U.S. District Court Rules in Favor of Meta in Patent Infringement Suit over Identity Verification

U.S. District Court Rules in Favor of Meta in Patent Infringement Suit over Identity Verification

The U.S. District Court for Northern District of California, has ruled in favor of Meta Platforms Inc., in an infringement suit from Street Spirit IP LLC over a patent that protected identity verification and management online.

Street Spirit had also sued LinkedIn, Match and eHarmony for alleged infringement of an identity-verification patent of social networks.

The Court found that Street Spirit’s patent claims were directed at an abstract idea and lacked a sufficiently transformative concept to be an eligible patent.

The Presiding Senior Judge William Alsup of the U.S. District Court for the Northern District of California, dismissed without leave to amend Street Spirit’s copyright infringement case against Meta, determining Street Spirit’s claims were abstract ideas that weren’t patent-eligible.

“The patent protected a method for receiving and confirming identity data before authorizing access to the user’s requested resources. But, restricting access to resources remains, at its core, an abstract idea,” Judge William Alsup said.

Street Spirit had claimed that Meta and Instagram had infringed on U.S. Patent No. 9,282,090, entitled ‘Methods and Systems for Identity Verification in a Social Network Using Ratings.’

Street Spirit originally sued Meta, LinkedIn, Match and eHarmony for alleged infringement of an identity-verification patent of social networks.

In February 2023, Street Spirit sued Meta, accusing the tech-giant to maintain, operate and administer products and services for providing customer relationship management in a social network system that infringed one or more claims of the ‘090 patent’, and termed it to be direct, indirect, and wilful infringement.

Moreover, Street Spirit had also filed for a separate suit against Meta subsidiary Instagram with similar allegations.

According to the Court, both actions involved the same parties, lawyers, patent and associated products and services, with the complaints being ‘substantially the same.’

Meta filed a motion to dismiss the complaint on each of the allegations on the grounds that the ‘090 patent’ claims are ineligible under Section 101 of the Patent Act.

The Court, following the two-step test for evaluating patent claims under Section 101 of the Patent Act from the Supreme Court’s 2014 decision in Alice Corp. Pty. Ltd. vs. CLS Bank International, determined the claims were directed to an abstract idea and lacked an inventive concept that transformed said abstract idea into a patent-eligible application.

First, while determining whether the claims were directed to a patent-ineligible concept, the Court assessed whether the elements of the claim did more than reciting a ‘well-understood, routine, conventional activity.’

The Court was of the view that the requirement was not satisfied by claims that use generic, functional language to achieve the solution without reciting how that result was actually achieved.

The Court observed, “Thus, if the claims are directed to an abstract idea at the first step of the Alice analysis, and the claims lack an inventive concept sufficient to transform the abstract idea into a patent-eligible application at the second step of the Alice analysis, the claims are ineligible under Section 101.”

While applying the Alice Corp (Supra) second test step, the Court considered whether the elements of the claim contained ‘an inventive concept sufficient to transform the claimed abstract idea into a patent-eligible application,’ assessing whether the elements went beyond merely reciting a ‘well-understood, routine, conventional activity.’

While Street Spirit emphasized that the claimed invention was ‘directed towards specifically constructed physical devices that provide a technological improvement to an identification-secured network,’ the Judge opined that there were no physical devices that were being claimed.

Therefore, the Court determined that the patent was simply claiming to accelerate and expand the process of determining whether a user’s identity is sufficiently verified based on an evolving evaluation of the user, finding the patent.

“Generating and updating an identity rating fails to add a technological improvement or otherwise provide something more to transform the nature of these claims,” the Judge averred.

The Court concluded that Street Spirit failed to ‘meaningfully engage in an Alice analysis and failed at substantively address Meta’s step one and step two contentions’ and instead broadly argued that the claims advance the prior art on three grounds.

The Court ruled that the mere application of identity verification within a technological environment does not elevate the concept to being non-abstract, and despite Street Spirit’s argument, the patent does not teach a solution to cybercrime.

Further, the Court found that Street Spirit’s argument that ‘further discovery is needed to verify the United States Patent and Trademark Office (USPTO) finding that the prior art does not include the claimed novel method,’ was irrelevant to the Alice inquiry.

The Court determined that ‘a finding of novelty from the USPTO is distinct from a finding of patent eligibility.’

Hence, the Court was of the view that Street Spirit’s arguments were unavailing and concluded by stating that the patent-eligibility analysis (or, more precisely, the lack thereof) that Street Spirit purports to be relevant was not conducted in the context of the contemporary case law.

Meta was represented by Attorney Lisa Kim Anh Nguyen of Allen & Overy, in Palo Alto.

Street Spirit was represented by Attorney, Susan S.Q. Kalra of Ramey, in Houston.