Patent For Searching and Unifying Data Invalid Under 35 U.S.C. § 101

The court granted defendant's motion for judgment on the pleadings that plaintiff's patent for searching and unifying data was invalid for lack of patentable subject matter and found that the claims lacked an inventive concept. "[P]laintiff’s proffered improvements, i.e., the solutions to 'data overload,' 'costs for organizing data,' 'data permissions,' and 'downstream proliferation of data,' are not 'necessarily rooted in computer technology to overcome a problem specifically arising in the realm of computer networks.' Rather, these are common problems generally associated with large amounts of data, not computer networks. 'Data overload,' which plaintiff describes as 'the proliferation of different data sources' has been around for ages and is a problem that undoubtedly affects noncomputerized data storage."

DATATRAK International, Inc. v. Medidata Solutions, Inc., 1-11-cv-00458 (OHND November 6, 2015, Order) (Gaughan, J.)