District Courts

Federal district court decisions

District Courts, Section 230

Jane Doe v. Discord — N.D. Ohio Holds Section 230 Bars “Defective Design” Claims Over Sexual Predation

Judge Donald Nugent dismissed all claims — negligence, strict liability, concealment, and misrepresentation — against Discord brought on behalf of a minor sexually exploited by an adult user, holding that the plaintiff’s “defective design” theory was a repackaged demand that Discord moderate or block third-party communications, which Section 230 forecloses.

District Courts, Tech Law

NetChoice v. Griffin — W.D. Ark. Enjoins Arkansas Act 900 Social Media Restrictions on First Amendment Grounds

Judge Timothy Brooks granted NetChoice’s preliminary-injunction motion against Arkansas Act 900, the General Assembly’s second attempt to regulate minors’ use of social media after the same court enjoined the predecessor Act 689 in 2025. Act 900’s addictive-practices ban, mandatory notification curfew, default privacy settings, and parental dashboard provisions all fall under First Amendment scrutiny.

Copyright, District Courts

Butzer v. HyperSphere Technologies — Developer-Founder’s Copyright Claims Over Quantum Encryption Software Dismissed for Failure to State a Claim

A Georgia federal court dismissed copyright infringement claims by the inventor of “key shadowing” quantum-resistant encryption technology against HyperSphere Technologies, the company to which he had assigned his patent, ruling he failed to adequately state a claim that his separately registered software code was infringed.

District Courts, Patent Subject Matter Eligibility

B.E. Technology v. Google — Delaware Court Invalidates Last Targeted Advertising Patent Claim Under §101

A Delaware federal judge granted Google summary judgment on the last remaining claim of B.E. Technology’s targeted advertising patent, finding Claim 25 of U.S. Patent No. 8,769,440 directed to the abstract idea of providing real-time targeted advertising and lacking any inventive concept under the Alice/Mayo framework.

District Courts, Section 230

Bouck v. Meta — N.D. Cal. Holds Meta’s Generative-AI Advertising Tools Could Defeat Section 230 Immunity in Chinese Penny-Stock Pump-and-Dump

Chief Judge Seeborg denied Meta’s motion to dismiss claims by investors who lost more than $300 million to a Chinese penny-stock scam advertised on Facebook and Instagram, holding that Meta’s generative-AI advertising tool ‘Advantage+ Creative’ — which actually produced some of the ad text and imagery — raised a plausible factual dispute on whether Meta materially contributed to the offending content and thus lost Section 230 immunity.

District Courts, Section 230

The Upper Deck Co. v. Pixels.com — S.D. Cal. Holds Print-on-Demand Vendor Loses Section 230 Immunity for the Physical Sale of Infringing Prints, but Keeps It for Online Display and Search Tools

Chief Judge Bashant’s amended summary-judgment order in The Upper Deck Co. v. Pixels.com draws a clean line through Section 230 for print-on-demand platforms: when Pixels acts as a website operator displaying and indexing user-uploaded images, Section 230 immunizes it; when Pixels acts as the manufacturer, seller, and shipper of physical prints containing those same images, Section 230 does not.

District Courts, Utility Patent

Valve v. Rothschild — First-Ever Jury Verdict Under a State Anti-Patent-Troll Law

A federal jury in Seattle returned a $152,093 verdict for Valve and against inventor Leigh Rothschild and his patent-licensing entities — finding violations of the Washington Patent Troll Prevention Act, the Washington Consumer Protection Act, and a 2016 patent licensing settlement. It is, according to the IP bar, the first jury verdict under a state anti-troll statute.

District Courts, IP Law

Valve Corporation v. Rothschild — Western District of Washington Jury Returns First-of-Its-Kind Verdict Under State Patent Troll Prevention Act

A Seattle federal jury returned a verdict for Valve Corporation on every count, finding inventor Leigh Rothschild and his affiliated entities and counsel violated Washington’s Patent Troll Prevention Act, breached a 2016 settlement and license, and that the asserted patent claim was obvious — in what may be the first jury verdict ever rendered under a state anti-patent-trolling statute.

District Courts, Utility Patent

Ridge Wallet v. Bemmo — Court Denies Dismissal of Patent and Trade Dress Claims Over Compact Wallet Design

An Eastern District of New York judge denied Bemmo’s motion to dismiss Ridge Wallet’s patent infringement and trade dress claims, holding that claim construction disputes are premature at the pleading stage and that Ridge Wallet adequately alleged secondary meaning and non-functionality of its distinctive ‘Forged Ember’ design.

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