On May 2, 2016, the District Court for the District of Delaware denied defendant’s motion for attorneys’ fees under § 285. Plaintiff had originally filed suit against defendant, arguing that it infringed two patents generally directed to computer-based messaging systems. The defendant filed a motion for summary judgment arguing that the claims were directed to the abstract idea of “collecting and saving information relating to a business process,” and thus were invalid under § 101. The court ultimately granted defendant’s motion.
Afterward, the defendant filed a motion for attorneys’ fees under § 285, alleging that the case was exceptional because plaintiff “knew its claims were objectively invalid over the prior art.” In its motion denying attorneys’ fees, the court noted that it had expended considerable effort in reaching its invalidity determination, and that “the § 101 analysis is an evolving state of the law and a difficult exercise.” Accordingly, the court was not persuaded that plaintiff’s claims were exceptionally meritless, particularly in light of the changing landscape of § 101.
YYZ LLC v. Pegasystems Inc., 1-13-cv-00581 (D. Del. May 2, 2016).