01 Communique Laboratory, Inc. v. Citrix Systems, Inc., 1-06-cv-00253 (OHND December 21, 2015, Order) (Lioi, J.)
Wednesday, December 23, 2015
Patent Claiming Remote Access Communication Portal Not Invalid Under 35 U.S.C. § 101
The court granted plaintiff's motion for summary judgment that its remote access communication portal patent was not invalid for lack of patentable subject matter and found that the claims were not directed toward an abstract idea. "[Defendant] . . . argues that the invention could be, and was, performed by humans when telephone operators connected one caller to a second caller at the first caller’s request. . . . [Defendant's] analogy breaks down when claim 24 is considered as a whole, as [Alice Corp. Pty. Ltd., v. CLS Bank Int’l., 134 S. Ct. 2347 (2014)] requires. . . . [T]he purpose of claim 24 . . . in creating the private communication channel for remote access is not simply to allow people to talk with each other, but to allow direct access of data on the personal computer from the remote computer. A telephone operator cannot and does not provide the caller with direct access to data on the callee’s desk. [Defendant] oversimplifies the subject matter of the [patent] and claim 24 in an attempt to characterize the invention as an abstract idea. . . . Rather, claim 24 describes a 'particular approach' to solving problems with prior art remote access patents that could only exist in a post-Internet world, utilizing a 'location facility' that creates the private communication portal between the personal and remote computers in a specific way, even if the IP address of the personal computer is dynamic and not publicly addressable, to achieve the solution taught by the [patent-in-suit]."