Voice and Data Communications Unification Patents Invalid Under 35 U.S.C. § 101

The court granted defendant's motion to dismiss because the asserted claims of plaintiff’s voice and data communications unification patents encompassed unpatentable subject matter and found that the claims were directed toward an abstract idea. "Plaintiff argues that the patents-in-suit 'are directed to unifying different types of electronic voice and data communication systems, and allowing users to operate the systems through natural speech recognition and commands.' The claim language (which does not recite a unification theory) calls for using a 'computer and telecommunications network for receiving, sending and managing information from a subscriber to the network and from the network to a subscriber.'. . . Although at the time of issuance the challenges addressed by the patents-in-suit undoubtedly were considered to be Internet-centric, under the current analytical paradigm (i.e., in hindsight), the fact that there are pre-Internet analogs to the patent claims suggests methods of organizing human (business) activity and, therefore, an abstract idea."

Parus Holdings, Inc. v. Sallie Mae Bank et al, 1-14-cv-01427 (DED October 8, 2015, Order) (Robinson, J.)