Yodlee, Inc. v. Plaid Technologies, Inc., C.A. No. 14-1445 - LPS, May 23, 2016.
Burke, M. J. Report and Recommendation recommending that defendant’s motion to dismiss for failure to state a claim be granted-in-part. Oral argument took place on May 4, 2015, and supplemental briefing was filed May 6, 2015.
Defendant challenges patent eligibility under Section 101. Seven patents are disputed. A Markman decision has provided significant guidance in resolving this motion. The disputed technology relates to Internet navigation. With respect to step one in the Alice analysis, the court find this case is a close call where the court cannot clearly conclude as a matter of law that the representative claim is directed to an abstract idea. The court concludes that additional fact-finding is needed as to the scope of preemption, and that defendant has not met is burden to demonstrate the ‘077 patent fails to contain an inventive concept. The court recommends that the motion be denied with respect to this claim. The court finds that claim 8 of the ‘451 patent, claim 20 of the ‘548 patent, and claim 20 of the ‘520 patent are not patent eligible and recommends that the motion be granted with respect to those claims.