Distributed Learning Patent Invalid Under 35 U.S.C. § 101

The court granted defendant's motion for summary judgment that plaintiff's distributed learning patent was invalid for lack of patentable subject matter and found that the claims were directed toward an abstract idea. "Plaintiff responds that the [patent-in-suit] is 'not directed to the abstract idea of a classroom,' but instead claims 'specific methods and systems of distributed learning — an instructional model that allows instructors, students, and content to exist in different physical locations so that instruction and learning can occur independent of place and time.'. . . [T]he claims are directed to the abstract concept of creating a virtual, interactive learning environment. . . . Plaintiff's argument that the idea of 'real time, interactive distance learning' claimed in the [patent] 'necessarily requires a technology solution' is similarly beside the point, for the fact that a method can only be performed using a computer does not necessarily render Section 101 inapplicable."

Richard A. Williamson v. Citrix Online LLC, et al, 2-11-cv-02409 (CACD February 17, 2016, Order) (Otero, J.)