Game Play Network, Inc. v. Lien Games Racing LLC, 1:23-cv-00323

Plaintiff Game Play Network, Inc. (GPN) sued Potent Systems, Inc. and Lien Games Racing LLC, alleging infringement of four patents related to gaming systems.
Defendants moved to dismiss the complaint under FRCP 12(b)(6), arguing the asserted patents claimed ineligible subject matter under 35 U.S.C. § 101.
The Court granted Defendants' motion to dismiss, finding the claims directed to abstract ideas lacking inventive concepts, and denied GPN's request to amend the complaint as futile.
GPN filed a Motion for Reconsideration and Reargument, claiming legal errors, unaddressed factual disputes, and improper denial of leave to amend.
The Court, applying the stringent standards for reconsideration, reviewed the alleged errors and new evidence, if any, to determine whether reconsideration was warranted.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Need for Claim Construction	Claimed the Court ignored terms requiring construction before ruling on § 101 eligibility	Argued GPN failed to propose specific constructions or show material impact	No error; Plaintiff too vague
Factual Disputes	Asserted factual disputes over alleged technological improvements precluded dismissal	Asserted GPN offered only conclusory, not well-pleaded, factual allegations	No genuine dispute; legal issue only
Leave to Amend	Claimed right to amend to include further factual allegations about inventiveness	Asserted amendment would be futile; no specifics offered by GPN	Properly denied; request too generic
Standard for Reconsideration	Alleged manifest error and need to prevent injustice	Maintained no misunderstanding or new law/evidence to support reconsideration	Did not meet high burden for relief

Trinity Info Media, LLC v. Covalent, Inc., 72 F.4th 1355 (Fed. Cir. 2023) (For Rule 12(b)(6), patentee must propose specific construction and explain its relevance to § 101 eligibility.)
MyMail, Ltd. v. ooVoo, LLC, 934 F.3d 1373 (Fed. Cir. 2019) (If claim construction is raised at motion to dismiss, district court must address it to the extent needed for § 101 analysis.)
Berkheimer v. HP Inc., 881 F.3d 1360 (Fed. Cir. 2018) (Factual disputes regarding improvements described in specification may preclude Rule 12 dismissal for patent eligibility.)
Aatrix Software, Inc. v. Green Shades Software, Inc., 882 F.3d 1121 (Fed. Cir. 2018) (Plausible factual allegations about inventiveness can defeat eligibility dismissal.)
LaSpina v. SEIU Pennsylvania State Council, 985 F.3d 278 (3d Cir. 2021) (Leave to amend may be denied if amendment would be futile.)