MAZ Encryption Technologies LLC v. Blackberry Corporation, 1-13-cv-00304 (DED September 29, 2016, Order) (Stark, USDJ)
Monday, October 3, 2016
Electronic Document Encryption Patent Not Ineligible Under 35 U.S.C. § 101
The court denied defendant's motion for judgment on the pleadings on the ground that plaintiff’s electronic document encryption patent encompassed unpatentable subject matter because the asserted claims were not directed toward an abstract idea. "The patent's specification describes problems associated with 'typical' prior art encryption systems, such as incompatibility with EDMS systems and general difficulty of use. The [patent] purports to solve these problems using a method that the PTO determined was non-obvious over references considered during the ex parte reexamination of the patent. . . . Defendant's broad articulations of abstract ideas do not capture what claim 31 is 'directed to' because they do not take into account the two separate tables used to distinguish claim 31 over the prior art. Although not every difference between a purported invention and the prior art is necessarily relevant under a § 101 analysis, here it is plain from the reexamination prosecution history (with support in the specification) that the two-table limitations added during reexamination are sufficiently important that they must be included in any accurate description of the nature of claim 31 as a whole. . . . Moreover, encryption is a relatively sophisticated, computer-implemented method of protecting data, unlike the simple, human-executable method described in Defendant's analogy."