Network Information Management Patent Invalid Under 35 U.S.C. § 101

The court granted defendants' motion to dismiss because the asserted claims of plaintiff’s network information management patent encompassed unpatentable subject matter and found that the claims were directed toward an abstract idea. "Plaintiff responds that the [patent-in-suit] . . . is directed to specific improvements in the functioning of computers. . . . [T]he claims . . . are directed to the abstract idea of using information stored in one place to determine the location of and retrieve information stored in a second place, i.e., a form of 'information management.'. . . [T]he Court agrees with Defendants that the concept of using a 'pointer' found in one place to locate and retrieve information found in a separate place is indistinguishable from the idea of using an information desk, a catalogue, or the Dewey Decimal System to locate a desired library book, either within the same library or in a separate library using, say, an interlibrary loan. . . . [T]he claims . . . do not purport to alter the structure or function of the physical object, the computer, or indeed any part of the network of computers."

Activision Publishing, Inc. v. xTV Networks, Ltd. et al, 2-16-cv-00737 (CACD July 25, 2016, Order) (Otero, J.)