SimpleAir, Inc. v. Google Inc. et al, 2-14-cv-00011 (TXED September 25, 2015, Order) (Gilstrap, J.)
Tuesday, September 29, 2015
Data Transmission Patents Not Invalid Under 35 U.S.C. § 101
The court denied defendant's motion for summary judgment that plaintiff's data transmission patents were invalid for lack of patentable subject matter and found that the claims were not directed toward an abstract idea. "[T]he Patents-in-Suit are not directed toward an abstract idea, because they are directed toward patent-eligible methods and systems of 'using a central broadcast server' to package and transmit 'data from an online information source to remote computing devices.' Though Defendants argue that the Patents-in-Suit are directed to the abstract idea of 'packaging and transmitting information,' Defendants do not explain how such a characterization, which ignores significant claim limitations, encompasses the invention claimed by the Patents-in-Suit. Such conclusory argument, without more, is not enough for Defendants to meet their burden of establishing that the Patents-in-Suit are directed to an abstract idea. . . . The Court does not disagree that the patented inventions, at some level, contain an implementation of the abstract idea of 'packaging and transmitting information.' However, every invention can be reduced to some form of an abstract idea."