Trinity Info Media, LLC v. Raya App, Inc.

Trinity Info Media, LLC, a patent assertion entity (PAE), initiated this patent infringement lawsuit against Raya App, Inc. Trinity Info Media focuses on asserting its intellectual property rights, as evidenced by its litigation history involving patents related to networking systems. Raya App, Inc. operates a private, membership-based social networking application renowned for its exclusivity, catering to celebrities, high-profile individuals, and those in creative industries, offering platforms for dating, networking, and social discovery.

The asserted patent in this litigation is U.S. Patent No. 9,087,321 (the '321 patent), titled "Poll-Based Networking System." This patent broadly describes a system and method for connecting users based on similarities determined through their answers to polling questions, providing real-time results. The system is designed to identify a "likelihood of match" between users and suggest connections accordingly, utilizing components such as multiple match servers and a match aggregator. Raya App, Inc.'s social networking platform, which facilitates connections and discovery among its users, is the accused technology.

The case was filed in the Central District of California (CACD), a prominent venue for patent litigation due to the concentration of technology companies in the region. Raya App, Inc. is headquartered in Los Angeles, California, which falls within this district. While a specific judge for this case number (2:21-cv-01361) was not explicitly identified, Judge John W. Holcomb presided over a closely related case, Trinity Info Media, LLC v. Covalent, Inc. (Case No. 2:21-cv-01360), which also involved the '321 patent in the same court and was filed around the same time.

This case is particularly notable due to a significant ruling by the Federal Circuit in a parallel case, Trinity Info Media, LLC v. Covalent, Inc. On July 14, 2023, the Federal Circuit affirmed the district court's decision that the '321 patent, along with a related patent, is invalid under 35 U.S.C. § 101 for claiming unpatentable subject matter. The court found that the patent's claims were directed to the abstract idea of "matching users who gave corresponding answers to a question" and lacked an "inventive concept," concluding that merely using generic computer components to perform an abstract idea faster does not transform it into patent-eligible subject matter. This precedent from the Federal Circuit regarding the invalidity of the '321 patent under Section 101 will likely be highly influential, if not determinative, for the ongoing Trinity Info Media, LLC v. Raya App, Inc. litigation, despite its current active status.

Based on the provided case metadata, Trinity Info Media, LLC filed suit against Raya App, Inc. in the California Central District Court on March 3, 2021, asserting US Patent 9087321, under case number 2:21-cv-01361. However, web searches for this specific case number and defendant combination in the California Central District Court did not yield relevant patent litigation results. Instead, case number 2:21-cv-01361 appears to be associated with unrelated cases in other district courts.

Critically, extensive public records and legal news uniformly point to a highly relevant and active patent infringement litigation involving the same plaintiff (Trinity Info Media, LLC) and the same patent (US Patent 9087321) in the same court (Central District of California) and same timeframe, but against a different defendant, Covalent, Inc., under case number 2:21-cv-01360-JWH-MRW. It is highly probable that the case number and/or defendant in the prompt's metadata may contain a slight discrepancy, and the significant legal developments for US Patent 9087321 by Trinity Info Media, LLC are found in the Trinity Info Media, LLC v. Covalent, Inc. litigation.

Therefore, the following summary details the key legal developments and outcome for US Patent 9087321 based on the Trinity Info Media, LLC v. Covalent, Inc. litigation, as this represents the authoritative public record of patentability challenges for the patent at issue.

Key Legal Developments and Outcome for US Patent 9087321 (from Trinity Info Media, LLC v. Covalent, Inc.)

1. Filing & Initial Pleadings:

• February 2021: Trinity Info Media, LLC (formerly Trinity Intel Media, LLC) sued Covalent, Inc. in the Central District of California, alleging infringement of U.S. Patent Nos. 9,087,321 and 10,936,685. The patents relate to methods and systems for connecting users based on their answers to polling questions.

2. Pre-trial Motions of Substance:

• Covalent, Inc. filed a motion to dismiss, arguing that the asserted patent claims were invalid under 35 U.S.C. § 101 for being directed to patent-ineligible subject matter.
• District Court Grant of Motion to Dismiss (C.D. Cal. 2021): The United States District Court for the Central District of California granted Covalent's motion to dismiss, concluding that the asserted claims were directed to the abstract idea of "matching users who gave corresponding answers to a question" and lacked an inventive concept. The District Court found that the claims did not improve computer functionality but rather used "generic computer components as tools to perform the functions faster than a human would."

3. Appeal to the Federal Circuit & Final Disposition:

• Trinity Info Media, LLC appealed the district court's decision to the United States Court of Appeals for the Federal Circuit (Case No. 2022-1308). Trinity argued, among other things, that the district court improperly neglected to conduct claim construction and fact discovery before analyzing the asserted claims under § 101.
• Federal Circuit Affirmation (2023-07-14): The Federal Circuit issued an opinion on July 14, 2023, affirming the district court's decision that U.S. Patent Nos. 9,087,321 and 10,936,685 are invalid under 35 U.S.C. § 101.
  • The Federal Circuit rejected Trinity's argument regarding premature § 101 analysis, stating that Trinity failed to propose a specific claim construction or identify specific facts needing development that would alter the § 101 analysis.
  • The Federal Circuit agreed with the district court, holding that the claims were directed to the abstract idea of "matching based on questioning" and did not contain an inventive concept that transformed the abstract idea into a patent-eligible application. The court noted that "a human mind could review people's answers to questions and identify matches based on those answers" and that using generic computer components to perform functions faster was insufficient for patent eligibility.

4. Parallel PTAB IPR/PGR Proceedings:

• No information about parallel PTAB IPR/PGR proceedings specifically initiated by Raya App, Inc. or Covalent, Inc. concerning US Patent 9087321 was found in the search results. The invalidation of the patent under § 101 by the Federal Circuit would largely obviate the need for such proceedings from the perspective of potential infringers.

The outcome for US Patent 9087321, at least as litigated by Trinity Info Media, LLC against Covalent, Inc., is that the patent was found invalid under 35 U.S.C. § 101 by the Central District of California and this decision was affirmed by the Federal Circuit.

Based on available information and common practices in patent litigation, attorneys from Russ August & Kabat, LLP are highly likely representing the plaintiff, Trinity Info Media, LLC, in this case. While a direct PACER docket entry explicitly listing their appearance in case 2:21-cv-01361 was not directly retrieved, the firm, and specifically attorneys Marc A. Fenster and Reza Mirzaie, have a prominent plaintiff-side patent litigation practice and have represented Trinity Info Media, LLC in closely related patent infringement cases involving the same patent (U.S. Patent 9087321).

Here are the details for the likely counsel of record for Trinity Info Media, LLC:

1. Marc A. Fenster

• Role: Lead Counsel (Co-chair of Litigation Department and Chair of Patent Litigation Department at Russ August & Kabat).
• Firm: Russ August & Kabat, LLP, Los Angeles, California.
• Experience: Marc Fenster is a first-chair trial lawyer specializing in high-technology patent litigation. He founded Russ August & Kabat's patent litigation practice in 2003, which is consistently ranked among the country's top patent litigation firms. He has secured numerous multi-million dollar jury verdicts for his clients, including significant wins against major technology companies like Samsung, Apple, Amazon, Google, and Western Digital in cases involving wireless push messaging, targeted advertising, smart thermostat technology, and hard disk drive technology. He has been recognized as a Southern California Super Lawyer since 2010 and a Top 100 Super Lawyer for several years.

2. Reza Mirzaie

• Role: Lead Counsel (Co-chair of the plaintiff's patent infringement litigation department at Russ August & Kabat).
• Firm: Russ August & Kabat, LLP, Los Angeles, California.
• Experience: Reza Mirzaie's practice focuses on patent litigation and licensing, having obtained over $600 million for his clients in the past five years alone, with an undefeated jury trial record. He is a registered patent attorney and has extensive experience in post-grant matters before the USPTO. He has co-led trial teams with Marc Fenster on many significant patent infringement cases, securing large jury verdicts against companies such as Samsung, Amazon, Google, and Western Digital, related to various technologies including OLED and touchscreen, data saving, wireless push messaging, and magnetic recording media. He was an equity partner at Knobbe Martens LLP before joining Russ August & Kabat. Mirzaie has been recognized as a Southern California Super Lawyer from 2022-2026 and a Super Lawyers Rising Star multiple times.

Other Attorneys Queried:

• Joseph A. Mirzaie: No information was found to suggest that Joseph A. Mirzaie is involved in patent litigation or is affiliated with Russ August & Kabat, LLP, for this case.
• Raja S. Gill: Search results indicate Raja S. Gill is a founding attorney at Gill Law Group, PC, focusing exclusively on divorce and family law. There is no indication he is involved in patent litigation.

Counsel of Record for Defendant Raya App, Inc.

Raya App, Inc. is represented by attorneys from Kirkland & Ellis LLP.

Here is a breakdown of the identified counsel:

• Adam R. Alper
  • Role: Lead Counsel
  • Firm: Kirkland & Ellis LLP, San Francisco, CA
  • Relevant Patent Litigation Experience: Adam Alper is a prominent member of Kirkland & Ellis's intellectual property litigation group, specializing in high-stakes patent and trade secret disputes. He has a strong track record, including numerous defense-side jury verdicts in multi-patent cases and securing over $2.1 billion in damages awards and settlements for clients in IP litigation. Alper has been recognized as a "Top IP Lawyer" by the Daily Journal and a "Trials MVP of the Year" by Law360. His practice focuses on competitor-versus-competitor disputes across various industries, including semiconductor, telecommunications, computer hardware, and pharmaceutical.

Further attorneys from Kirkland & Ellis LLP or any local or in-house counsel have not been explicitly identified as appearing for Raya App, Inc. in the provided search results. A direct search of the PACER docket for this specific case would provide a complete and definitive list of all appearing counsel.