On January 3, 2025, District Judge Jesse M. Furman granted Defendant Trustpilot, Inc.’s (“Trustpilot”) Motion to Dismiss Linfo IP, LLC’s (“Linfo”) complaint alleging that Trustpilot directly and indirectly infringed U.S. Patent No. 9,092,428 (the “’428 patent”). Linfo IP, LLC v. Trustpilot, Inc., No. 24-CV-2796 (S.D.N.Y. Jan. 3, 2025).
The ’428 patent claims “a computer-assisted method for discovering information in a text context.” The method “provides users with interface objects to act on the discovered information, such as extracting, displaying or hiding, or highlighting or un-highlighting words or phrases in a text content as needed to aid information handling.” Id. at *2.
Trustpilot hosts a website where users can rate businesses on a scale from one to five stars, post reviews about those businesses, filter a business’s reviews based on star ratings, and highlight comments based on other selected metrics, which Linfo alleged infringes the claims of the ’428 patent. Id. Trustpilot moved to dismiss Linfo’s complaint on the ground that the claims of the ’428 patent are unpatentable because they are directed towards an abstract idea. Id. at *3. The Court evaluated the claims at issue under both steps of Alice and agreed with Trustpilot that the claims are directed to unpatentable subject matter. Id.
Under Step 1 of Alice the Court found that the ’428 patent’s claims of “provid[ing] users with interface objects to act on the discovered information, such as extracting, displaying or hiding, or highlighting or un-highlighting words or phrases in a text content as needed to aid information handling” were directed to an abstract idea. Id. at *5. More specifically, it found that the Federal Circuit has held repeatedly that “claims focused on collecting information, analyzing it, and displaying certain results of the collection and analysis are directed to an abstract idea.” Id. (citing SAP Am., Inc. v. Investpic, LLC, 898 F.3d at 1167(Fed. Cir. 2018)). Additionally, the court held that the ’428 patent’s system merely automates a mental process, finding that “[a] human can manually survey customer reviews; sort reviews based on particular attributes; and extract, highlight, and compile certain text associated with those attributes into lists, charts, and word clouds.” Id. at *6.
The Court then progressed to Step 2 of Alice to determine whether the patent claims contained an “inventive concept” and found that they did not. Id. at *7. The court noted that Linfo only provided conclusory allegations that the ’428 patent claimed an inventive concept sufficient to transform it into a patent-eligible process. Indeed, the court found that Linfo relied on steps that are routine and directed to merely implementing the abstract idea of data collection, manipulation, and display on a computer. Id.
As such, the court granted Trustpilot’s Motion to Dismiss and found the claims of the ’428 patent to be directed towards an unpatentable abstract idea. Id. at *9.
The case is Linfo IP, LLC v. Trustpilot, Inc., No. 24-CV-2796 (S.D.N.Y. Jan. 3, 2025).
