Tranxition, Inc. v. Lenovo (United States), Inc., 3-12-cv-01065 (ORD July 9, 2015, Order) (Hernandez, J.)
Wednesday, July 15, 2015
Computer Configuration Migration Patents Invalid Under 35 USC § 101
The court granted defendant's motion for summary judgment that plaintiff's configuration settings migration patents were invalid for lack of patentable subject matter and found that the patents lacked an inventive concept. "[Plaintiff's] invention is not 'necessarily rooted in computer technology' in the same sense as a server computer specially programmed to display a hybrid web page. True, the problem of transferring user settings from one computer to another did not arise until computers were invented. And true, [plaintiff's] invention necessarily requires a 'source computing system' and a 'targeting computing system.' The nature of the process that [plaintiff's] invention claims, however, is a human one. . . . [T]he patents themselves explain that migration is a manual process predating the invention. . . . [Plaintiff's] patents explain that one of primary problems with the manual migration process is that it can take a long time. The other problem is that the potential complexity of the migration could lead to errors. . . . Using a generic computer to perform a manual task more efficiently and accurately than a human could is not a patentable idea, and courts have routinely invalidated patents asserting such claims."