Unreported / Non-Citable
Background
Damaka, Inc. sued The Cigna Group, Cigna Health and Life Insurance Company, and Cigna Healthcare of Texas, Inc. for allegedly infringing five patents that share a common specification and generally concern computer and mobile-device communications with audio and video capabilities. Cigna moved to dismiss the amended complaint, arguing that the asserted patent claims were ineligible under 35 U.S.C. § 101.
For purposes of the motion, the court treated claim 15 of U.S. Patent No. 9,027,032 as representative because Cigna proposed it and Damaka did not dispute that characterization. Cigna argued that the claim merely recited the abstract result of identifying and displaying data without interruption and lacked an inventive concept. Damaka countered that Cigna oversimplified the claimed arrangement of a “superblock application” and “function block,” and that their operation within a given memory produced improvements in battery life and processing power.
The Court’s Holding
The court denied Cigna’s renewed motion to dismiss without prejudice. It did not decide whether the asserted claims were patent eligible under the two-step Alice framework.
Instead, the court concluded that claim construction could assist its eligibility analysis because the parties disputed the meaning and scope of at least “superblock application” and “function block,” terms appearing throughout the asserted patents. Because eligibility issues can be intertwined with claim construction, the court determined that resolving the parties’ construction disputes should precede a § 101 ruling. Cigna may renew its eligibility challenge after the court issues its claim-construction order.
Key Takeaways
- The court made no final determination that Damaka’s patent claims are eligible or ineligible under § 101.
- Disputes over the scope of “superblock application” and “function block” made a pleading-stage eligibility decision premature.
- Cigna may reassert its § 101 arguments after claim construction.
Why It Matters
The order illustrates that although courts may resolve patent eligibility on a motion to dismiss, they may defer the issue when disputed claim meanings could affect the Alice analysis. Defendants pursuing early § 101 dismissal should account for any material claim-construction disputes rather than assuming that functional claim language will be read as generic software activity.