The Federal Circuit recently issued a precedential decision in Adnexus Inc. v. Meta Platforms, Inc., 2024-1551, vacating a district court's order granting Meta's motion to dismiss Adnexus' complaint for failure to state a claim for patent infringement.1 As summarized below, the Court's decision to vacate the dismissal order focused on the requirement that Adnexus' complaint needed only to state a "plausible" claim for relief to survive the motion and held the Adnexus' infringement claim remained plausible absent an unfavorable claim construction.
Below we summarize the background of the case and the Federal Circuit's analysis and vacatur, which emphasizes the Court's general reluctance to resolve infringement disputes at the pleading stage when doing so requires claim construction.