MPEG Decoder Patents Not Ineligible Under 35 U.S.C. § 101​

The court denied defendant's motion to dismiss on the ground that plaintiff’s MPEG decoder system patents encompassed unpatentable subject matter because the asserted claims did not lack an inventive concept. "[Defendant] argued that the Court could only consider the language of the claims when determining whether the claims contained an inventive concept. However . . . this Court can rely on 'the claims or the specification' to determine whether a combination of abstract ideas forms an inventive concept. . . . Here, the Court finds that [the claims] attempt to improve a technological issue. . . . As described in each specification, unary binarization can create codewords that are very long. In addition, a disadvantage of binary binarization is that the codewords become indistinguishable. . . . Unlike in [Alice Corp. Pty. Ltd. v. CLS Bank Int’l, 134 S. Ct. 2347 (2014)], the claims do not simply use general computers to perform abstract ideas; instead, the mathematical formula attempts to improve the functioning of compressing and decompressing video, images, and signals."

Broadcom Corporation et al v. Sony Corporation et al, 8-16-cv-01052 (CACD October 5, 2016, Order) (Selna, USDJ)