Versata Software, Inc. et al v. Zoho Corporation, 1-13-cv-00371 (TXWD October 26, 2015, Order) (Sparks, J.)
Thursday, October 29, 2015
Mobile Device Data Monitoring Patent Not Invalid Under 35 U.S.C. § 101
The court denied defendant's motion for summary judgment that plaintiffs' mobile device data monitoring patent was invalid for lack of patentable subject matter because defendant did not establish that the claims were directed to an abstract idea. "The goal of the [patent-in-suit's] innovation is to allow a relatively large amount of data about particular external states to be easily monitored on mobile devices and for the information to be digested by the user at a glance. . . . These useful compact displays are coupled with the flexibility of allowing a non-programmer user to configure what external states to monitor and how to monitor them. . . . [Plaintiff] argues that at the time the [patent] was issued, the growth of mobile device usage led to a corresponding increase in the demand for rich information content; however, the 'inevitable' space constraints on mobile devices 'limit[ed] the richness of information content available to a user.' The [patent], then, had 'the specific technical objective of allowing status updates to be displayed more efficiently within the limited display screen of a mobile phone, pager, PDA or similar mobile device.' Indulging every inference in [plaintiff's] favor, the Court concludes the [patent] does not embody an impermissibly abstract idea."