AATRIX SOFTWARE, INC. v. GREEN SHADES SOFTWARE, INC.

AATRIX SOFTWARE, INC. v. GREEN SHADES SOFTWARE, INC., Appeal No. 17-1452 (Fed. Cir. Feb. 14, 2018).  Before Reyna, Taranto, and Moore.  Appealed from M.D. Fla. (Judge Schlesinger).  (Motion to File Amended Complaint)

Background:

Aatrix owns two patents with the same specification that are both directed to systems and methods for designing, creating, and importing data into a viewable form on a computer so that a user can manipulate the form data and create viewable forms.

Aatrix sued Green Shades for infringement of its patents.  However, the district court ruled, prior to claim construction, that all of Aatrix’s claims are invalid under §101.  The district court held that the claims are directed to the abstract idea of “collecting, organizing, and performing calculations on data to fill out forms: a fundamental human activity that can be performed using a pen and paper.”  The district court did not perform the Alice/Mayo analysis on claim 1 of Aatrix’s ‘615 patent, although it did perform the Alice/Mayo analysis on the remaining claims in both of Aatrix’s patents.

After the district court’s ruling, Aatrix requested leave to file a second amended complaint.  Aatrix argued that the second amended complaint contained additional allegations and evidence that would have precluded a dismissal under §101.  The district court denied Aatrix’s motion.

Issue/Holding:

Did the district court err in denying Aatrix’s motion to file the second amended complaint? (continue reading)

Summary by:  Amy Lang

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