Defendant's motion to dismiss plaintiff's infringement action for failure to state a claim was granted. "The Complaint alleges that 'as a result of its activities in connection with the television show "American Idol,"' the Defendant is infringing Plaintiff's patents. The Complaint does not allege which device, product, or method infringes Plaintiff's patents with any greater specificity. . . . Plaintiff fails to plead any information that identifies the infringing product or method or even the class or type of the product or method. The Complaint implies, but does not actually state, that Defendant's 'electrical systems' infringed Plaintiff's patents, but provides no details about which 'electrical systems' are at issue. . . . In fact, the only explicit allegations of infringement in this Rorschach-image-style Complaint are that Defendant infringed the patents at issue 'as a result of its activities in connection with the television show 'American Idol.'"
Lyda v. Fremantlemedia North America, 1-10-cv-04773 (NYSD July 14, 2011, Order) (Batts, J.)