Containerized Data Patents Invalid Under 35 U.S.C. § 101

The court granted defendant's motion to dismiss because the asserted claims of plaintiff’s containerized data patents encompassed unpatentable subject matter and found that the claims were directed toward an abstract idea. "[T]he [first patent-in-suit] recites the abstract idea of searching and processing containerized data. Updating searchable containers of information based on past search results or based on external time or location resembles age-old forms of information processing such as have previously been employed in libraries, businesses, and other human enterprises with folders, books, time-cards, ledgers, and so on. . . . [T]he [second] patent is also directed to an abstract idea: containerized data storage utilizing rules and instructions."

Evolutionary Intelligence, LLC v. Yelp, Inc., 5-13-cv-03587 (CAND October 6, 2015, Order) (Whyte, J.)