"Significantly Less Memory” Requirement Does Not Transform Portable Device into a Special Purpose Computer

The court granted defendant's motion for summary judgment that plaintiff's electronic document distribution patents were invalid for lack of patentable subject matter because the claims were drawn to an abstract idea and not limited by an inventive concept. "The requirement that the portable device have 'significantly less' memory than the networked device does not transform the portable device into a special purpose computer. . . . Although the court understands plaintiff's argument that the steps of 'transmitting' and 'receiving' may not have been conventional practices in the field of computing at the time of invention, these steps nonetheless do nothing more than recite functions that 'can be achieved by any general purpose computer without special programming.' The court also recognizes that the application of document cataloguing in the realm of portable computing usefully addressed the problem of limited memory space in portable computers. The fact that an abstract idea may be usefully applied, however, is not enough to 'transform an unpatentable principle into a patentable process.'"
Cloud Satchel LLC v. Amazon.com Inc., 1-13-cv-00941 (DED December 18, 2014, Order) (Robinson, J.)

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Three additional patents deemed invalid under Alice

In addition to the decision reported above, three other decisions recently invalidated asserted patent claims under Alice. The asserted claims were directed to (i) the secure management of patient records, (ii) financial transaction alerts, and (iii) internet marketing via “match engine.” To view summaries of all dispositive or potentially dispositive decisions addressing unpatentable subject matter since Alice, click here. If you’d like to be notified of new orders addressing patentable subject matter, follow the link below, then click the “Create Alert” button at the bottom of the page.