Hermes IP Management Defeats Lenovo's Motion to Dismiss as Court Preserves Patent Claims and Rejects Early §101 Challenge

LONGHORN IP

Sep 25

3 min read

PLANO, Texas, September 25, 2026 – Hermes IP Management LLC announced today that the United States District Court for the Eastern District of Texas has denied Lenovo Group Ltd.'s attempt to dismiss Hermes' patent infringement claims at the pleading stage, marking an important early victory for Hermes in its litigation against Lenovo.

In a Memorandum Opinion and Order issued by Rodney Gilstrap, Chief Judge of the Eastern District of Texas, the Court denied Lenovo's Rule 12(b)(6) motion challenging the eligibility of Hermes' asserted patents under 35 U.S.C. §101. The Court found that claim construction could materially affect the eligibility analysis and concluded that dismissal at this stage would be premature.

The ruling preserves Hermes' infringement claims relating to U.S. Patent Nos. 8,855,720 and 9,613,060 and allows the case to proceed toward claim construction and merits discovery.

"The Court is persuaded that claim construction could be beneficial in addressing the issues of eligibility of the Challenged Patents in this case."

Notably, despite Lenovo's effort to invalidate the patents at the outset of the case, the Court declined to adopt Lenovo's position and instead determined that disputed claim language should first be construed before any eligibility determination is made. The Court emphasized that patent eligibility issues are often "inextricably tied to claim construction," particularly where the parties dispute the meaning and scope of key claim terms.

The Court further relied on Federal Circuit precedent recognizing that resolving claim construction disputes may be necessary before adjudicating patent eligibility questions.

Lenovo Failed to Obtain the Extraordinary Relief Sought Under Rule 12(b)(6)

A motion to dismiss under Rule 12(b)(6) requires a defendant to demonstrate that the plaintiff's claims fail as a matter of law. Here, Lenovo sought dismissal before claim construction, arguing that the asserted patents were directed to ineligible subject matter under §101. The Court rejected that request and concluded that the disputed claim terms could affect the eligibility analysis, thereby preventing dismissal at this preliminary stage.

The Court specifically noted that the parties dispute the proper construction of key claim terms appearing in the asserted patents and agreed that those disputes should be addressed before determining whether the claims are patent-eligible.

Validation of Hermes' Litigation Position

Throughout the briefing, Hermes argued that Lenovo's motion was premature because the Court had not yet construed disputed claim language and because those constructions could directly impact the eligibility analysis. The Court agreed that claim construction could be beneficial and denied the motion without prejudice.

While Lenovo may attempt to renew its arguments following claim construction, the Court's order ensures that Hermes' patent claims remain fully intact and that the case will proceed through the next critical stages of litigation.

Statement from Hermes IP Management

"This ruling reinforces a fundamental principle of patent law: defendants should not be permitted to short-circuit infringement cases by oversimplifying patent claims before the Court has determined what those claims actually mean," said Khaled Fekih-Romdhane, Manager of Hermes IP Management LLC.

"Hermes presented substantial claim construction disputes that go directly to the technological innovations covered by our patents. The Court agreed that those issues should be addressed before any eligibility determination is made. We are pleased that the Court rejected Lenovo's attempt to dismiss these claims at the outset and look forward to advancing the case on the merits."

About the Case

The litigation, Hermes IP Management LLC v. Lenovo Group Ltd., Case No. 2:25-cv-00944-JRG, is pending before the United States District Court for the Eastern District of Texas, Marshall Division. Hermes alleges infringement of multiple patents relating to mobile device user interface technologies and location-based image data technologies.