Papst Licensing GmbH & Co. KG v. Xilinx Inc., 5-16-cv-00925 (CAND June 9, 2016, Order) (Koh, J.)
Monday, June 13, 2016
Computer Memory Testing Patents 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 computer memory testing patents encompassed unpatentable subject matter and found that the claims were directed toward an abstract idea. "[E]ach of the asserted claims, at its heart, is directed to the use of a simulator to determine whether a memory test violates a set of rules. . . . Although Plaintiff contends that 'the [a]sserted [c]laims improve the functioning of the computer itself,' that conclusion does not follow from the specification of the [patents] or the asserted claims. The [patents] are directed to methods of verifying and optimizing memory tests, not to improving the computer or software components used to carry out those methods. . . . [T]he primary improvement cited by Plaintiff — the efficient generation of memory tests for modern, complex memory devices — is not reflected in the limitations of the asserted claims. . . . [T]he asserted claims’ reflection of generic, and conventional, computerization of processes previously performed by humans without computers confirms the Court’s conclusion that the asserted claims are directed to patent-ineligible abstract ideas."