Sound View Innovations, LLC v. Facebook, Inc., 1-16-cv-00116 (DED August 30, 2016, Order) (Andrews, USDJ)
Thursday, September 1, 2016
Asserted Claims of Electronic Information Management Patent Invalid Under 35 U.S.C. § 101
The court granted defendant's motion to dismiss because the asserted claims of plaintiff’s electronic information management patent encompassed unpatentable subject matter and found that the claims were directed toward an abstract idea. "[Defendant] argues that the asserted claims of the [patent-in-suit] 'are directed to the abstract idea of managing information and preferences among members of a community.' . . . [Plaintiff] argues that . . . the claims are not directed to an abstract idea because the 'the plain focus of the claims is on an improvement to computer functionality itself.'. . . [T]he invention of the [patent] seeks to make a non-technological improvement to the non-technological problem of providing a user with information that is better suited to the user. The asserted claims of the [patent] thus are directed to the concept of offering more meaningful information to an individual based on his own preferences and the preferences of a group of people with whom he is in pre-defined relationships. The claimed concept is abstract."