Text-Message Telecommunication Patent Not Invalid Under Alice

The court granted plaintiff's motion for judgment on the pleadings that its server communication patent was not invalid for lack of patentable subject matter because it claimed an inventive concept. "Claim 20 is directed to a problem unique to text-message telecommunication between a mobile device and a computer. The solution it provides is tethered to the technology that created the problem. . . . It specifies how an interaction between a mobile phone and a computer is manipulated in order to achieve a desired result which overrides conventional practice. . . . If one looks at almost any patent from far enough away, it could arguably claim an abstract idea. For example, Alexander Graham Bell's patent could be said to claim the abstract idea of oral communication. But his invention was not the concept of oral communication itself; it was a technological innovation that allowed a type of oral communication between people who could otherwise not communicate in that way. The claimed method here does the same: it uses technology that allows communication where it would otherwise be impossible."

Messaging Gateway Solutions LLC v. Amdocs, Inc. et al, 1-14-cv-00732 (DED April 15, 2015, Order) (Andrews, J.)