Network Resource Access Control Patents Not Invalid Under 35 U.S.C. § 101

The court granted plaintiff's cross-motion for summary judgment that its network resource access control patents were not invalid for lack of patentable subject matter and found that the claims contained an inventive concept. "During the mid-1990s, the patents addressed an inventive concept that solved the problem of delivering resources over an untrusted network. . . . [T]he patents’ inventive use of identity associated with the client computer to control access to resources over an untrusted network was an improvement over the current technology of that time . . . [T]he patents in application do more than 'broadly and generically claim ‘use of the Internet’ to perform an abstract business practice.' The claims modify the way the Internet functions to provide secure access over a protected computer resource. The problems addressed by [plaintiff's] claims are ones that 'arose uniquely in the context of the Internet, and the solution proposed was a specific method of solving that problem.'"

Prism Technologies v. T-Mobile USA, Inc., 8-12-cv-00124 (NED September 22, 2015, Order) (Strom, J.)