Digital Content Usage Rights Patents Not Invalid Under 35 U.S.C. § 101

The court denied defendants' renewed motion for judgment on the pleadings that plaintiff's digital content usage rights 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, 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. Though the Patents-in-Suit address problems associated with creating and enforcing usage rights with content, they are directed to non-abstract solutions through the use of trusted systems. Further, the Court finds Defendants’ analogy to library loans unpersuasive. A library cannot effectively enforce usage restrictions on a book once that book has left the library’s premises. . . . Defendants essentially argue that the Patents-in-Suit must disclose detailed levels of security in order to require 'specific computer programming.' However, the implementation of the invention disclosed in the Patents-in-Suit may require 'specific computer programming,' even though the Patents-in-Suit may not disclose the particular security levels of that implementation."

ContentGuard Holdings, Inc. v. Amazon.com Inc. et al, 2-13-cv-01112 (TXED October 5, 2015, Order) (Gilstrap, J.)