SRI International Inc. v. Cisco Systems Inc., 1-13-cv-01534 (DED April 11, 2016, Order) (Robinson, J.)
Wednesday, April 13, 2016
Network Security Patents Not Invalid Under 35 U.S.C. § 101
The court denied defendant's motion for summary judgment that the asserted claims of plaintiff’s network security patents encompassed unpatentable subject matter and found that the claims were not directed toward an abstract idea. "[Defendant] argues that the claims are directed to the abstract idea 'of monitoring and analyzing data from multiple sources to detect broader patterns of suspicious activity,' which is 'a fundamental building block of intelligence gathering and network security.' [Defendant] analogizes this idea to a number of spy and security gathering endeavors, including 'networks [employed by] . . . both sides during the Revolutionary War' . . . . That [defendant] can simplify the invention enough to find a human counterpart (or argue that a human could somehow perform the steps of the method) does not suffice to make the concept abstract, as '[a]t some level, "all inventions . . . embody, use, reflect, rest upon, or apply laws of nature, natural phenomena, or abstract ideas."' The patents address the vulnerability of computer networks' 'interoperability and sophisticated integration of technology' to attack. The claims at bar are, therefore, more complex than 'merely recit[ing] the performance of some business practice known from the pre-Internet world along with the requirement to perform it on the Internet,' and are better understood as being 'necessarily rooted in computer technology in order to overcome a problem specifically arising in the realm of computer networks.'"