Guvera IP Pty Ltd. v. Spotify, Inc.
- Jesse Furman
- 1:21-cv-04544
- U.S. District Court · Southern District of New York
- 3
In Guvera IP Pty Ltd. v. Spotify USA, Inc., Judge Furman denied reconsideration, finding no controlling-law change and no plausible inventive concept.
Guvera IP Pty Ltd. and Spotify USA, Inc.; the prior dismissal and denial of leave to amend remained in place.
What happened
Guvera IP Pty Ltd. v. Spotify USA, Inc. concerned Guvera’s request to revisit an earlier decision that dismissed its patent case and denied permission to amend the complaint. Guvera argued that a Federal Circuit decision issued the same day changed the law governing patent eligibility.
The court rejected that argument, explaining that the Federal Circuit decision applied existing law to different facts rather than changing controlling law. The court also said Guvera could not plausibly allege that its patent contained an inventive concept because it described only instructions for carrying out the abstract idea of matching content on a computer.
Judge Jesse M. Furman denied Guvera’s motion for reconsideration. The earlier dismissal and denial of permission to amend therefore remained in place.
The detailed version
- Guvera IP Pty Ltd. v. Spotify, Inc. · No. 1:21-cv-04544
- Jesse Furman
- Nov. 16, 2022
Background
The court had previously granted Spotify USA, Inc.’s motion to dismiss Guvera IP Pty Ltd.’s patent case and denied Guvera leave to amend its complaint. Guvera then moved for reconsideration under Rule 59(e) of the Federal Rules of Civil Procedure and Local Civil Rule 6.3.
Guvera argued that the Federal Circuit’s decision in Cooperative Entertainment, Inc. v. Kollective Tech., Inc., issued on the same day as the earlier dismissal, was an intervening change in controlling law that required a different result. A motion for reconsideration is a request to revisit an earlier ruling, and the court explained that it is available only for an intervening change in controlling law, new evidence, clear error, or manifest injustice.
Court’s Analysis
The court held that Cooperative Entertainment did not change controlling law. Instead, it applied settled law to a particular set of facts. The court noted that the Federal Circuit did not describe the decision as changing the governing law, and that later Federal Circuit decisions addressing related issues did not treat it as such.
The court also rejected Guvera’s substantive patent argument. It relied on its earlier conclusion that Guvera’s ’633 Patent recited only instructions for implementing the abstract idea of content matching on a computer. The patent specification and Guvera’s second amended complaint did not contain non-conclusory allegations that the patent claims identified a specific technological improvement. For that reason, the court concluded that Guvera could not plausibly allege an inventive concept.
Disposition
Judge Jesse M. Furman denied Guvera’s motion for reconsideration and directed the Clerk of Court to terminate the motion from the docket. The opinion did not alter the earlier order granting Spotify USA, Inc.’s motion to dismiss and denying Guvera leave to amend.
Classification
This is a procedural order because the court ruled on a motion for reconsideration of an earlier decision rather than issuing a new merits judgment on the patent claims.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.