Wednesday, April 12, 2023

Sanderling loses at CAFC

The outcome"

Sanderling Management Ltd. (“Sanderling”) appeals from the district court’s dismissal of Sanderling’s patent infringement suit against Snap Inc. (“Snap”) due to the asserted claims’ lack of patent-eligible subject matter under 35 U.S.C. § 101 (“Section 101”). Sanderling also asks us to review the district court’s denial of its motion for leave to amend its complaint. We affirm.

Footnote 6: It is within a district court’s discretion to require a party opposing a Rule 12 motion based on Section 101 to identify, and articulate the significance of, specific fact disputes that purportedly make granting the motion improper. A patentee’s failure to do so should, as here, preclude the court from denying the motion simply based on a vague pronouncement to the effect that “a factual dispute exists.”


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