Thursday, January 22, 2015

Groupware System and Integrated Circuit Design Patents Invalid Under Alice

The court granted defendant's motion for judgment on the pleadings that plaintiff's groupware system patents were invalid for lack of patentable subject matter. "The common specification of the five [patents-in-suit] describes the unremarkable concept of people working together on a project. . . . [T]his concept existed well before the invention of the [patents]. . . . The problem with the asserted claims is that their core concept is inherently abstract, and their implementation, which consists of standard technology like browsers, servers, and networks, has nothing inventive whatsoever about it."

Open Text SA v. Box, Inc. et al, 3-13-cv-04910 (CAND January 20, 2015, Order) (Donato, J.)

The court granted defendant's motion for summary judgment that plaintiff's integrated circuit patents were invalid for lack of patentable subject matter and rejected plaintiff's argument that the patents contained an inventive concept. "[I]n an effort to demonstrate the requisite 'inventive concept,' [plaintiff] first points to the lack of any reference to the claimed methods in the prior art. [Plaintiff's] reliance on a lack of prior art is misplaced, however. . . . Similarly unavailing is [plaintiff's] argument that the asserted claims do not 'pose a risk of preemption,' as logic synthesis can be performed 'without using assignment conditions.'. . . [T]he asserted claims do preempt a building block of human ingenuity, a mental process, albeit a specific one. . . . The fact that previously a designer would not have followed the exact same thought process does not change the analysis. A method primarily designed for use by a computer is, almost by definition, going to differ from the manner in which a natural person thinks through a problem."

Synopsys, Inc. v. Mentor Graphics Corporation, 3-12-cv-06467 (CAND January 20, 2015, Order) (Chesney, J.)

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