NEW YORK, March 23, 2020 - On March 16, Baker Botts secured a dismissal for its client Samsung Electronics America, Inc. in a patent litigation action brought by plaintiff William Grecia (Grecia v. Samsung Electronics America, Inc., filed in the Southern District of New York, Case No. 1:19-cv-02810).
United States District Judge Valerie Caproni granted Samsung’s motion to dismiss Mr. Grecia’s complaint with prejudice, finding that the sole claim of U.S. Pat. No. 8,887,308 (the “’308 Patent”) is invalid because it is directed to patent-ineligible subject matter. Judge Caproni applied the two-step analysis for determining eligibility set forth in the Supreme Court’s Alice and Mayo decisions, and determined that claim 1 of the ’308 Patent fails both steps. First, in finding the claims are directed to an abstract idea, Judge Caproni analogized the asserted claim to a military police officer dealing with authorization to access a secure military base. Second, she found that the claim does not provide an inventive concept, noting that Mr. Grecia’s purported inventive concept is nothing more than the abstract idea of step one.
This is the second summary judgment win for Samsung against Mr. Grecia. In a prior case, Mr. Grecia asserted a related patent (Grecia v. Samsung Electronics America, Inc., filed in the Southern District of New York, Case No. 1:16-cv-09691), and Baker Botts won a finding of patent invalidity for Samsung based on indefiniteness of all of the asserted claims.
“We are happy to again secure a win for our long-standing client Samsung,” said Neil Sirota, a New York based Intellectual Property Partner. “We are especially gratified to do so during the initial pleading stage of the case.”
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