Inmar Brand Solutions, Inc. overcame an early hurdle in its patent infringement lawsuit against competitor Quotient Technology Inc. when the court denied Quotient’s motion to dismiss under Section 101 of the federal patent statute.
Judge John F. Murphy, a Pennsylvania federal district judge sitting by designation in Delaware, issued the order denying Quotient’s motion.
A Bunsow De Mory team of partners Denise De Mory and Marc Belloli, counsel Li Guo, and associate Brenda Entzminger crafted the winning arguments to defeat Quotient’s motion.
Inmar is the exclusive licensee of a patented coupon-processing system developed by Intelligent Clearing Network, Inc. In September 2023, Inmar sued Quotient in Delaware district court for infringing United States Patent Nos. 10,846,729 (“the ’729 Patent”), 9,070,133 (“the ’133 Patent”), and 9,098,855 (“the ’855 Patent”). The claimed inventions describe computer systems for clearing coupons, and the claims specify how those systems are configured or how they operate.
In its motion to dismiss, Quotient argued that the asserted patent claims are directed to ineligible subject matter under the Supreme Court’s decision in Alice Corp. v. CLS Bank International, 573 U.S. 208 (2014) that interpreted 35 U.S.C.§ 101. Under Alice‘s two-part test, a patent can be invalidated if it’s directed to an abstract idea and if there is no added inventive concept.
Judge Murphy agreed with Inmar that the asserted patent claims are not directed to an abstract idea and thus Quotient’s arguments failed at “step one” of the Alice inquiry. “Inmar’s patent claims . . . are directed to the non-abstract idea of processing coupons with a computer system configured in a particular way to overcome flaws in prior art systems. The system’s configuration reduces coupon fraud and facilitates coupon clearing in ways that humans cannot,” Judge Murphy wrote.
Read the full decision here. For news coverage of this win: Law360 (subscription required).
The case is Inmar Brand Solutions, Inc. v. Quotient Technology Inc., No. 1:23-cv-00994 (D. Del.).
