Asghari-Kamrani et al v. United Services Automobile Association, 2-15-cv-00478 (VAED July 5, 2016, Order) (Doumar, J.)
Thursday, July 7, 2016
User Authentication Patent Invalid Under 35 U.S.C. § 101
The court granted defendant's motion to dismiss because the asserted claims of plaintiffs’ user authentication patent encompassed unpatentable subject matter and found that the claims were directed toward an abstract idea. "[D]espite the electronic setting and purportedly Internet specific problem addressed, the patent claims are directed to a common method for solving an old problem. The claims are directed to the abstract idea of using a third party and a random, time-sensitive code to confirm the identity of a participant to a transaction. . . . Certainly it is true that the problem of authenticating parties to a transaction has been magnified by computer and network technology. Through computer networks many individuals may conduct business over long distances in an instance. However, just because a problem has been magnified by computer and network technology does not make the problem unique to this environment. . . . It is true, as Plaintiffs argue, that there are advantages to performing the claimed method on computers. However, these advantages do not transform the method into one directed to an improvement of computer technology."