OpenTV, Inc. v. Pinterest, Inc.

Summary

The United States District Court for the District of Delaware denied Pinterest, Inc.’s motion for partial judgment on the pleadings in OpenTV, Inc.’s patent infringement action. Pinterest argued that claims of three OpenTV patents were patent-ineligible under 35 U.S.C. § 101. The opinion addresses representative claims and the Alice framework for patent eligibility, including targeted advertising technology under the ’212 patent.

Holdings

1. Claim 44 may be treated as representative of the other challenged claims of the '212 Patent because Pinterest made a prima facie showing that the claims were substantially similar and linked to the same alleged abstract concept, and OpenTV did not present a meaningful, nonfrivolous argument for separate treatment.
2. Representative Claim 44 of the '212 Patent is directed to the abstract idea of targeted advertising.
3. Judgment on the pleadings was improper as to the '212 Patent because the pleadings plausibly alleged that the claimed advertising manager could be a non-generic component supplying an inventive concept, and whether it was well-understood, routine, or conventional presented factual questions requiring further inquiry and discovery.
4. The court declined to decide the eligibility of the '503 and '817 Playlist Patent claims before claim construction because the parties disputed the meaning of 'social connections,' and construction could affect the character of the claimed subject matter, the presence of an Internet-specific solution, and the conventionality inquiry.

Questions Presented

1. Whether the claims of the '212 Patent could be held patent-ineligible under 35 U.S.C. § 101 on a Rule 12(c) motion.
2. Whether Claim 44 of the '212 Patent could properly be treated as representative of the other challenged claims.
3. Whether the '503 and '817 Playlist Patent claims could be held patent-ineligible before claim construction where the parties disputed the meaning of 'social connections.'

Disposition

denied