Mira Advanced Technology Systems Inc. v. Google LLC
- Andrew Carter
- 1:21-cv-07931
- U.S. District Court · Southern District of New York
- 12
In Mira v. Google, Judge Carter granted Google’s motion and dismissed Mira’s infringement claim after finding its patent claims patent-ineligible.
Mira’s infringement claim against Google was dismissed, and Google obtained a grant of its motion to dismiss.
What happened
Mira Advanced Technology Systems Inc. sued Google LLC, alleging that Google Keep infringed Mira’s patent for a mobile organizer that gives reminders based on a user’s location. Google asked the court to dismiss the case, arguing that the patent was not eligible for protection and that Mira had not adequately pleaded infringement.
The court applied the two-part test for patent eligibility. It found that the patent covered the abstract idea of giving location-based notifications using a remote server and ordinary computer functions, without adding a sufficiently inventive technical feature. Because the claims were invalid, the court did not allow Mira’s infringement claim to proceed.
Judge Andrew L. Carter, Jr. granted Google’s motion and dismissed Mira’s infringement claim. The opinion does not add a prejudice qualifier to that dismissal.
The detailed version
- Mira Advanced Technology Systems Inc. v. Google LLC · No. 1:21-cv-07931
- Andrew Carter
- Aug. 31, 2022
Background
Mira alleged that Google’s Google Keep application infringed claims 1, 3, 5, and 7 of U.S. Patent No. 10,594,854. The patent describes a personal organizer for mobile devices that uses a physical address, geocoding, and global-positioning information to alert a user when the user reaches a location connected to a saved task. Mira asserted direct and indirect infringement, including induced infringement, and alleged that Google’s conduct was willful.
Google moved under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not adequately state a legal claim. Google argued both that the patent claims were invalid under 35 U.S.C. § 101 and that Mira had not sufficiently pleaded direct, indirect, or willful infringement.
Patent Eligibility Analysis
The court applied the two-step Alice/Mayo framework for determining whether patent claims cover patent-eligible subject matter. At the first step, the court concluded that the claims were directed to the abstract idea of location-based reminders. In the court’s view, the patent used a user-entered location, a remote server to obtain GPS coordinates, and a mobile device’s GPS function to display a reminder when the user reached the location.
At the second step, the court considered whether the claims contained an “inventive concept”—a feature that transformed the abstract idea into a patent-eligible invention. The court found that the patent did not describe nonstandard technology or methodology. It reasoned that using a database, transmitting information over a network, and using a computer to perform routine tasks more quickly or accurately did not supply the required inventive concept.
The court therefore held that the patent claims were invalid under § 101. It stated that Mira had no right to pursue its infringement claim against Google because the patent claims were invalid.
Disposition
The court granted Google’s motion and dismissed Mira’s infringement claim. The opinion does not state that the dismissal was with or without prejudice.
Read the full 12-page opinion on CourtListener, the free public archive maintained by the Free Law Project.