Bascom Research, LLC v. Facebook, Inc., 3-12-cv-06293 (CAND January 5, 2015, Order) (Illston, J.)
Wednesday, January 7, 2015
Data Structure for Linking Data is Abstract Idea
The court granted defendants' motion for summary judgment that plaintiff's network document management patents were invalid for lack of patentable subject matter and found that the claims were drawn to an abstract idea. "[Plaintiff] argues that [the claims at issue in Alice Corp. Pty. v. CLS Bank Int’l, 134 S. Ct. 2347 (2014), and buySAFE, Inc. v. Google, Inc., 765 F.3d. 1350, 1355 (Fed. Cir. 2014)] are fundamentally different from [the patents-in-suit], which 'narrowly claim a specific type of data structure for linking data' . . . namely the 'link relationships' and 'link directories' in which link relationships are stored separately from a document object and relate documents objects to one another. . . . [Plaintiff] relies upon a narrow interpretation of the term 'abstract idea.' Abstract ideas are not limited to 'fundamental truths,' 'fundamental economic practices,' or 'basic tools of scientific and technological work.'. . . Allowing users to generate relationships between document objects and storing those relationships separately from the document objects simply describes the abstract idea of creating, storing and using relationships between objects. As defendants illustrate at length, the concept of establishing and using relationships between documents is a common, age-old practice. Courts have found similar 'commonplace and time-honored practices' to be abstract ideas."