JIPEL Blog 2015 - 2016 Patent Trademark

Courts Should Swipe Left on the Online Dating Patent

ByStaff Editor

Oct 19, 2015

Trends have shown that Americans are turning to the internet to pursue new dating prospects, with online dating rates at an all-time high.  However, a recently settled lawsuit against an online dating app has caused controversy in the world of intellectual property, and despite the settlement, the case could have potentially far-reaching effects for online dating in general.  Spark Networks, a parent company that owns a variety of Jewish-targeted matchmaking platforms including the popular JDate, filed a patent and trademark infringement lawsuit against Smooch Labs, the owner of the competing app JSwipe, and the suit has made waves among legal commentators.  
The lawsuit, Spark Networks USA v. Smooch Labs, Inc., involved two main intellectual property claims.  First, Spark Networks alleged that JSwipe’s name and branding violate its “J-Family” trademark portfolio.  Second, Spark Networks alleged that JSwipe’s matchmaking formula and method violate its patented “Method and Apparatus for Detection of Reciprocal Interests or Feelings and Subsequent Notification” issued in United States Patent No. 5,950,200.  
Experts were initially skeptical of the viability of both claims.  As pointed out by technology expert Greg Ferenstein, the use of the letter “J” is especially common in Jewish-centered media, including a variety of other dating apps like JCrush, JWed, and JZoog.  The central focus of trademark infringement claims is whether or not there is a “likelihood of confusion,” which means that consumers would mistakenly believe a product or service is associated with the source of a different product or service identified with a similar mark. However, with the large amount of “J”-related content available to the public, it was unlikely that the average consumer would wrongfully believe JSwipe was associated with JDate.
The patent infringement case appeared even more dubious.  According to Charles Duan, the Director of the Patent Reform Project at Public Knowledge, Spark Networks’ patent is “absurd.”  The method, patented in 1999, is essentially a matchmaking algorithm.  One user (“Person A”) indicates their interest in a second user (“Person B”) to the system.  Person A’s interest in Person B remains hidden until Person B also indicates interest in Person A.  A “match” only occurs when the system determines that Person A and Person B both have indicated mutual interest in each other.  As Duan points out, this patented method has been in practice for hundreds, if not thousands, of years, and Spark Networks has done little innovation other than filing a patent for a particularly abstract idea.
If this case had not settled, it likely would have been invalidated under the Supreme Court’s abstract ideas doctrine laid out in Alice Corporation v. CLS Bank International.  In that case, the Court refused to allow a patent that was simply a “method of organizing human activity,” since that method was too abstract.  According to Daniel Nazer, an attorney at the Electronic Frontier Foundation, the Spark Networks patent infringement claim was “not a close case.” Matchmaking methods, much like the currency exchange methods in Alice Corporation, is simply too abstract of an idea to qualify for a patent.  However, now that Spark Networks has acquired Smooch Labs and its JSwipe brand, the case is no longer on a docket and a court will not have the opportunity to analyze the validity of its patent.
So now that JSwipe is officially affiliated with Spark Networks and JDate, the controversy should be over, right?  Not quite.  As of October 2015, Spark Networks’ patent still exists and many large websites are paying to use intellectual properties owned by Spark Networks.  For instance, because of the terms of settlement in the 2011 suit Spark Networks USA v. Humor Rainbow, Inc., the Internet giant IAC, which purchased Humor Rainbow during the course of the suit, agreed to pay to use all of Spark Networks’ intellectual properties.  Since IAC owns some of the biggest names in online dating, including Tinder, Match.com, and OkCupid, it is safe to assume that Spark Networks is profiting off of the majority of online dating activity.
The apps most affected by this current patent regime are up-and-coming competing dating services like JSwipe that cannot necessarily afford to pay for use of the patent, especially at early stages in their development.  Before the settlement, JSwipe and Smooch Labs faced financial ruin, forcing the owners of JSwipe to set up an Indiegogo crowdfunding campaign to cover their legal fees.  This threat of litigation can be seen as utilizing courts to impose additional costs on competitors.  Potential defendants who wish to defend against Spark Networks’ patent infringement claims face high legal fees – estimated to be between $300,000 and $500,000.  Therefore, despite the likely invalidity of Spark Networks’ patent, it is doubtful that a case will get to a point where a court can strike it down any time soon, since defendants like JSwipe will probably settle in a similar fashion or perhaps even shut down entirely.
The losers in all of this are consumers.  With former entirely-free-to-use apps like Tinder now offering added benefits to paid subscribers, the number of popular, completely free apps is dwindling.  According to David Yarus, the creator of JSwipe, app developers are constantly searching for new “fast, fun, and free” ways to make connections, since “[t]he idea of pay-to-play dating websites doesn’t resonate with millennials.” However, with potential litigation looming over developers’ heads, incentives to create new content is dwindling, and the concentration of ownership among dating apps will likely continue.
With no solution in site, it will be interesting to see how the patent landscape in the world of online dating will continue to evolve.  With Spark Networks now having multiple settled lawsuits over its patent under its belt, it is hard to not to begin to view the company as a “patent troll” preying on would-be competitors.  We may need a proverbial David to take on the Goliath that is Spark Networks so that a court can finally “swipe left” on its online dating patent once and for all.
 
Eddie Guers is a J.D. candidate, 2017, at NYU School of Law.

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    وبلاگ شیرین! من آن را در حین جستجو در
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    در لیست یاهو نیوز دارید؟ مدتی است که تلاش
    می کنم اما به نظر می رسد هرگز به آنجا نرسیدم!
    قدردانی کنید|
    عالی وب سایت. Lots of مفید اطلاعات در اینجا.
    من آن را برای چند دوستان ارسال می‌کنم و هم‌چنین در
    خوشمزه به اشتراک می‌گذارند. و البته، ممنونم از تلاش!|
    عالی انتشار، بسیار آموزنده. معجبم چرا برعکس متخصصان این بخش {نمی‌دانند} توجه می‌کنند.
    نوشتن خود را باید ادامه دهید.من مطمئن هستم}، دارید پایگاه خوانندگان بسیار بزرگی دارید!|
    ضرب عالی ! وقتی سایت خود را اصلاح می‌کنید،
    می‌خواهم شاگردی کنم، چگونه می‌توان برای
    وبلاگ وب‌سایت مشترک شوم؟ حساب به من کمک کرد
    تا معامله قابل قبولی داشته باشم.
    من تا حدی با این برنامه ارائه ارائه شده روشن و شفاف ایده| آشنا بودم.

    عالی امتیاز در مجموع، شما فقط به
    دست آوردید یک خواننده جدید. چه چیزی
    آیا شما پیشنهاد در مورد پست خود}
    که شما روز پیش؟ آیا مطمئنا؟|
    آیا اشکالی ندارید که چند از مقالات شما را تا زمانی که اعتبار و منابع را به وبلاگ شما ارائه می‌دهم نقل کنم؟ وبلاگ سایت من در دقیقاً
    یکسان توقف شماست و کاربران من واقعا از 101 سود می‌برند.
    بسیاری از اطلاعاتی که در اینجا {ارائه می‌دهید}.
    لطفاً به من اطلاع دهید اگر این خیلی خوب با شماست.

    به سلامتی!|
    با داشتن این همه محتوا و مقاله آیا تا به حال با مشکلات سرقت ادبی یا نقض حق چاپ مواجه شده اید؟ وب سایت
    من دارای محتوای کاملاً منحصر به فرد زیادی است که
    من خودم یا خودم ایجاد} یا
    برون سپاری کرده ام، اما به نظر می رسد بسیاری
    از آن ها هستند. نمایش آن در سرتاسر اینترنت بدون مجوز من.
    آیا هیچ راه حل برای کمک به کاهش بیان|گفتن} و راه
    که می‌گویی. می‌سازید آن را لذت‌بخش می‌کنید
    و هنوز مراقب باشید تا آن را معقول نگه دارید} .

    من نمی‌توانم صبر کنم تا از شما بیاموزم
    بسیار بیشتر. این است در واقع یک عالی سایت.|
    اگر کسی می‌خواهد با جدیدترین فناوری‌ها
    به‌روز شود بعد از آن باید بازدید
    این وب سایت بروید و هر روز به روز باشید.|
    من معجب بودم که آیا تا به حال {به
    این فکر می‌کنید که} طرح‌بندی سایت خود را تغییر
    دهید؟ بسیار خوب نوشته شده است؛ من عاشق
    چیزی هستم که باید بگویی اما شاید بتوانید کمی
    بیشتر در مسیر محتوا قرار دهید تا مردم
    بتوانند بهتر با آن ارتباط برقرار کنند.
    فقط برای داشتن 1 یا دو تصاویر متن
    بسیار زیادی دارید. شاید بتوانید آن را بهتر از هم جدا کنید؟|
    خیلی به سرعت این وب‌سایت در میان
    همه وبلاگ‌نویسی و سایت‌سازی بینندگان، به دلیل اینکه مقالات یا نظرات است،
    خوب است}|
    اگر کسی آرزو دارد نظر متخصص در خصوص راه‌اندازی وبلاگ سپس مشاوره به او برای رفتن برای دیدن این وبلاگ، ادامه دهید عصبی کار.|
    اجناس فوق العاده از شما مرد.
    من مطالب شما را قبلاً درک کرده ام و تو
    فقط خیلی عالی} عالی. من در واقع آنچه را که در اینجا به دست آورده‌اید، واقعاً، واقعاً آنچه را که می‌گویی} و نحوه بیان
    آن را دوست دارم. شما آن را لذت‌بخش می‌کنید و همچنان مواظب هستید تا آن
    را عاقلانه نگه دارید. من نمیتونم صبر کنم تا خیلی بیشتر از شما بخونم.
    این واقعا یک برد فوق العاده استderful| فوق العاده}
    وب سایت.|
    ضرب فوق العاده ! من می‌خواهمدر
    حالی که وب‌سایت خود را اصلاح می‌کنید، چگونه می‌توانم برای یک وبلاگ وب سایت؟ حساب aided یک معامله قابل قبول.
    من بودمآشنای} با این پخش شما ارائه روشن
    روشن ایده|
    معمولا من در وبلاگ‌ها نمی‌ مقاله می‌کنم، اما می‌خواهم بگویم که این نوشته بسیار مجبور تلاش
    و چنین انجام دهم! طعم نوشتن شما
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    پست.|
    این وب‌سایت ازطریق پسر عمویم} پیشنهاد شد.
    من نه مثبت آیا این انتشار نوشته شده است
    هی وجود دارد. من وبلاگ شما را با استفاده از
    msn پیدا کردم. این یک مقاله بسیار خوب است.
    می‌خواهم مطمئن شوید آن را نشانه‌گذاری
    می‌کنم و برای خواندن اطلاعات بیشتر از اطلاعات مفید شما،
    برمی‌گردم. از پستتان ممنونم.
    حتما برمی گردم. خوب نوشته شده است.
    مطمئن شوید آن را نشانک‌گذاری می‌کنم و برمی‌گردم تا از اطلاعات بیشتر مفید بیاموزید.
    بابت پست متشکرم. حتما برمی گردم.|
    با تشکر for one’s را تخصص داشتم، از بارگذاری مجدد سایت بسیاری از بارها قبل از من می‌توانستم آن را به‌درستی بارگیری کنم.

    می‌دانستم که آیا میزبان وب شما خوب
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    خب من این RSS را به e-mail خود اضافه می‌کنم و می‌توانم به
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    محتوای | هیجان انگیز}. مطمئن شوید این را دوباره خیلی زود به روز کنید.|
    آنچه من نمی‌دانم این است که اگر حقیقت گفته
    شود چگونه شما دیگر نیستید واقعا خیلی بیشتر خوب-ترجیح از شما ممکن است در حال حاضر.
    تو خیلی باهوشی. می‌دانید بنابراین به‌طور
    قابل‌توجهی در مورد این موضوع، من را از نظر من در نظر بگیرید آن را از {تصور کنید} زوایای بسیار زیاد|تعدادی|بسیاری از}
    متنوع. مانند زنان و مردان به نظر
    نمی‌رسد درگیر تا این چیزی کاری} برای
    انجام با گاگای زن! شخصی چیزهای خوب است.
    همیشه مراقبت!|
    عجب! بالاخره من یک صفحه وب دریافت کردم که از آنجا میتوانم واقعاً |در واقع|درست|واقعاً} دریافت مفید داده
    درباره مطالعه و دانش من.|
    وقتی کسی پست را می نویسد، ایده یک کاربر را در مغز خود حفظ
    به نفع من، که این زمان من دارم این تأثیرگذار آموزنده مقاله را اینجا در مسکن.|
    چه خبر، همه‌چیز اینجا خوب پیش می‌رود و البته همه حقایق را به اشتراک می‌گذارند، این واقعا خوب، به نوشتن
    ادامه دهید.|
    A impressive! من همین الان این را برای یک همکار که بود انجامکوچکی تکلیف در مورد این.
    و برای من در واقع سفارش داد ناهار به این دلیل که برای او کشف کردم روده
    بر شدن از خنده. بنابراین {اجازه دهید} این را دوباره بنویسم ….
    از شما برای وعده غذایی!! اما
    بله، {تشکر} از اینکه زمان را صرف بحث و گفتگو در مورد} این موضوع در اینجا در صفحه وب.|
    اوه این وبلاگ فوق العاده خیلی دوست دارم
    مقالات شما را می‌خوانم|مطالعه می‌کنم.

    {بمانید|به کار {خوب|عالی} ادامه دهید!

    {می‌دانید|می‌فهمید|می‌دانید|می‌شناسید|از قبل می‌دانید}، {بسیاری|بسیاری از|خیلی‌ها} {مردم هستند|افراد هستند|افراد} {شکار|جستجو|نگاه می‌کنند} {در اطراف|دور می‌گردند} برای این {اطلاعات|اطلاعات}، {می‌توانید|می‌توانید} بسیار
    به آنها {کمک|کمک کنید}. |
    {سلام|هیا|هی|هی|روز بخیر|سلام|سلام|سلام|سلام|سلام}!
    من می دانم که این تا حدی خارج از موضوع است {با این حال،|با این وجود|اما|اما} فکر می کردم بپرسم.
    آیا علاقه مند به {تبادل|تجارت} پیوندها
    هستید یا ممکن است مهمان {نوشتن|نویسنده} یک
    وبلاگ {مقاله|پست} باشید یا بالعکس؟
    {وب‌سایت|سایت|وبلاگ} من
    {می‌گذرد|بحث می‌کند|آدرس|پوشش می‌دهد}

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