IP Law Daily, PATENT—N.D. Cal.: Search engine patent case against Google is dismissed with prejudice, (Oct 7, 2025)

By Steven Melendez

Even after amendment, patent holder LookSmart failed to demonstrate its patent covered eligible material.

A court dismissed a search engine-related patent case brought by LookSmart against Google, finding the company failed to demonstrate its patent claimed eligible material rather than mere abstract ideas. LookSmart had already amended its complaint in the search engine patent case, and the judge found that further amendment "would be futile," granting Google's motion to dismiss and dismissing LookSmart's claims with prejudice (LookSmart Group, Inc. v. Google, LLC, No. 4:24-cv-07147-JST (N.D. Cal. Oct. 3, 2025)).

LookSmart filed the case on October 14, 2024, alleging Google had infringed its Patent No. 7,356,530 (the '530 patent), titled “Systems and Methods of Retrieving Relevant Information.” The patent deals with retrieving information from a large collection of data, such as the internet and world wide web.

But the court previously dismissed the complaint, finding the patent was merely “directed to the abstract idea of collecting, storing, indexing, and ranking information” and failed to recite an actual "inventive concept" beyond that abstract idea. Still, the court allowed LookSmart to file an amended complaint, which it did on July 17, 2025, also filing a new declaration in the matter.

Alice analysis. The court analyzed the patent using the criteria from Alice Corp. v. CLS Bank International.

In the first step, the court considered whether the patent was directed to an ineligible abstract idea. The court initially determined that the patent's Claim 1 did "nothing more than recite ‘a desired function or outcome without providing any limiting detail that confines the claim to a particular solution to an identified problem,’” rejecting arguments by LookSmart that the patent's specification demonstrated patentability. The court had found the patent lacked detail about how particular "intrinsic and extrinsic weighting factors" were calculated.

LookSmart argued that its newly amended complaint “specifically ties the claim limitations to the technological solution described in the specification," showing that the patent claims focus on using "specific ranking factors in a pre-indexed database" to address speed and accuracy issues in search engines. The amended complaint alleges how dependent claims in the patent limit how these factors are "determined and adjusted" and how "indexing is conducted," the company argued.

But the court rejected that argument and found that the dependent claims still "do not teach how the intrinsic or extrinsic ranking factors are calculated."

LookSmart also argued that software patents don't have to cite "some specific algorithm" to be valid. But the court still found the patent lacked the "limiting detail" necessary to go beyond mere abstraction.

In the second step of the Alice analysis, the court then considered whether the elements of the claim still "recite an inventive concept" beyond simply applying the abstract idea. LookSmart argued in its amended complaint and the attached declaration that its invention addressed problems in search engines of its day.

Still, the court found that the "the ’530 Patent does not teach how one would calculate" the various factors involved, and that it failed to show that the elements of its claims "recite an inventive concept."

The Case is No. 4:24-cv-07147-JST.

Judge: Tigar, J.

Attorneys: Jason McManis (Ahmad, Zavitsanos & Mensing, PLLC) for Looksmart Group, Inc. Robert Addy Van Nest (Keker, Van Nest & Peters LLP) for Google, LLC.

Companies: Looksmart Group, Inc.; Google, LLC

Cases: Patent CaliforniaNews TechnologyInternet