American Needle, Inc. v. Zazzle Inc.

American Needle, Inc. v. Zazzle Inc., No. 15-cv-03971 (Darrah, J.) (N.D. Ill. Jan. 19, 2016)


7,319,980 | Entitled, “Method and a computer network server for facilitating sale of an object”


Grant of motion to dismiss for lack of patentable subject matter

Abstract Idea:


Something More:



Method of facilitating a sale over a computer network by allowing customers to preview and customize design of good.


The court found that promoting sales by providing a visual aid over the internet is not “rooted in computer technology,” and in fact adding design elements to merchandise and display merchandise can be performed by human thought alone, thus rendering the alleged invention abstract. From there the court determined that there was no inventive concept as the patent was not tied to a particular machine, and did not transform the article. The court also rejected American Needle’s argument that the multiple views in the patent that were lacking in the prior art supported an inventive concept, as standing along this is not enough to confer patent eligibility.