Tuesday, January 12, 2021

MORTGAGE APPLICATION TECH. v. MERIDIANLINK, INC: Loss on 101 but no attorney's fees awarded

The outcome:

Mortgage Application Technologies, LLC (“MAT”) appeals the final decision of the U.S. District Court for the Central District of California finding that the asserted claims of U.S. Patent No. 8,548,902 (“’902 patent”) are invalid under 35 U.S.C. § 101. Mortg. Application Techs., LLC v. Meridianlink, Inc., No. 19-CV-704, 2020 WL 1000581 (C.D. Cal. Jan. 6, 2020). MeridianLink, Inc. (“MeridianLink”) cross-appeals from a separate decision that denied MeridianLink’s motion for attorney’s fees. Mortg. Application Techs., LLC v. Meridianlink, Inc., No. 19-CV704, 2020 WL 4187766 (C.D. Cal. Mar. 12, 2020). For the reasons set forth below, we affirm the district court’s decision finding the ’902 patent invalid and affirm the denial of MeridianLink’s motion for attorney’s fees.

Of attorney's fees:

We now turn to MeridianLink’s cross-appeal on the denial of attorney’s fees. Under 35 U.S.C. § 285 “[t]he court in exceptional cases may award reasonable attorney fees to the prevailing party.” “[A]n ‘exceptional’ case is one that stands out from others with respect to the substantive strength of a party’s litigating position (considering both the governing law and the facts of the case) or the unreasonable manner in which the case was litigated.” Octane Fitness, LLC v. ICON Health & Fitness, Inc., 572 U.S. 545, 134 S. Ct. 1749, 1756, 188 L. Ed. 2d 816 (2014). “District courts may determine whether a case is ‘exceptional’ in a case-by-case exercise of their discretion, considering the totality of the circumstances.” Id. Section 285 “imposes no specific evidentiary burden” and is rather “a simple discretionary inquiry[.]” We review the district court’s exceptional case determination for abuse of discretion. See Highmark Inc. v. Allcare Health Mgmt. Sys., Inc., 572 U.S. 559, 564, 134 S. Ct. 1744, 1749, 188 L. Ed. 2d 829 (2014). Because the district court did not abuse its discretion, we affirm.


MeridianLink further argues that the district court underestimated the weakness of MAT’s litigation position in light of the relevant caselaw, and that this case is exceptional because it “was not a close call under Alice.” CrossAppellant Br. 64. The district court, however, reviewed the relevant case law and found that MAT’s litigation position was not substantively weak. Although the ’902 patent is ineligible under § 101, it was unlike a number of other cases that MeridianLink cites in which the patents at issue were drawn to a fundamental economic processes. Specifically, as the district court stated, the claims in this case are drawn to an abstract process that is applied to a fundamental economic process. Mortg. Application, 2020 WL 4187766, at *3. MeridianLink argues that although the district court distinguished this case from a number of precedential cases, it did not distinguish this case from a few other cases MeridianLink cites. We are not persuaded that the handful of cases finding patent ineligibility under § 101, including Audatex, is sufficient to show that the district court abused its discretion in ultimately denying MeridianLink’s motion for attorney’s fees


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