Sound View Innovations, LLC v. Facebook, Inc., C.A. No. 16-116 – RGA, August 30, 2016.

Robinson, J. Defendant’s motion to dismiss for lack of patentable subject matter pursuant to section 101 is granted.  Oral argument took place on July 1, 2016.

Defendant seeks to dismiss one of the seven patents-in-suit.   The disputed technology relates to managing electronic community interest or community information preference. Defendant argues under Alice that the asserted claims are abstract as they are directed to the abstract idea of managing ideas and preferences among members of a community. The court agrees noting that the patent does not provide computer specific solutions.  Plaintiff contends that patent claims include inventive concepts, namely determining the community information preferences of a user based on information preferences of that user, information preferences of other users related to that user, and at least one decision rule. It further employs relationships between users that are defined by a user, rather than determined by characteristics of user profiles. The court finds that neither concept is inventive.  That the method is a new means of transmitting information is irrelevant. The claimed computer components also do not render the asserted claims patent eligible.