Lcharts v. Tableau Software: All Three Patents Invalidated Under § 101 in 202 Days
Lcharts, LLC asserted three data visualisation patents against Tableau Software’s cloud analytics suite, including Tableau Desktop, Tableau Cloud, and Tableau CRM Analytics. Judge William Alsup of the Northern District of California granted Tableau’s motion for judgment on the pleadings, invalidating all three patents as abstract ideas lacking inventive concept — ending the case in just 202 days.
Three data visualisation patents wiped out at pleadings stage in N.D. Cal.
Lcharts, LLC filed suit against Tableau Software, LLC on 24 May 2024 in the Northern District of California, asserting infringement of three patents — US8271892B2 (the ‘892 patent), US8520000B2 (the ‘000 patent), and US9712595B2 (the ‘595 patent) — against a wide range of Tableau’s data analytics and visualisation products, including Tableau Desktop, Tableau Cloud, Tableau CRM Analytics, Tableau AI, and Tableau Prep, among others.
On 12 December 2024, Judge William Alsup granted Tableau’s motion for judgment on the pleadings under Federal Rule of Civil Procedure 12(c), holding that all three patents are directed to abstract ideas and lack the inventive concept required for patent eligibility under 35 U.S.C. § 101. The court further denied any opportunity to amend, finding the deficiencies were intrinsic to the patent claims themselves and thus incurable. Tableau’s counterclaims seeking declaratory relief of invalidity and non-infringement were simultaneously rendered moot.
The 202-day resolution is notably rapid, consistent with the Northern District of California’s track record of disposing of § 101 challenges early in proceedings. The outcome suggests the asserted claims were characterised at a high level of abstraction without a sufficiently concrete technical implementation. What remains unknown from the public record is whether Lcharts evaluated any continuation or reissue strategy, or whether a licensing negotiation preceded the filing.
Filing to Judgment on the merits for Defendant in 202 days
202 days — resolved well before trial, consistent with early § 101 dismissals
Judgment on the pleadings: what the § 101 invalidity ruling means for both parties
Judgment on the pleadings: § 101 abstract idea finding
A Rule 12(c) judgment on the pleadings is decided solely on the face of the pleadings, without discovery or trial. Here, the court applied the two-step Alice/Mayo framework and found all three patents directed to abstract ideas at step one, lacking any inventive concept at step two. Crucially, the court held that amendment was futile because no complaint allegation can alter what the patent claims themselves recite.
35 U.S.C. § 101 — Alice/MayoLcharts loses all three patents — no path to amendment
The court’s futility ruling is particularly consequential: Lcharts was denied leave to amend its complaint, meaning the patents cannot be revived in this action through re-pleading. All three asserted patents are now invalidated by a final district court judgment. Unless Lcharts pursues an appeal to the Federal Circuit, the ‘892, ‘595, and ‘000 patents are unenforceable as a matter of law.
Patents invalidated — no amendment permittedTableau achieves full invalidity without reaching claim construction
Tableau secured invalidity of all three asserted patents before any claim construction hearing or discovery, substantially reducing litigation cost and risk. Because the counterclaims for declaratory relief were mooted by the judgment — rather than adjudicated — Tableau avoids any preclusion complications. The ruling removes the entire patent portfolio Lcharts had deployed against Tableau’s product suite.
Full invalidity — pre-discovery resolution§ 101 remains a potent early defence for data visualisation software
This outcome reinforces the Northern District of California’s willingness to resolve software patent eligibility challenges at the pleadings stage, consistent with Federal Circuit precedent in Sanderling v. Snap. Data analytics and BI software vendors facing portfolio assertions should assess whether the asserted claims recite a technical solution or merely automate an abstract analytical process — the latter remains highly vulnerable to early § 101 motions.
Software patent eligibility riskFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Lcharts, LLC | Company | Data visualisation IP licensing entity — holder of US8271892B2, US8520000B2, and US9712595B2Search in Eureka ↗ |
| Defendant | Tableau Software, LLC | Company | Tableau Software, LLC — Salesforce subsidiary and leading provider of data analytics and visualisation softwareSearch in Eureka ↗ |
| Plaintiff counsel | Carrie J. Richey | Attorney | Counsel for Lcharts, LLCSearch in Eureka ↗ |
| Plaintiff counsel | Carrie Richey | Attorney | Counsel for Lcharts, LLCSearch in Eureka ↗ |
| Plaintiff counsel | Christian Emile Mammen | Attorney | Counsel for Lcharts, LLCSearch in Eureka ↗ |
| Plaintiff counsel | Daniel M. Grigore | Attorney | Counsel for Lcharts, LLCSearch in Eureka ↗ |
| Plaintiff counsel | Fabio Elia Marino | Attorney | Counsel for Lcharts, LLCSearch in Eureka ↗ |
| Plaintiff counsel | Michael P. Adams | Attorney | Counsel for Lcharts, LLCSearch in Eureka ↗ |
| Plaintiff counsel | Steven M. Levitan | Attorney | Counsel for Lcharts, LLCSearch in Eureka ↗ |
| Plaintiff law firm | Dykema Gossett PLLC | Law Firm | Representing Lcharts, LLCSearch in Eureka ↗ |
| Plaintiff law firm | Womble Bond Dickinson (US) LLP | Law Firm | Representing Lcharts, LLCSearch in Eureka ↗ |
| Defendant counsel | Ciara N. McHale | Attorney | Counsel for Tableau Software, LLCSearch in Eureka ↗ |
| Defendant counsel | Erin Catherine Jones | Attorney | Counsel for Tableau Software, LLCSearch in Eureka ↗ |
| Defendant counsel | Erin Jones | Attorney | Counsel for Tableau Software, LLCSearch in Eureka ↗ |
| Defendant counsel | Hailey L. Suggs | Attorney | Counsel for Tableau Software, LLCSearch in Eureka ↗ |
| Defendant counsel | Matthew C. Powers | Attorney | Counsel for Tableau Software, LLCSearch in Eureka ↗ |
| Defendant counsel | Ryan A. Tyz | Attorney | Counsel for Tableau Software, LLCSearch in Eureka ↗ |
| Defendant counsel | Ryan Tyz | Attorney | Counsel for Tableau Software, LLCSearch in Eureka ↗ |
| Defendant counsel | Sean Apple | Attorney | Counsel for Tableau Software, LLCSearch in Eureka ↗ |
| Defendant counsel | Sean Kristofer Apple | Attorney | Counsel for Tableau Software, LLCSearch in Eureka ↗ |
| Defendant counsel | Udit Sood | Attorney | Counsel for Tableau Software, LLCSearch in Eureka ↗ |
| Defendant law firm | Graves Dougherty Hearon & Moody PC | Law Firm | Representing Tableau Software, LLCSearch in Eureka ↗ |
| Defendant law firm | Tyz Law Group PC | Law Firm | Representing Tableau Software, LLCSearch in Eureka ↗ |
| Presiding judge | Judge William Alsup | Judge | California Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The court’s order is unusually direct: it invalidates all three patents on the face of the pleadings, explicitly citing Sanderling v. Snap to foreclose any amendment. The phrase ‘fundamental infirmities that assertions elsewhere cannot repair’ signals the judge found the abstract idea not merely insufficiently pleaded but structurally baked into the patent claims — a strong finding that would complicate Federal Circuit reversal, which requires de novo review of § 101 but deference on any underlying factual findings.
US8271892B2, US8520000B2 & US9712595B2 — Data Visualisation and Charting Technology
The three asserted patents — US8271892B2, US8520000B2, and US9712595B2 — cover methods and systems relating to interactive data charting and visualisation, spanning application dates across 2008 to 2014. The patents fall within the broader software domain of business intelligence and data presentation, an area where § 101 eligibility has been sharply contested since the Supreme Court’s Alice Corp. v. CLS Bank decision in 2014. The claims were found to recite abstract ideas without the concrete technical implementation needed to confer eligibility.
These patents were asserted against virtually all of Tableau’s commercial product lines — from Tableau Desktop to Tableau AI — signalling a broad licensing or enforcement strategy targeting the data analytics market. The invalidation of all three in a single ruling by one of the Northern District’s most experienced patent judges substantially erodes the portfolio’s licensing leverage. Competitors and potential acquirers of similar charting or data presentation IP should treat this outcome as a benchmark for assessing abstract idea risk in the BI software sector.
Should you run an FTO analysis against US8271892B2, US8520000B2, and US9712595B2?
Despite the invalidity ruling, product and IP teams working on data visualisation, charting libraries, or business intelligence tooling should conduct FTO analysis against these patents and related family members. The invalidation applies as a judgment in this specific case; continuation applications or related patents from the same family may still be active and enforceable. Any team building interactive data presentation features should assess exposure across the broader Lcharts portfolio.
PatSnap Eureka’s FTO Search Agent can map the full patent family surrounding US8271892B2, US8520000B2, and US9712595B2 — identifying active continuations, divisionals, or related applications that were not asserted in this case. Eureka can also surface prior art that further supports invalidity arguments and benchmark your product features against the claim language to quantify infringement risk across the live family.
Run a freedom-to-operate analysis on US8271892B2 to assess your product’s exposure
Run FTO in Eureka →Similar § 101 data visualisation patent cases in N.D. Cal. and the Federal Circuit
Cases involving data analytics and business intelligence software patents invalidated under § 101 in the Northern District of California and Federal Circuit.
What this case signals for the data analytics and BI software IP landscape
The rapid § 101 takedown of three charting patents signals continued exposure for abstract software IP in N.D. Cal.
Early § 101 motions remain decisive against data visualisation patents
Judge Alsup’s ruling confirms that data visualisation and charting patents framed at a functional or abstract level — without a concrete, specific technical implementation — remain highly susceptible to Rule 12(c) motions in the Northern District of California. Defendants should file § 101 challenges early and press the futility of amendment.
Patent drafters must embed technical specificity to survive Alice scrutiny
The court’s refusal to allow amendment underscores that § 101 deficiencies must be addressed at prosecution, not litigation. Patent holders asserting data analytics IP should audit existing portfolios for abstract idea exposure and ensure continuation applications include claim language tied to specific technical improvements rather than generalised data processing outcomes.
Lcharts v Tableau — key questions answered
Lcharts asserted US8271892B2 (the ‘892 patent), US8520000B2 (the ‘000 patent), and US9712595B2 (the ‘595 patent) — all covering data visualisation and charting technology. All three were invalidated by Judge Alsup under 35 U.S.C. § 101 as directed to abstract ideas lacking inventive concept.
The court held that amendment was futile because the abstract idea deficiency was intrinsic to the patent claims themselves, not to how the complaint characterised them. Citing Sanderling v. Snap (Fed. Cir. 2023), Judge Alsup stated that no amendment to a complaint can alter what a patent itself states.
A Rule 12(c) motion for judgment on the pleadings is decided on the face of the pleadings alone — before discovery or claim construction. In patent cases, courts apply it to resolve § 101 eligibility when the abstract nature of the claims is apparent from the patent document itself, allowing defendants to obtain invalidity rulings at minimal cost.
Once the court invalidated all three asserted patents via judgment on the pleadings, there was no live controversy remaining for Tableau’s counterclaims seeking declaratory relief of invalidity and non-infringement. Courts treat such counterclaims as moot when the underlying dispute is fully resolved by the main ruling, avoiding a redundant separate adjudication.
Lcharts accused a broad range of Tableau products, including Tableau Desktop, Tableau Cloud, Tableau Server, Tableau Public, Tableau Prep, Tableau AI, Tableau CRM Analytics, Tableau Advanced Management, Tableau Data Management, Tableau Embedded Analytics, and Data Cloud for Tableau — effectively Tableau’s entire commercial analytics suite.
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