IP Law Daily, PATENT—D. Del.: Videoconferencing patent infringement claims survive Zoom’s invalidity challenge, (May 5, 2026)

By Ravindra Kumar Singh, B.L.

Although the asserted claims were directed to abstract ideas, the court held that Ricoh’s allegations plausibly established inventive concepts, precluding dismissal.

Zoom Communications, Inc. failed to secure dismissal of a patent infringement suit brought by Ricoh Company, Ltd., as the federal district court in Wilmington, Delaware denied its Rule 12(b)(6) motion challenging patent eligibility under 35 U.S.C. § 101. The court held that although all asserted claims were directed to abstract ideas at step one of the Alice framework, Ricoh plausibly alleged inventive concepts at step two. The court emphasized that factual disputes regarding whether the claimed elements were well-understood, routine, and conventional precluded dismissal at the pleading stage (Ricoh Company, Ltd. v. Zoom Communications, Inc., No. 1:25-cv-01095-JCG (D. Del. May 1, 2026)).

Background. The plaintiff, Ricoh Company, Ltd., is a multinational technology company headquartered in Japan that develops imaging, electronics, and communication systems, including cloud-based collaboration technologies. The defendant, Zoom Communications, Inc., is a U.S.-based provider of video-first unified communications platforms offering services such as video meetings, chat, whiteboarding, and enterprise collaboration tools. Both companies operate in the digital communications ecosystem, with overlapping technological offerings in videoconferencing and integrated collaboration systems.

The litigation concerned seven asserted patents relating to videoconferencing systems and collaborative communication technologies: U.S. Patent Nos. 10,904,487 (the ’487 patent), 10,909,059 (the ’059 patent), 10,931,917 (the ’917 patent), 11,256,464 (the ’464 patent), 11,289,093 (the ’093 patent), 11,516,278 (the ’278 patent), and 11,546,548 (the ’548 patent). These patents broadly address innovations in managing video communication sessions, including display control, transmission systems, participant identification, multimedia synchronization, and integration of collaborative tools such as whiteboards and messaging interfaces.

Ricoh initiated the action in August 2025, alleging that Zoom’s suite of products, including Zoom Meetings, Zoom Workplace, and related features, infringed the asserted patents. Zoom moved to dismiss the complaint under Federal Rule of Civil Procedure 12(b)(6), contending that the patents were invalid under § 101 because they claimed abstract ideas implemented using generic computer components. After Ricoh filed a First Amended Complaint, Zoom renewed its motion, reiterating that the claims merely recited conventional data processing and display functions without any technological improvement.

Court’s analysis. The court applied the two-step test articulated in Alice Corp Pty Ltd v CLS Bank International, 573 U.S. 208, 216 (2014), and Mayo Collaborative Services v Prometheus Laboratories Inc., 566 U.S. 66, 71 (2012), to determine patent eligibility. At step one, the court assessed whether the claims were directed to patent-ineligible concepts such as abstract ideas. At step two, it evaluated whether the claims contained an inventive concept sufficient to transform the abstract idea into a patent-eligible application.

The court emphasized that patent eligibility is a question of law informed by underlying factual determinations, citing Berkheimer v HP Inc., 881 F.3d 1360, 1365 (Fed. Cir. 2018) and Aatrix Software Inc v Green Shades Software Inc., 882 F.3d 1121, 1125 (Fed. Cir. 2018). It further noted that dismissal at the Rule 12(b)(6) stage is inappropriate where plausible factual allegations raise disputes regarding whether claim elements are conventional.

Abstract nature of the asserted claims. At step one, the court concluded that all asserted patents were directed to abstract ideas. The ’059 patent, which concerned displaying information about participants in a videoconference, was found to involve the abstract concept of collecting and displaying data.

The ’548 patent, directed to tracking and updating attendance states of videoconference participants, was similarly found abstract because it involved storing, updating, and displaying attendance information. The ’278 patent, which enabled users to assign customized names in meetings, was characterized as the abstract idea of updating and storing name information, akin to a manual process such as updating a name tag. Citing Credit Acceptance Corp v Westlake Services, 859 F.3d 1044, 1055 (Fed. Cir. 2017), the court reiterated that automating such human activities using generic computers does not confer patent eligibility.

The ’464 patent, relating to controlling the display of images across multiple screens, was also deemed abstract. The court found that the claims merely recited transmitting, receiving, and displaying image data, without specifying a particular technological improvement. Further, the ’487 patent, which integrated videoconferencing with interactive whiteboard interfaces, was held to be directed to the abstract idea of displaying overlapping information. The court noted that presenting information in layered or overlaid formats does not, by itself, constitute a technical improvement in computer functionality.

The ’093 patent, which synchronized text transcripts with corresponding audio playback positions, was found to involve the abstract idea of tagging or bookmarking information for ease of reference. The court compared this functionality to longstanding human practices such as annotating or bookmarking content, referencing Intellectual Ventures I LLC v Erie Indemnity Co., 850 F.3d 1315, 1327 (Fed. Cir. 2017). Finally, the ’917 patent, which enabled transmission of video data from external devices without logging them into a system, was characterized as the abstract idea of transmitting data between devices.

Across all patents, the court rejected Ricoh’s arguments that the claims were directed to specific technological improvements. It found that the claims were largely results-oriented and lacked sufficient detail to demonstrate improvements in computer functionality at step one.

Inventive concept and factual disputes. Despite finding the claims abstract, the court denied Zoom’s motion at step two of the Alice analysis. It held that Ricoh’s amended complaint included detailed factual allegations that the claimed inventions were not conventional and represented technological improvements over prior systems. The court emphasized that under Berkheimer, the question of whether claim elements are well-understood, routine, and conventional is a factual issue. It further noted, citing Aatrix, that courts must accept plausible factual allegations as true at the motion-to-dismiss stage.

Ricoh alleged that its inventions employed unconventional architectures, including improved display management techniques, centralized transmission systems, enhanced naming and identification frameworks, and innovative multimedia synchronization methods. The court found that these allegations plausibly suggested that the claimed features were not routine or conventional at the time of invention. Importantly, the court observed that nothing in the patents themselves conclusively contradicted these assertions. As a result, the court concluded that it could not determine, as a matter of law, that the claims lacked an inventive concept. The presence of factual disputes required further development of the record, making dismissal inappropriate at this stage of the proceedings.

Thus, the court denied Zoom’s motion to dismiss in its entirety and directed the parties to proceed with case scheduling.

The Case is No. 1:25-cv-01095-JCG.

Judge: Choe-Groves, J.

Attorneys: Andrew Colin Mayo (Ashby & Geddes) for Ricoh Co., Ltd. Michael J. Flynn (Morris, Nichols, Arsht & Tunnell LLP) for Zoom Communications, Inc. f/k/a Zoom Video Communications, Inc.

Companies: Ricoh Co., Ltd.; Zoom Communications, Inc. f/k/a Zoom Video Communications, Inc.

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