Wednesday, March 2, 2016

Email Address Directory Patent Invalid Under 35 U.S.C. § 101

The court granted defendant's motion for judgment on the pleadings that the asserted claims of plaintiff’s email system patent encompassed unpatentable subject matter and rejected plaintiff's argument that the claims were not directed toward an abstract idea based on TQP Dev., LLC v. Intuit Inc. (E.D. Tex. Feb. 19, 2014). "[Defendant] contends the [patent-in-suit] is nothing more than a computerized version of the ages old concept of an address directory. . . . [T]he TQP decision does not stand for the proposition that any improvement in computer communication is inherently patent eligible. Rather, the court found patent eligibility because the patent 'involves a method for changing data in a way that will affect the communication system itself, by making it more secure.'. . . [T]he [patent-in-suit] involves a method of doing business (i.e. the idea of using information in a message's destination address to look up the recipient's correct address), but does not involve any data modification in a way that will affect the communication system itself. The limitation of 'email address' as 'a string of characters complying with an addressing format for transmission of an email message by the SMTP protocol' does not effect the first step of the [Alice Corp. v. CLS Bank Int'l, 134 S. Ct. 2347 (2014)] analysis because a field of use limitation does not make an idea non-abstract. The Court is well aware that in many cases it is difficult to distinguish between an abstract idea and its application. . . . [T]he [patent-in-suit] is most accurately characterized as directed to the abstract idea of an address directory."

A PTY Ltd. v., Inc., 1-15-cv-00154 (TXWD February 29, 2016, Order) (Pitman, M.J.)

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