In Paltak Holdings, Inc. v. Riot Games, Inc., C.A. No. 16-1240-SLR (D.Del. May 15, 2017), Judge Sue L. Robinson denied Defendant’s motion to dismiss due to lack of patentable subject matter. The patents-in-suit “related to distribution of messages between computers in interactive environments, such as online gaming,” and Defendant argued they were directed to the abstract idea of “group communication that uses an agent to aggregate those communications for delivery.” Id. at 1, 4. The Court disagreed, finding the claims distinguishable from claims previously held unpatentable by the Federal Circuit. Id. at 8. In addition to agreeing with Plaintiff that the claims were not directed to an abstract idea, the Court also observed that Defendant had not carried its burden to show an abstract idea because the comparisons it attempted to draw would require consideration of matters outside the pleadings. Id. at 8-9.