Tridia Corporation vs. Sauce Labs, Inc., 1-15-cv-02284 (GAND July 13, 2016, Order) (Long, Special Master)
Friday, July 15, 2016
Patent for Remotely Accessing and Controlling an Application Over a Network Invalid Under 35 U.S.C. § 101
The special master recommended granting defendants' motions to dismiss because the asserted claims of plaintiff’s patent for remotely accessing and controlling an application over a network encompassed unpatentable subject matter and found that the claims lacked an inventive concept. "The invention relates to remote execution of computer programs over a network . . . without requiring pre-installation of the remote control program on the user’s computer. . . . The claim recites a first computer and a second computer. Such generic computers are insufficient to transform the claim into patent eligible subject matter. The claim further recites that the . . . 'remote control module' is transmitted from one computer system to another. Transmitting digitally coded information, of any type, over a network from one computer system to another could hardly be considered anything other than routine at the time of the invention. . . . Plaintiff characterizes the Internet in 1995 as being in its 'infancy', and argues that at the time of the invention these limitations were not 'conventional.' Infancy or not, the specification makes clear that the Internet and related network technology, including the use of modules capable of being interpreted by a browser and that did not require installation, were all well-known within the industry. . . . [W]hether or not the technology was fairly characterized as 'new,' it was sufficiently known to qualify as 'conventional' under the second step of [Alice Corp. Pty. Ltd. v. CLS Bank Int’l, 134 S. Ct. 2347 (2014)]."