Wireless Media Innovations, LLC v. Maher Terminals, LLC, 2-14-cv-07004 (NJD April 20, 2015, Order) (Linares, J.)
Thursday, April 23, 2015
Shipping Container Monitoring Patents Invalid Under Alice
The court granted defendants' motions to dismiss because plaintiff's shipping container monitoring patents claimed unpatentable subject matter. "[The] Patents are directed to the . . . . abstract idea [of] monitoring locations, movement, and load status of shipping containers within a container-receiving yard, and storing, reporting and communicating this information in various forms through generic computer functions. Plaintiff’s arguments that the patent claims are not abstract because they require physical steps and include the use of tangible components is beside the point; the claims merely recite the abstract idea of monitoring the location and load status of containers in a yard. . . . While Plaintiff argues that the claim is not abstract because it includes the use of tangible components, the Court has already noted that an abstract idea is not rendered patentable just because of connections to the physical world. . . . Adding routine steps of recording, identifying, and communicating the ID code of a particular container, or moving the container from the receiving area to a vehicle does not transform an otherwise abstract idea into patent-eligible subject matter. Instead, the claimed sequence of steps comprises only 'conventional steps, specified at a high level of generality,' which is insufficient to supply an 'inventive concept.'"