Luxer Corporation v. Package Concierge, Inc.
1:24-cv-00603
D. Del.Feb 6, 2025Background
- Luxer Corporation (Luxer) sued Package Concierge, Inc. for allegedly infringing U.S. Patent No. 11,625,675, which covers a system and method for electronically controlling access to a storage room for package delivery and retrieval.
- The accused technology was Package Concierge’s Access-Controlled Package Room, a system designed to automate deliveries and secure packages in buildings, featuring electronic locks and access codes.
- Package Concierge moved to dismiss the infringement claim under Rule 12(b)(6), arguing the patent claims are ineligible under 35 U.S.C. § 101 for being directed to an abstract idea and lacking an inventive concept.
- The court analyzed Claim 1 as representative of all asserted patent claims, as Luxer did not sufficiently argue why other claims should be treated differently.
- The court applied the Supreme Court’s two-step Alice/Mayo framework to assess Section 101 subject matter eligibility at the motion-to-dismiss stage.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Claim 1 is representative | Other claims have distinctive physical/functional aspects | All claims are substantially similar, reciting abstract idea | Claim 1 treated as representative |
| Patent eligibility under Alice Step One | Patent covers a specific machine/system, not abstract | Merely automates credential-verification for access | Directed to an abstract idea (not eligible) |
| Patent eligibility under Alice Step Two | Combination is inventive; factual dispute precludes dismissal | All elements and combinations are conventional | Lacks inventive concept; no patentable application |
| Weight of Patent Office determinations | Reliance on Patent Office’s decision to grant patent | Courts are not bound by Patent Office Section 101 decisions | Court is not bound; performs de novo review |
Key Cases Cited
- Alice Corp. Pty. Ltd. v. CLS Bank Int’l, 573 U.S. 208 (2014) (establishes the two-step test for determining patent eligibility for abstract ideas under Section 101)
- Mayo Collaborative Servs. v. Prometheus Labs., Inc., 566 U.S. 66 (2012) (sets framework for evaluating when an otherwise abstract idea includes an inventive concept)
- Enfish, LLC v. Microsoft Corp., 822 F.3d 1327 (Fed. Cir. 2016) (clarifies when a claim is a patent-eligible improvement to computer technology)
- McRO, Inc. v. Bandai Namco Games Am. Inc., 837 F.3d 1299 (Fed. Cir. 2016) (distinguishes patent-eligible technological improvements from claims directed at abstract ideas)
- Universal Secure Registry, LLC v. Apple Inc., 10 F.4th 1342 (Fed. Cir. 2021) (patent for secure identity verification held ineligible as an abstract idea)
- Affinity Labs of Texas, LLC v. DirectTV, LLC, 838 F.3d 1253 (Fed. Cir. 2016) (guides on analyzing claims directed to abstract results vs. technological improvements)