Language Technologies Incorporated v. Microsoft Corporation
4:23-cv-00520
| D. Ariz. | Mar 31, 2025Background
- Language Technologies, Inc. (LTI) sued Microsoft in the District of Arizona for infringement of two patents related to computerized text parsing and display technology.
- The patents cover methods for phrase prediction and improving text display for readability in computer systems, specifically addressing problems in grouping text for human comprehension.
- The court initially dismissed LTI’s original complaint under Rule 12(b)(6) for failure to allege patent-eligible subject matter but allowed LTI to amend its complaint.
- LTI’s First Amended Complaint added detailed factual allegations describing the patented methods as technological improvements, not abstract ideas or conventional practices.
- Microsoft renewed its motion to dismiss, arguing the amended allegations were insufficient and the patents remained ineligible as abstract ideas under 35 U.S.C. § 101 and Alice v. CLS Bank framework.
- The Court denied the motion to dismiss, finding the plausibility of LTI’s factual allegations on both non-abstractness and inventive step sufficient to proceed beyond the pleading stage.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Patent eligibility under § 101 | Patents describe specific technical improvements, not abstract ideas | Patents cover abstract ideas using known linguistic rules; no inventive concept | Sufficient factual issues pled; motion denied |
| Sufficiency of factual pleadings | Complaint details how claims improve technology, referencing specific algorithms and results | New facts are just expansions of old, conclusory contentions | Factual allegations plausible; dismissal not proper |
| Inventive concept (Alice Step 2) | Detailed steps and ordered combination were not routine or conventional at time of invention | Steps are generic, not novel, and just use known grammatical rules | Need not decide at this stage given factual issues |
| Improvement over prior art | Patents solve technological problems not addressed by prior art | Patents don't identify any specific problem in prior art | Allegations plausible; issue not ripe for dismissal |
Key Cases Cited
- Alice Corp. Pty. Ltd. v. CLS Bank Int'l, 573 U.S. 208 (framework for patent eligibility, abstract ideas vs. inventive concept)
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standards for plausibility)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading standard for factual sufficiency)
- Gottschalk v. Benson, 409 U.S. 63 (mathematical algorithms as abstract ideas)
- Parker v. Flook, 437 U.S. 584 (conventional computer implementation not inventive)
- Diamond v. Diehr, 450 U.S. 175 (patent-eligibility for technological process improvement)
- Mayo Collaborative Servs. v. Prometheus Labs., Inc., 566 U.S. 66 (patent eligibility and natural laws)
- Enfish, LLC v. Microsoft Corp., 822 F.3d 1327 (software inventions and improvements to technology)
- McRO, Inc. v. Bandai Namco Games Am. Inc., 837 F.3d 1299 (concrete improvement by computer-implemented algorithms)