Luxer Corporation v. ButterflyMX, Inc., 1:24-cv-00602

Luxer Corporation alleged that ButterflyMX, Inc. infringed U.S. Patent No. 11,625,675, which covers a system for controlling access to a storage room using an electronic lock and credential authentication.
Luxer’s system, the “Luxer Room,” allows recipients and couriers to access package storage rooms via access codes and records entry events.
ButterflyMX launched a similar product, which Luxer claimed infringed their patent.
ButterflyMX moved to dismiss the lawsuit under Rule 12(b)(6), arguing the patent is invalid under 35 U.S.C. § 101 as directed to an abstract idea.
The court was tasked with analyzing whether the patent claims were patent-eligible, focusing on whether they were directed at an abstract idea and if they contained an “inventive concept.”

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are the patent claims eligible under § 101?	Luxer argued the claims are for a tangible machine/system for automated access, improving the technology of package storage by allowing any size package.	ButterflyMX argued the claims only automate longstanding, abstract ideas of credential-based access via conventional technology.	The claims are directed to an abstract idea and are not patent-eligible.
Should Claim One be treated as representative of all claims for eligibility analysis?	Luxer did not meaningfully contest using Claim One as representative, focusing on similarities in arguments for all claims.	ButterflyMX argued all claims were essentially the same as Claim One and added nothing inventive.	Claim One is representative; analysis applies to all asserted claims.
Does the patent provide an inventive concept beyond an abstract idea?	Luxer argued the combination and arrangement of conventional components is novel, and that acceptance by the USPTO shows inventiveness.	ButterflyMX argued the components and operations (signals, locks, authentication) were routine and generic in the industry.	No inventive concept was found; use of generic components in conventional ways.
Should the court defer to the USPTO’s patent-eligibility determination?	Luxer argued the USPTO’s allowance shows eligibility.	ButterflyMX argued courts are not required to defer to the USPTO on eligibility.	Courts owe no deference to USPTO eligibility findings.

Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard for plausibility)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility pleading standard)
Alice Corp. Pty. Ltd. v. CLS Bank Int'l, 573 U.S. 208 (two-step test for patent eligibility under § 101)
Mayo Collaborative Servs. v. Prometheus Labs., Inc., 566 U.S. 66 (foundation for patent eligibility framework)
McRO, Inc. v. Bandai Namco Games Am. Inc., 837 F.3d 1299 (claims must improve relevant technology to be patent-eligible)
Enfish, LLC v. Microsoft Corp., 822 F.3d 1327 (focus on technological improvement for § 101)
Universal Secure Registry, LLC v. Apple Inc., 10 F.4th 1342 (credential authentication abstract under § 101)
Ericsson Inc. v. Commc’n Tech. Holdings Ltd., 955 F.3d 1317 (automating human tasks is not patent-eligible)
Berkheimer v. HP Inc., 881 F.3d 1360 (representative claim analysis for § 101)