NantWorks LLC and Nant Holdings IP LLC sued Niantic, Inc. for infringing two augmented reality patents: the '518 patent, which covers mapping AR objects and rendering them on a device display, and the '051 patent, which covers incorporating visual objects into a digital representation of an environment. NantWorks accused Niantic of infringement through its popular AR games, Pokémon Go and Harry Potter: Wizards Unite. Niantic moved for judgment on the pleadings regarding the '518 patent and for summary judgment regarding the '051 patent, arguing the claims were invalid under 35 U.S.C. § 101. The district court granted both motions, finding the claims directed to abstract ideas without significantly more. NantWorks appealed, challenging the district court's characterization of the claims and its application of the patent eligibility framework.
The Federal Circuit applied the two-step Alice/Mayo framework to determine patent eligibility. At step one, the court analyzed whether the claims were directed to a patent-ineligible concept. For the '518 patent, the court rejected NantWorks' argument that specific steps like using 'tessellated tiles' or an 'area database' made the claims non-abstract. The court found these steps merely described the abstract idea of 'providing information based on a location on a map,' a concept previously identified in cases like Zillow and Sanderling. The court noted that these steps could be performed with a pencil and paper, a telltale sign of abstraction. Similarly, for the '051 patent, the court found the claims directed to the abstract idea of 'receiving information about a location and displaying materials based on that information.' The court held that tailoring content based on a viewer's location is a fundamental practice long prevalent in the system. At step two, the court searched for an 'inventive concept' that would transform the abstract idea into a patent-eligible application. The court found that the claims recited only generic computer components like processors, memory, and servers, which are insufficient to supply an inventive concept. NantWorks' reliance on unclaimed benefits from the specification, such as memory savings or improved efficiency, was rejected because the claims themselves did not recite those specific features. The court concluded that the claims merely invoked computers as a tool to perform the abstract idea, failing to fundamentally change or improve how a computer functions.
The decision affirms that generic augmented reality features involving location-based filtering and rendering are likely ineligible for patent protection under current § 101 jurisprudence. Niantic's AR games are no longer subject to infringement liability for the specific claims invalidated in this order. The ruling reinforces the Federal Circuit's strict application of the Alice/Mayo framework to software and AR patents that rely on conventional computer components to implement abstract ideas.
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