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ARTICLE · 03 NOVEMBER 2022

D. Mass. Patent Litigation Update: September 2022

Finnegan, Henderson, Farabow, Garrett & Dunner LLP
Finnegan, Henderson, Farabow, Garrett & Dunner LLP
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In Integrated Technology Solutions, LLC v. iRacing.com Motorsport Simulations, LLC, No. 1:21-cv-11477, Judge Talwani granted iRacing's motion to dismiss...

United StatesIntellectual Property

In Integrated Technology Solutions, LLC v. iRacing.com Motorsport Simulations, LLC, No. 1:21-cv-11477, Judge Talwani granted iRacing's motion to dismiss, finding that ITS's patent directed to modifying components of a video game racing track to alter user experience was invalid under 35 U.S.C. § 101. The Court applied the two-step framework laid out by the Supreme Court in Alice Corp. Pty. Ltd. v. CLS Bank Int'l., 573 U.S. 208 (2014), examining first whether the claims at issue are directed to laws of nature, natural phenomena, or abstract ideas, and, second, whether the elements of each claim both individually and as an ordered combination transform the nature of the claim into a patent-eligible application.

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