IP Law Daily, PATENT—W.D. Wash.: Judgment on the pleadings granted in streaming patents asserted against Meta Platforms, Inc., (Jan 12, 2026)
Law Firms Mentioned:Avantech Law LLP | Cooley LLP
Organizations Mentioned:Cooley, LLP | Meta Platforms Inc. | Weple IP Holdings LLC
By Kevin M. Finson, J.D.
Claims relating to the receiving, storing, generating, or otherwise manipulating digital content were invalid for being directed to an abstract idea because they did not relate to any technological improvement.
Meta showed that three patents asserted against it were invalid for being directed to an abstract idea, the U.S. District Court in Seattle has held. The claims were directed to the manipulation of digital content using functional, results-oriented language without any technological improvement (Weple IP Holdings LLC v. Meta Platforms Inc., No. 2:24-cv-01316-JLR (W.D. Wash. Jan. 9, 2026)).
Weple IP Holdings, LLC (Weple) was the owner of U.S. Patents Nos. 11,734,730 (the ’730 patent), 11,966,952 (the ’952 patent), 12,112,357 (the ’2,357 patent), 12,118,591 (the ’591 patent), 12,131,356 (the ’356 patent), and 12,131,357 (the ’1,357 patent”), all six of which shared a specification and were entitled “Mobile Device Streaming Media Application.” Weple alleged these patents comprised a comprehensive platform which facilitated the “creation, management, distribution, and monetization of diverse content in a mobile environment.” Weple brought suit for infringement against Meta Platforms, Inc. (Meta). Meta moved for and obtained dismissal of the claims relating to the ’952, ’730, and ’356 patents on the ground that they were directed to a non-patent eligible abstract idea. Meta then answered the complaint and moved for judgment on the pleadings as to the remaining patents. Weple moved for leave to file a second amended complaint.
Judgment on the pleadings. With regard to each of the surviving patents, the court applied the two-step Alice test and found that the claims were directed to the abstract idea of receiving, storing, generating, or otherwise manipulating digital content, and that each patent did so using functional, results-oriented language without describing an improvement to the underlying technology. On step two of the Alice test, the court found that Weple failed to show any inventive concept, and that each patent simply carried out the abstract idea using generic computer technology. The court also noted that Weple made essentially no arguments on the validity of the claims in its operative complaint (the first amended complaint) and instead focused on the claims it hoped to make in its proposed second amended complaint. The court found that these arguments were not response to the motion at hand and considered them only in view of the motion for leave to amend.
Leave to amend. The court found that Weple’s proposed second amended complaint and the expert designation upon which it relied made allegations which were inconsistent with the language of the patents themselves. Nothing Weple could plead would change the language of the patents, which was at the heart of the abstract idea inquiry. Accordingly, the proposed amendment was futile.
The court granted Meta’s motion for judgment on the pleadings and denied Weple’s motion to amend.
The Case is No. 2:24-cv-01316-JLR.
Judge: Robart, J.
Attorneys: Jason Zucchi (Avantech Law LLP) for Weple IP Holdings LLC. Dena Chen (Cooley LLP) for Meta Platforms Inc.
Companies: Weple IP Holdings LLC; Meta Platforms Inc.
Cases: Patent TechnologyInternet WashingtonNews