Patent Case Summaries October 16, 2024

Patent Case Summaries | Week Ending October 11, 2024

AlexSam, Inc. v. Aetna, Inc., No. 2022-2036 (Fed. Cir. (D. Conn.) Oct. 8, 2024). Opinion by Stark, joined by Lourie and Bryson.

AlexSam filed a complaint accusing Aetna of patent infringement based on Aetna’s “Mastercard Products” and “VISA Products.” The district court granted Aetna’s motion to dismiss the complaint for failure to state a claim. The court ruled that AlexSam could not prevail as to the Mastercard Products because Aetna had an express license via a prior licensing agreement. And the court ruled that AlexSam failed to state a claim of infringement as to the VISA Products because only third-party customers could have directly infringed, and the allegations of indirect infringement were deficient. AlexSam appealed.

The Federal Circuit vacated and remanded portions of the judgment of dismissal. As to the Mastercard Products, the Federal Circuit ruled that the district court erred by resolving the Mastercard licensing issues on the limited information provided in the complaint, its attachments, and the briefing on the motion to dismiss. The Federal Circuit concluded that the scope of the license was “narrower than the district court seems to have understood,” and there are “open issues remaining that need to be resolved before the impact of the license on AlexSam’s allegations can be fully assessed.” Analyzing the license agreement in view of the infringement allegations, the Federal Circuit concluded that “not every act that infringes these claims will necessarily be licensed.” Because the district court misconstrued the scope of the license, the Federal Circuit vacated as to the Mastercard Products.

Turning to the VISA Products, the Federal Circuit noted that it had “not explicitly set out the standard of review applicable to a trial court’s categorization of a complaint’s allegations,” meaning “whether a particular allegation is well-pled and factual, and therefore accorded a presumption of truth, or is instead a legal conclusion or in other respects merely conclusory—and, hence, not credited at the motion to dismiss stage.” The court resolved that issue: “We hold today that our review of trial court determinations on these matters is de novo.”

Reviewing AlexSam’s claims based on Aetna’s VISA Products de novo, the Federal Circuit ruled that the district court erred by concluding that AlexSam failed to allege plausible claims of direct and indirect infringement. The allegations were “sufficiently specific and factual to constitute well-pled allegations,” which “must be credited.” The district court thus erred by granting Aetna’s motion to dismiss AlexSam’s claims directed to the VISA Products.

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