Realtime Tracker, Inc. v. RELX, Inc. d/b/a LexisNexis
- Paul Engelmayer
- 1:21-cv-08815
- U.S. District Court · Southern District of New York
- 1
In Realtime Tracker v. RELX, Judge Engelmayer held the patent claims ineligible under § 101 and dismissed the amended complaint with prejudice.
Realtime Tracker, Inc. could not continue the patent claims at issue in this case or file a second amended complaint. RELX, Inc. prevailed on its motion to dismiss, and the case was closed.
What happened
Realtime Tracker, Inc. sued RELX, Inc., doing business as LexisNexis, over patent-related claims involving the patent at issue.
The court ruled that the claims covered subject matter that patent law does not allow and were therefore invalid under § 101. It granted RELX’s motion to dismiss the amended complaint with prejudice, meaning the complaint cannot be refiled in a new version. Because of that ruling, the court did not decide whether Juris Suite infringed the patent if the patent were valid, and the case was closed.
Judge Paul Engelmayer issued the ruling on March 7, 2023.
The detailed version
- Realtime Tracker, Inc. v. RELX, Inc. d/b/a LexisNexis · No. 1:21-cv-08815
- Paul Engelmayer
- Mar. 7, 2023
Background
Realtime Tracker, Inc. brought patent-related claims against RELX, Inc., doing business as LexisNexis. The judgment refers to the parties’ dispute over whether Juris Suite infringed the patent, assuming the patent was valid.
Ruling
The court found that the claims at issue were directed to patent-ineligible subject matter and were invalid under § 101 of the Patent Act. The court granted RELX’s motion to dismiss the amended complaint.
The court stated that the dismissal rested on an inherent deficiency in the patent itself and could not be corrected by filing a differently drafted second amended complaint. The court therefore dismissed the amended complaint with prejudice. Because of this ruling, it did not decide the parties’ arguments about whether Juris Suite infringed the patent if the patent were valid. The case was closed.
Classification
This is classified as a procedural order because the court granted a motion to dismiss. The dismissal nevertheless resolved the patent-eligibility issue under § 101 and barred filing a second amended complaint.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.