Judge Robinson Invalidates Patent
February 3, 2016
Publication| Intellectual Property
In Motivation Innovations, LLC v. Petsmart, Inc., C.A. No. 13-957-SLR (D. Del. Jan. 12, 2016), Judge Robinson granted the defendant’s motion for judgment on the pleadings and declared the plaintiff’s patent invalid under 35 U.S.C. § 101. In holding the patent invalid, Judge Robinson found that the patent was directed toward the abstract idea of “using coupons to provide discounts.” Judge Robinson rejected the plaintiff’s attempt to add limitations to how the patented method worked, finding that the limitations did not detract from the fact that the ultimate function of the patent is the “use and redemption of coupons.”
Judge Robinson held that “the asserted limitations of the asserted claims recite conventional or routine activity or computer technology.” Judge Robinson also found that the patent required no “special programming” of the machine that determines whether a discount offered by the barcode applied to the transaction. Finally, Judge Robinson rejected the plaintiff’s argument that the patent was novel because it disclosed the previously unknown concepts of (1) using a single coupon to redeem discount offers on multiple products, and (2) creating a database to track an individual consumer’s purchasing history when the customer redeems those coupons. Judge Robinson noted that these concepts are not “an internet (or computer) centric problem,” and using “routine and conventional computer technology to redeem discounts and track customer spending habits” did not render the patent claims valid.
Analysis: This case mirrors the nationwide trend of courts invalidating patents under 35 U.S.C. § 101.