Judge Robinson Rejects § 101 Challenges Against Image Scanning, Network Congestion, and Translingual Internet Search Patents

The court denied defendant's motion for judgment on the pleadings on the ground that plaintiff’s image scanning patent encompassed unpatentable subject matter because the asserted claims were not directed toward an abstract idea. "The asserted claims include steps for determining the parameters (which meet a certain mathematical formula) and applying such parameters to operate a scanner. The court concludes that such claims do not claim the mathematical formula nor do they seek to simply 'implement' such a formula, therefore, the claims are not directed to an abstract idea."

Intellectual Ventures I LLC v. Ricoh Americas Corporation et al, 1-13-cv-00474 (DED March 22, 2016, Order) (Robinson, J.)

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The court denied defendants' motion to dismiss on the ground that plaintiff’s network congestion control patent encompassed unpatentable subject matter because the asserted claims were not directed toward an abstract idea. "Defendants analogize the claims at bar to resource management performed by a human such as a TSA worker at an airport checkpoint or a factory line supervisor of widgets down a production assembly line. . . . [C]laims 1 and 6 are directed to 'alleviating congestion in a communication network' and recite steps used to perform the method for a flow of data to and from end user devices connected to a network through communication devices. That defendants are able to come up with a human equivalent of 'resource control management' does not render the claims at bar similar to methods that 'merely recite the performance of some business practice known from the pre-Internet world along with the requirement to perform it on the Internet.' Instead, the claims at bar are . . . 'necessarily rooted in computer technology in order to overcome a problem specifically arising in the realm of computer networks.'"

Network Congestion Solutions LLC v. United States Cellular Corporation, 1-14-cv-00903 (DED March 22, 2016, Order) (Robinson, J.)

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The court denied defendant's motion to dismiss on the ground that plaintiff’s translingual internet search and advertising patents encompassed unpatentable subject matter because the asserted claims were not directed toward an abstract idea. "Defendant analogizes the method of the [patent-in-suit] to a set of tasks performed by a human, concluding that the [patent] is directed to the abstract idea of searching for documents in a foreign language by translating a modified search request. . . . That a method involving a computer and the internet may be broken down into a series of steps performed by a human does not resolve whether such method is an 'abstract idea.'. . . The methods at bar do not perform a business method known from the pre-Internet world on the computer, instead, the methods contain an additional layer of complexity. The methods of [one patent-in-suit] 'address the problem of ensuring that Internet search engines retrieve not only Web pages and documents written in the query language (source), but in foreign (target) languages as well.' The methods of the [other] patent perform translingual searches and use them to display cross-language advertising to the user of the search engine.'"

Improved Search LLC v. AOL Inc., 1-15-cv-00262 (DED March 22, 2016, Order) (Robinson, J.)