Intellectual Property – Patent Infringement – Abstract Idea – Online Inventory – Movie Ticket Sales

Mankes v. Fandango, LLC (Lawyers Weekly No. 002-017-17, 13 pp.) (Louise Flanagan, J.) 513-cv-00716; E.D.N.C.

Holding: Plaintiff’s “Active Reservation System” patent claims methods for a system to control inventory when goods and services are sold through the Internet and at a physical site. Although the movie ticket reservation system used by defendant Fandango, in conjunction with defendant Regal Entertainment Group’s operation of a local reservation system, largely mimics that disclosed in the patent, the patent’s claimed methods simply provide a method of implementing the well-known business practice of inventory management on conventional computer hardware. The method claims, viewed as an ordered combination, do not impose specific limitations sufficient to render plaintiff’s claims patent-eligible.

The claims at issue are directed to an abstract idea and lack an inventive concept. Consequently, the asserted claims are patent-ineligible under 35 U.S.C. § 101.

The court grants defendants’ motion to dismiss.