Electronic Messaging Patents Invalid Under 35 U.S.C. § 101

The court granted defendant's motion for summary judgment that the asserted claims of two of plaintiff’s electronic messaging patents encompassed unpatentable subject matter and found that the claims were directed toward an abstract idea. "[T]he asserted claims of [one patent] are directed to the basic idea of sending and storing messages, which is not rooted in computer technology. . . . The idea of sending and storing messages as described in the [patent] is an abstract idea that is not patent eligible. . . . The Court further determines that claim 8 of the [other] Patent is directed to a method for effectuating the abstract concept of coded communication. [Defendant's] hypothetical of coded battlefield communications shows how the method of claim 8 of the [patent] could be performed by a human. . . . The practice of communicating using codes has been in existence for a long time. Coded communication is an abstract idea that is not patent eligible."

Mobile Telecommunications Technologies, LLC v. Research In Motion Corporation, 3-12-cv-01652 (TXND May 12, 2016, Order) (Lynn, J.)