lack of standing where Patent application is unidentified in assignment

Plaintiff Intellectual Ventures appealed dismissal of infringement claims under Rule 12(b)(1) for lack of standing or under Rule 12(b)(6) for patent ineligibility under Section 101.  The Federal Circuit affirmed the 12(b)(1) dismissal for lack of standing agreeing with the district court's conclusion that plaintiff did not own the rights because a particular assignor did not assign any rights in the then-pending application to the asserted patent thereby breaking a chain in ownership.  Intellectual Ventures LLC v. Erie Indemnity Co., No. 2016-1128, -1132 (Mar. 7, 2017).  The Federal Circuit affirmed the 12(b)(6) dismissals of two other patents.