TriDim Innovations LLC v. Amazon.com, Inc., 3-15-cv-05477 (CAND September 19, 2016, Order) (Donato, USDJ)
Wednesday, September 21, 2016
3-D Workspace Patents Ineligible Under 35 U.S.C. § 101
The court granted defendant's motion to dismiss because the asserted claims of plaintiff’s 3-D workspace patents encompassed unpatentable subject matter and found that the claims lacked an inventive concept. "[N]either the problem [plaintiff's] patents purportedly solve (limited screen space for the display and organization of documents) nor the suggested solution (arranging documents by frequency of use) is 'necessarily rooted in computer technology.' To the contrary, storing documents that are less frequently used in a library or on a bookshelf as opposed to on one’s desk is a common solution to a common problem of limited space in physical offices everywhere. . . . The elements of the claims that relate to the means of moving and positioning the document objects suffer from the same lack of inventive concept. According to [plaintiff], the 'touch and drop' and 'flicking' gestures were 'improvements specifically adapted for a 3-D space' because 'known techniques for operating a 2-D workspace such as drag and drop techniques were not efficient.' But the patents do not disclose any specific ways, hardware or software, that a user may program or implement these gestures. . . . An additional problem for [plaintiff] is that the patents and claims here, which are defined in terms of their functionalities only, raise a serious preemption concern."