MicroStrategy Incorporated v. Apttus Corporation, 3-15-cv-00021 (VAED July 17, 2015, Order) (Gibney, J.)
Tuesday, July 21, 2015
Business Intelligence Patents Invalid Under 35 USC § 101
The court granted defendant's motion to dismiss plaintiff's infringement claims on the basis the asserted business intelligence patents claimed unpatentable subject matter and found that the claims were directed to abstract ideas. "The invention allows for the gathering of information, the sorting and classification of that information, and report generation based on the information. . . . [T]he patent is essentially a 'method of processing a query and returning results, deriving content from those results, and then organizing and delivering that content somewhere.' Identifying, organizing, and presenting stored information is an abstract idea that is 'devoid of a concrete or tangible application.' . . . [D]ata storage is a 'method that can be performed by human thought alone' and is therefore 'merely an abstract idea [that] is not patent-eligible under § 101.' Similarly, the 'idea of collecting information in classified form, then separating and transmitting that information according to its classification' is an abstract idea that is not patent-eligible."