IP Law Daily, PATENT—D. Del.: Dismissal denied in web crawler patent dispute, (Dec 17, 2025)

By Kevin M. Finson, J.D.

Claims relating to automated systems for generating sales leads using web crawlers were not shown to be invalid for being directed at an abstract idea because the plaintiff plausibly alleged the patents recited technological improvements.

A seller of automated predictive analysis systems for generating sales leads using internet crawlers failed to show a competitor’s patents were invalid at the pleading stage, the U.S. District Court in Wilmington, Delaware, has held. While the claims were directed to the abstract idea of collecting and analyzing information, it was at least plausibly alleged that they possessed an inventive concept in the form of technological improvements to the underlying technology (ZoomInfo Technologies LLC v. Zenleads Inc., No. 1:25-cv-00324-JCG (D. Del. Dec. 15, 2025)).

ZoomInfo Technologies, LLC (ZoomInfo) was the owner of U.S. Patents Nos. 10,380,609 (the ’609 patent) and 11,392,964 (the ’964 patent), both of which descended from the same application and shared a specification, and both of which were directed to automated predictive analytics systems providing for generating sales leads with lead engagement recommendations.

ZoomInfo brought suit against Zenleads, Inc., d/b/a Apollo.io (Apollo), alleging that Apollo’s go-to-market intelligence and sales infringed at least claim 1 of each patent. Apollo moved to dismiss, arguing that the asserted claims were invalid for being directed at a patent-ineligible abstract idea. After determining that claim 1 of the ’609 patent was representative, the court applied the two-step Alice test.

Abstract idea. Apollo argued that the claims were directed to the abstract idea of collecting and analyzing information about potential and existing clients, a fundamental practice in commerce which was simply being executed on a computer. ZoomInfo argued that the claims were instead directed to specific improvements in computer functionality, such as the use of “‘web pages, hyperlinks, and link structures,’ ‘content and code on web pages,’ ‘unstructured text,’ ‘and feature matrices’” in a way not done by the prior art.

Reviewing the specifics of the claim language, the court found that it did not require anything more than conventional computer technology used to carry out a fundamental business practice. Accordingly, the representative claim was directed to an abstract idea.

Inventive concept. Apollo argued that the challenged claim simply used generic computer technology, while ZoomInfo argued that it recited the inventive concept of improved technology which advanced the relevant art by specifically “tuning web crawling to identify lead generations through categorization and dynamic adjustment.”

The court, noting its obligation to accept the plaintiff’s factual allegations as true and draw reasonable inferences in favor of the non-movant, held that it was plausible the methods claimed represented technological improvements in the computer systems used to crawl the Internet and predictively generate client data.

The court denied the motion to dismiss.

The Case is No. 1:25-cv-00324-JCG.

Judge: Groves, J.

Attorneys: Monte Terrell Squire (Duane Morris LLP) for ZoomInfo Technologies LLC. Adam Wyatt Poff (Young, Conaway, Stargatt & Taylor LLP) for Zenleads Inc. d/b/a Apollo.io.

Companies: ZoomInfo Technologies LLC; Zenleads Inc. d/b/a Apollo.io

Cases: Patent TechnologyInternet DelawareNews