United States Federal Circuit

In this case, plaintiff Content Extraction appeals from the dismissal of its patent infringement suit and cross-appellant Diebold appeals from the dismissal of its tortious interference and Racketeer Influenced and Corrupt Organizations Act (RICO) claims against Content Extraction in a related action. Dismissal of both Content Extraction's and Diebold's claims is affirmed, where: 1) the claims of Content Extraction's asserted patents are invalid as patent ineligible under 35 U.S.C. section 101; and 2) because Content Extraction's infringement suits were not objectively baseless at the time they were filed, the act of filing its suits was shielded from liability by the Noerr-Pennington doctrine, and the district court therefore correctly dismissed Diebold's tortious interference and RICO violation claims against Content Extraction.

Appellate Information

• Decided 12/23/2014
• Published 12/23/2014

Judges

• Chen

Court

• United States Federal Circuit

Counsel