Personalized Media Communications LLC v. Apple Inc., 2-15-cv-01366 (TXED September 13, 2016, Order) (Payne, MJ)
Thursday, September 15, 2016
Signal Processing Patents Not Patent Ineligible Under 35 U.S.C. § 101
The magistrate judge recommended denying defendant's motion to dismiss on the ground that one of plaintiff’s signal processing patents encompassed unpatentable subject matter because the asserted claims were not directed toward an abstract idea. "[Defendant] states that claim 1 itself shows the claim is directed to the abstract idea of 'decrypting encrypted information' or 'converting information from one format to another.'. . . The Court finds the elements of claim 1 show that the claim is directed to a method of using a 'control signal' associated with 'digital programming' to 'decrypt programming' 'based on' the 'control signal.' The Court finds that claim 1 is not directed to 'converting information from one format to another.' . . . [T]he claim and the specification show that using a 'control signal' to control decryption improves the way in which 'encrypted digital programming' is delivered."