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United States District Court for the District of Delaware
April 1, 2020, Decided; April 1, 2020, Filed
Civil Action No. 18-1717-MN-CJB (Lead)
REPORT AND RECOMMENDATION
Presently before the Court in these consolidated patent infringement cases are renewed motions to dismiss, filed pursuant to Federal Rule of Civil Procedure 12(b)(6), by Defendants Quotient Technology Inc., Intuit Inc., HealthEquity, Inc., WEX Health, Inc. and Netsmart Technologies, Inc. (collectively "Defendants")1 seeking to dismiss Plaintiff Sapphire Crossing LLC's ("Plaintiff") claims of patent infringement for failure to state a claim [*2] upon which relief can be granted (the "Motions"). (D.I. 56) According to Defendants, asserted U.S. Patent No. 6,891,633 ("the '633 patent" or "the asserted patent") is directed to ineligible subject matter under 35 U.S.C. § 101 ("Section 101"). For the reasons set out below, the Court recommends that the Motion be DENIED.
I. BACKGROUND AND LEGAL STANDARDS
The Court hereby incorporates by reference its summary of the procedural history of the case, its summary of the technology at issue and the asserted patent, and its summary of the relevant legal standards, all of which were set out in the Court's August 14, 2019 Report and Recommendation ("August 14 R&R") in this case. (D.I. 47 at 1-8); see Sapphire Crossing LLC v. Quotient Tech. Inc., Civil Action No. 18-1717-MN-CJB (Lead), 2019 U.S. Dist. LEXIS 137146, 2019 WL 3817571 (D. Del. Aug. 14, 2019), report and recommendation adopted, 2019 WL 4076219 (D. Del. Aug. 29, 2019). The Court writes here primarily for the parties, and assumes familiarity with the August 14 R&R.
Subsequent to the District Court's adoption of the August 14 R&R, which granted certain of Defendants' first motion to dismiss filed on Section 101 grounds (the "first motion to dismiss"), Plaintiff then filed Amended Complaints against each of the remaining Defendants. (D.I. 49; D.I. 50; D.I. 51; D.I. 53; Civil Action No. 19-1401-MN-CJB, D.I. 14 (collectively, the [*3] "Amended Complaint")2 ) Defendants Quotient Technology Inc., Intuit Inc., HealthEquity, Inc. and WEX Health, Inc. next filed their renewed motion to dismiss on October 3, 2019, (D.I. 56), while Defendant Netsmart Technologies, Inc. filed its renewed motion to dismiss on October 7, 2019, (Civil Action No. 19-1401-MN-CJB, D.I. 18). Briefing on the Motions was completed on November 22, 2019. (D.I. 77)
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2020 U.S. Dist. LEXIS 57033 *
SAPPHIRE CROSSING LLC, Plaintiff, v. QUOTIENT TECHNOLOGY INC., Defendant.
Prior History: Sapphire Crossing LLC v. Quotient Tech. Inc., 2019 U.S. Dist. LEXIS 137146 (D. Del., Aug. 14, 2019)
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