March 6, 2024
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The Central District of California recently granted dismissal of patent infringement claims concerning the generation and sharing of video content over social media, finding such content to be patent ineligible under the relevant legislation.
Playvuu, creators of the eponymous video generation app, sued Snapchat’s parent company, Snap Inc., alleging infringement of its patent for video-overlay and augmented-reality technology. Playvuu claimed that Snapchat incorporated certain of its patented video-altering features, which it allegedly demonstrated to the Snap team in a 2016 meeting to discuss a potential acquisition of Playvuu.
After Snap moved to dismiss the patent claim for ineligibility, the California Court analyzed the matter using the U.S. Supreme Court’s two-step framework from Alice Corp. v. CLS Bank Int’l, 573 U.S. 208, 217 (2014).
In step one, the Court considered whether the claims, taken in their entirety, were “directed to a patent-ineligible concept” and rejected the argument that the claims recite an “innovative user interface”. The Court instead found that the claims recite an abstract idea without specific elements – namely, a method for generating and sharing audio/video content on a social network, which did not disclose any novel method to accomplish the known claimed tasks.
In step two, the Court sought to determine whether the additional elements transformed the nature of the claim so as to be patent-eligible. The Court found that the claims were too “results-oriented and suggest[ed] using off-the-shelf components… without providing specific requirements or specialized software for doing so.” As such, the Court found that the claimed idea could not constitute the inventive concept in the abstract and on its own.
Authors: Roy Friedman and Arash Rouhi