Geographical Data Display Patent Not Invalid Under 35 U.S.C. § 101

The court denied defendant's motion for summary judgment that plaintiff's geographical data display patent was invalid for lack of patentable subject matter and found that the asserted claims did not lack an inventive concept. "The [patent-in-suit] seeks to 'enable [space related] data to be represented in any pre-selected image resolution in the way in which the object would have been seen by an observer with a selectable location and selectable direction of view.' Further, the patent aims to 'keep the effort required for generating an image so low that the image generation takes place so rapidly that upon alteration of the location and/or of the direction of view of the observer, the impression of continuous movement about the object arises.' These goals, the patent explains, are improvements over prior art systems like electronic maps stored on CD-ROMs, car navigation systems, or flight simulators. . . . As an ordered combination, this iterative process allows a user to access more electronic pictorial data in a more rapid fashion. The distributed data sources permit a user to access masses of data, while the recursive division step permits a user to access that data quickly, with increasing resolution over time. . . . The elements of the method described in the [patent] are not merely what a computer does; they are a specific procedure that is done by a computer. . . . Claim 1 recites a specific way of overcoming a problem which plagued prior art systems. This specific solution . . . demonstrates a sufficient inventive concept."

ART+COM Innovationpool GmbH v. Google Inc., 1-14-cv-00217 (DED April 28, 2016, Order) (Andrews, J.)