Piranha Media Distribution LLC v. Hulu, LLC

Piranha Media Distribution LLC v. Hulu, LLC The Federal Circuit affirmed the Rule 12(b)(6) dismissal, holding that representative claim 1 of the '403 patent is directed to the abstract idea of preventing skipping of advertisements by receiving, organizing, displaying, and controlling access to data, and contains no inventive concept under Alice/Mayo. It did not reach Hulu's alternative argument that a prior Board decision had preclusive effect. The decision reinforces that claims for ad-delivery or media-control functions implemented on generic computer components, with no problem unique to computer technology, remain vulnerable to pleading-stage Section 101 dismissal, and that conclusory 'novelty' statements in the specification or complaint will not supply an inventive concept. Affirmed. Piranha asserted the '403 and '768 patents (integration of advertisements in digital media) against Hulu. The parties agreed claim 1 of the '403 patent is representative of all asserted claims, and the district court dismissed under Section 101. Step one: claim 1 achieves ad-skip prevention through steps that only receive, organize, display, and control access to data. It does not solve a technological problem, since the patent and Piranha's own filings acknowledge ad skipping long predated computers. Piranha's cases (Data Engine, SRI, Uniloc, Ancora, Finjan) involved problems unique to computers or networks. Step one, continued: Piranha's own descriptions of the intersplicer amount to data organization. Inability of the human mind to perform the steps does not confer eligibility (FairWarning), and absence of complete preemption does not show eligibility. Step two: the claim uses generic components (processors, user interface input and output, memory) in conventional ways. The intersplicer's rules are an unspecified set of rules for organizing data, and the specification's 'novel' labels and the conclusory complaint allegations do not show an inventive concept. The court did not reach preclusion from a 2020 Board decision, because the district court expressly did not rely on it. § 101 non-precedential § 101 non-precedential § 101