Swarm Technology LLC v. Amazon.com Incorporated

CourtDistrict Court, D. Arizona
DecidedAugust 22, 2022
Docket2:21-cv-00438
StatusUnknown

This text of Swarm Technology LLC v. Amazon.com Incorporated (Swarm Technology LLC v. Amazon.com Incorporated) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Swarm Technology LLC v. Amazon.com Incorporated, (D. Ariz. 2022).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Swarm Technology LLC, No. CV-21-00438-PHX-DWL

10 Plaintiff, ORDER

11 v.

12 Amazon.com Incorporated, et al.,

13 Defendants. 14 15 Swarm Technology, LLC (“Plaintiff”) holds certain patents related to the design of 16 multiprocessor systems. In this action, Plaintiff accuses Amazon Web Services, Inc. and 17 Amazon.com, Inc. (collectively, “Defendants”) of infringing those patents in violation of 18 35 U.S.C. § 271. 19 Defendants previously moved to dismiss the complaint, arguing that Plaintiff’s 20 patents are ineligible under 35 U.S.C. § 101 because they are directed to an abstract idea— 21 computerizing the well-known project management technique known as a “scrum 22 board”—and do not contain any inventive concepts. (Doc. 29.) In September 2021, the 23 judge previously assigned to the case granted Defendants’ motion. (Doc. 64.) However, 24 the Court also held that “[i]f [Plaintiff] believes it may amend its pleadings to state a viable 25 claim, then it may file a motion for leave to file a first amended complaint to explain how 26 it could address the deficiencies identified in this Order.” (Id. at 9.) 27 Plaintiff took advantage of this opportunity and filed a motion for leave to file a 28 First Amended Complaint (“FAC”) (Doc. 66), along with a proposed FAC (Doc. 66-13). 1 The proposed FAC differs from the original complaint in three notable respects: first, it 2 contains an array of new allegations intended to establish that the patents at issue are 3 eligible under § 101 (Doc. 66-1 at 30-60); second, it is ostensibly supported by detailed 4 declarations from two experts, Dr. Brent Nelson of Brigham Young University (Doc. 66- 5 14) and Dr. Douglas Sylvester of the Sandra Day O’Connor College of Law at Arizona 6 State University (Doc. 66-15); and third, whereas the original complaint accused 7 Defendants of infringing two patents—U.S. Patent No. 9,852,004 (“the ’004 Patent”) and 8 No. 10,592,275 (“the ’275 Patent”)—held by Plaintiff, the FAC adds allegations regarding 9 a third patent, U.S. Patent No. 9,146,777 (“the ’777 Patent”). 10 After Plaintiff’s motion to amend became fully briefed (Docs. 68, 69), the 11 previously assigned judge recused (Doc. 76). The Court has now had an opportunity to 12 review the entire docket in this matter, as well as the parties’ many filings concerning 13 developments in related administrative proceedings (Docs. 81, 84, 86-92) and a recent 14 decision in which a different court rejected the sufficiency of Plaintiff’s allegations 15 regarding patent eligibility under § 101. Juniper Networks Inc. v. Swarm Tech., 2022 WL 16 3031211 (N.D. Cal. 2022). As explained below, although the issue presents a close call, 17 the Court concludes that the proposed FAC contains sufficient factual allegations to survive 18 dismissal under § 101 at the Rule 12(b)(6) stage. Accordingly, Plaintiff’s motion for leave 19 to amend is granted. 20 DISCUSSION 21 I. The September 2021 Dismissal Order And Juniper 22 Before addressing the parties’ current arguments, it is helpful to begin by 23 summarizing the September 2021 dismissal order and the recent Juniper decision, because 24 both help frame the dispute now before the Court. 25 The September 2021 order begins by discussing the nature of the two patents then 26 at issue, the ’004 Patent and the ’275 Patent. (Doc. 64 at 1-2.) It explains that they 27 “purport[] to cover a ‘processing architecture’ whereby ‘autonomous co-processors . . . 28 proactively retrieve tasks from a task pool populated by a central processing unit.’” (Id.) 1 Next, the September 2021 order identifies the relevant test for evaluating these patents’ 2 eligibility under § 101. (Id. at 3.) It explains that, under Alice Corp. Pty. Ltd. v. CLS Bank 3 Int’l, 573 U.S. 208 (2014), the “two-step analysis” consists of (1) assessing whether the 4 claims at issue are directed to a patent-ineligible concept, such as an abstract idea; and (2) 5 if so, assessing whether the elements of the claims nevertheless “contain an inventive 6 concept . . . that is sufficient to ensure that the patent in practice amounts to significantly 7 more than a patent upon the ineligible concept itself.” (Id., cleaned up.) 8 As for the first step, the September 2021 order explains that the dispute turns on 9 whether the patents may be characterized as “abstract because [they] simply computerize[] 10 a well-known project management technique known as a ‘scrum board,’” which “works by 11 first having a project manager list tasks on sticky notes and post them on one side of a 12 board. As the team members collect and perform each task, they individually move the 13 notes from the ‘incomplete’ side of the board to the other side, the ‘complete’ side of the 14 board.” (Id. at 4-5.) Although Plaintiff argued that “the scrum board comparison is a 15 mischaracterization of its Patents” because they “provide[] a ‘multiprocessor system with 16 the speed of parallel processing’ without traditional downsides,” the Court disagreed, 17 concluding that the “Patents are directed towards the abstract idea of a scrum board. 18 Although the Patents are aimed at allocating computer processing power in an efficient 19 way, scrum boards also allocate human resources in an efficient way. The Patents therefore 20 are not aimed at a ‘specific implementation of a solution’ as much as they consist of 21 ‘generalized steps to be performed on a computer using conventional computer activity.’ 22 The idea of a scrum board does not become non-abstract when limited to the computer 23 environment. Although there is no doubt that computers could perform tasks organized by 24 a scrum board more efficiently than humans, the idea itself remains abstract.” (Id. at 5-6.) 25 As for the second step, Plaintiff argued the inventive-concept requirement should 26 be deemed satisfied for three reasons: (1) it had overcome previous objections to its patents 27 under 35 U.S.C. §§ 102-03; (2) “the Patents ushered in a ‘new parallel processing 28 paradigm’ that dramatically increases computer performance”; and (3) “whether its Patents 1 represent something that genuinely improves computer performance is a question of fact, 2 which would preclude a finding that the Patents are ineligible on a motion to dismiss.” (Id. 3 at 7-8.) The Court disagreed. As for Plaintiff’s first argument, the Court identified 4 “caselaw show[ing] that whether a patent is novel or nonobvious [under §§ 102/103] is 5 irrelevant to the Alice analysis.” (Id. at 7.) As for Plaintiff’s second argument, the Court 6 held that “it is not enough that [Plaintiff] claim its Patents are novel. The Court has already 7 found that the Patents are abstract in that they describe a computerized scrum board, and 8 simply applying an abstract idea to computers, standing alone, cannot be an innovative 9 concept.” (Id.) As for Plaintiff’s third argument, the Court held that although “the 10 Complaint alleged that the Patents are designed to address two problems related to parallel 11 computer processing”—namely, “too much processing bandwidth was being occupied in 12 assigning tasks to ‘slave’ processors” and “many processors were being left idle while 13 awaiting a task”—these allegations did not appear in the patents themselves. (Id. at 7-8.) 14 The Court further held that “[a]lthough [Plaintiff] makes the conclusory assertion that its 15 Patents contain claim elements that, when combined, ‘are not well-understood, routine or 16 conventional,’ [Plaintiff] fails to elaborate.” (Id.

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Swarm Technology LLC v. Amazon.com Incorporated, Counsel Stack Legal Research, https://law.counselstack.com/opinion/swarm-technology-llc-v-amazoncom-incorporated-azd-2022.