Computer Navigator Patent Invalid Under 35 U.S.C. § 101

The court granted defendant's motion to dismiss because the asserted claims of plaintiff’s computer navigation patent encompassed unpatentable subject matter and found that the claims were directed toward an abstract idea. "[M]aps of cities have long existed that depict structures and include identifying marks that direct a user to information about those structures. . . . The Plaintiff makes much out of the fact that their invention is a 'non-text based system' that does not require, for example, the numbers used on [defendant's demonstrative] map to provide a user with information about a particular store. The Court finds this fact inapposite. . . . The Court also finds the use of multiple layers of maps that enables users to zoom into and out of a geographic area is an unpatentable abstract idea. . . . The Court does not agree that the [patent-in-suit] addresses a challenge particular to computers or the Internet. Rather, the [patent] addresses a problem 'known from the pre-Internet world': navigating through maps and locating information about structures appearing on those maps."

Peschke Map Technologies LLC v. Rouse Properties, Inc., 1-15-cv-01365 (VAED March 8, 2016, Order) (O'Grady, J.)