Motivation Innovations, LLC v. Petsmart, Inc., C.A. No. 13-957 -SLR, January 12, 2016.
Robinson, J. Defendant’s motion for judgment on the pleadings is granted.
The patent-in-suit is directed to redeeming discount offers by associating a machine-readable code with identifying items to be offered at a discount. Defendant asserts that the technology is patent ineligible under Alice. The court finds that the claims are directed to the use and redemption of coupons, which consists of the abstract idea of using coupons to provide discounts. The concept of using a machine-readable ID code to take discount offers and track customer purchasing habits do not negate preemption. The claims are invalid under section 101.