ContentGuard Holdings, Inc. v. Amazon.com Inc. et al, 2-13-cv-01112 (TXED August 6, 2015, Order) (Gilstrap, J.)
Monday, August 10, 2015
Digital Rights Patents Not Invalid Under 35 USC §101
The court denied defendants' renewed motion for judgment as a matter of law that plaintiff's digital content patents were invalid for lack of patentable subject matter because the patents were not directed toward an abstract idea and did not lack an inventive concept. "At a high level, the [asserted] Patents are generally directed toward systems and methods for controlling the use and distribution of digital works in accordance with 'usage rights' through the use of 'trusted' systems. . . .[T]he Patents-in-Suit are not directed toward an abstract idea, at least because they are directed toward patent-eligible methods and systems of managing digital rights using specific and non-generic 'trusted' devices and systems. Further, even arguendo, if the Court found that the patents are simply directed toward the 'abstract idea of enforcing usage rights and restrictions on digital content' as Defendants propose, which it does not, the claim limitations, individually and 'as an ordered combination,' are sufficient to ensure that the Patents-in-Suit amount to 'significantly more' than a patent simply on that abstract idea. . . . At the very least, the Patents-in-Suit disclose particular solutions for the problem of 'enforcing usage rights and restrictions on digital content' that '(1) [do] not foreclose other ways of solving the problem, and (2) recite a specific series of steps that result in a departure from the routine and conventional' way of managing digital rights."