Riggs Technology Holdings, LLC v. Relias Learning LLC
- Paul Gardephe
- 1:21-cv-06229
- U.S. District Court · Southern District of New York
- 4
In Riggs Technology Holdings v. Relias Learning, Judge Gardephe ordered Riggs to explain why its patent case should not be dismissed with prejudice.
Riggs must explain by November 20, 2023, why its complaint should not be dismissed with prejudice for failure to state a claim. Relias’s request for a conference about renewing its motion for judgment on the pleadings was denied without prejudice. The complaint was not dismissed by this order.
What happened
Riggs Technology Holdings, LLC v. Relias Learning LLC concerns Riggs’s claim that Relias infringed a patent covering remote training systems. Relias argued that the patent covers an abstract idea and lacks an inventive concept.
The court explained that final judgments invalidating the same patent can prevent later infringement actions from continuing. The Federal Circuit had affirmed one such ruling and dismissed another appeal as moot after that ruling.
Judge Paul G. Gardephe ordered Riggs to show cause by November 20, 2023, why the complaint should not be dismissed with prejudice for failure to state a claim. The court denied Relias’s request for a conference about renewing its motion for judgment on the pleadings without prejudice, lifted the stay, and did not yet dismiss the case.
The detailed version
- Riggs Technology Holdings, LLC v. Relias Learning LLC · No. 1:21-cv-06229
- Paul Gardephe
- Nov. 14, 2023
Background
Riggs Technology Holdings, LLC alleged that Relias Learning LLC infringed U.S. Patent No. 7,299,067, which concerns methods and systems for managing remote training provided through electronic data networks. The complaint alleged that Relias operated online and software-based training platforms, products, and services that infringed one or more patent claims.
Relias moved for judgment on the pleadings under Rule 12(c), arguing that the patent claims were directed to an abstract idea and lacked an inventive concept. The court stayed the case while appeals proceeded in two other cases involving the same patent. In those cases, district courts had dismissed Riggs’s infringement claims after finding that the patent was not directed to patent-eligible subject matter.
The Federal Circuit later affirmed the ruling in one of those cases, concluding that the patent was directed to the abstract mental process of managing remotely provided training and lacked an inventive concept. On the same day, the Federal Circuit dismissed the other appeal as moot, stating that the first decision had resolved the patent’s eligibility.
Court’s Analysis
The court stated that a final order holding a patent invalid can have preclusive effect in other pending or later infringement actions involving the same patent. Because the ’067 Patent had been held invalid in final judgments affirmed on appeal, the court concluded that Riggs had to explain why its complaint should not be dismissed.
Order
The court ordered Riggs to show cause by November 20, 2023, why the action should not be dismissed with prejudice for failure to state a claim based on the patent’s invalidity. The court did not dismiss the complaint in this order.
The court denied Relias’s request for a conference concerning renewal of its motion for judgment on the pleadings without prejudice. It also directed the clerk to lift the stay and terminate the letter motions at Docket Nos. 32 through 35. The court stated that, if the complaint is dismissed, Relias will submit a proposed briefing schedule for an anticipated motion seeking attorneys’ fees.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.