Zak v. Facebook, Inc., 4-15-cv-13437 (MIED September 12, 2016, Order) (Berg, USDJ)
Monday, September 19, 2016
Content Management Patents Not Ineligible Under 35 U.S.C. § 101
The court denied defendant's motion for summary judgment on the ground that plaintiff’s content management patents encompassed unpatentable subject matter because the asserted claims did not lack an inventive concept. "The claims of these patents are directed to enabling users, without third-party assistance, to post content to a website and to control which users can view the posted content. . . . [T]he [claim at issue] does not merely permit a known business practice to be performed on the Internet. Instead, the claim here specifies how a solution will be implemented that addresses a business challenge particular to the Internet. . . . [A]lthough the limitations to the claim in this case are not inventive alone, the ordered combination of these limitations is inventive because, taken together, the limitations are not routine and conventional. The claim does not simply dictate that communication must be targeted and access restricted. Instead, the claim states that users themselves will be able to control interactions on their web pages by managing business rules that will utilize profiles of other users to generate configurable links to determine how other users may interact with his or her web page. . . . Regardless of whether the subject matter of the patent is characterized as group collaboration with targeted communication or as restrictions on public access, the claim contains enough inventive elements to be aimed at more than a patent on the abstract idea itself."