By Memorandum Order entered by The Honorable Colm F. Connolly in Sound View Innovations, LLC v. Delta Air Lines, Inc., Civil Action No. 19-659-CFC (D.Del. April 3, 2020) (consolidated), the Court denied the Federal Rule of Civil Procedure 12(b)(6) motions to dismiss filed by Defendants in three actions. Defendants argued in support of their motions that the claims asserted against them are invalid under 35 U.S.C. § 101 because the patent claims asserted fail to claim patentable subject matter. Id. at *1. Specifically, Defendants argued that the claims asserted are “patent-ineligible because they are directed to abstract ideas and do not contain an inventive concept.” Id. at *5.
In denying the motions, the Court determined that it need not and “does not decide whether the asserted patents are directed to abstract ideas because statements in the specifications of the asserted patents that are alleged or incorporated by reference in the complaints plausibly establish that the asserted claims contain an inventive concept.” Id. Thus, accepting as true the facts in the complaints and viewing those facts in the light most favorable to plaintiff, the Court concluded that dismissal of the claims was not proper via a motion to dismiss. Id. at *6-11.
A copy of the Memorandum Order is attached.