concerned whether the same patent was directed to patent-eligible subject matter.

The court concluded that the Federal Circuit’s decision would likely significantly affect its ruling on Relias’s motion. It also found that the stay would not be indefinite because it would end when the Federal Circuit resolved the related appeals. Although the stay could delay Relias’s effort to resolve the case, Relias had not shown other prejudice, and the stay would preserve the parties’ and the court’s resources.

Ruling

Judge Paul G. Gardephe granted Riggs’s motion for a stay pending resolution of the related Federal Circuit appeals. In light of the stay, the court denied Relias’s motion for judgment on the pleadings on the ground that the patent claims were directed to patent-ineligible subject matter, with leave to renew once the stay is lifted. The court denied Relias’s motion for oral argument as moot.

The court directed the parties to submit a joint status letter every 90 days concerning the appeals and to submit letters within one week after the Federal Circuit issues its decision, addressing the decision’s effect on this case.