Netflix, Inc. v. Broadcom Inc., et al.

Summary

The United States District Court for the Northern District of California grants Broadcom Inc. and VMware LLC's motion to dismiss Netflix, Inc.'s first amended patent-infringement complaint, granting leave to amend in part. The court concludes that the asserted claims of Netflix's three Cherkasova patents are inadequately pleaded beyond claim 1 and that claim 1 of each patent is directed to patent-ineligible subject matter under 35 U.S.C. § 101. The opinion addresses patent eligibility under the Alice framework and the pleading standards for patent infringement.

Holdings

1. Netflix did not plausibly plead infringement of the other asserted claims because the complaint merely recited their claim elements and offered conclusory allegations without factual allegations explaining how the accused products met the materially different limitations.
2. Claim 1 of each Cherkasova patent is directed to the abstract idea of collecting and analyzing information, and therefore fails Alice step one.
3. Claim 1 of each Cherkasova patent does not contain an inventive concept and fails Alice step two.
4. Claim 16 of the '893 patent is directed to the abstract idea of allocating workload across a plurality of resources and lacks an inventive concept.
5. Claim 10 of the '122 patent is directed to the abstract idea of providing a graphical user interface for remote control and mapping and lacks an inventive concept.

Questions Presented

1. Whether Netflix plausibly pleaded infringement of claims other than claim 1 of the '424, '707, and '891 patents.
2. Whether claim 1 of each of the '424, '707, and '891 patents is directed to a patent-ineligible abstract idea and lacks an inventive concept under the Alice framework.
3. Whether claim 16 of the '893 patent is directed to a patent-ineligible abstract idea and lacks an inventive concept under the Alice framework.
4. Whether claim 10 of the '122 patent is directed to a patent-ineligible abstract idea and lacks an inventive concept under the Alice framework.

Disposition

other