By Memorandum Opinion entered by The Honorable Gregory M. Sleet in Inventor Holdings, LLC v. Bed Bath & Beyond Inc., Civil Action No. 14-448-GMS (D.Del., August 21, 2015), the Court granted Defendant Bed Bath & Beyond Inc.'s motion for judgment on the pleadings after finding that the patent-in-suit, U.S. Patent No. 5,862,582 ("the '582 patent"), is invalid under 35 U.S.C. § 101 because it claims a patent-ineligible subject matter (an abstract idea) and does not contain an "inventive concept" to meet the framework set forth in Alice Corp. v. CLS Bank Int'l, 134 S.Ct. 2347, 2355 (2014). In doing so, the Court found that "the '582 patent – and all of its seventy-three claims – are invalid under § 101, as they claim the abstract idea of paying for remote orders at local retailers, without reciting meaningful limitations to render the idea patent eligible." Id. at *6.
A copy of the Memorandum Opinion is attached.
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