Broadcom Corporation et al v. Sony Corporation et al, 8-16-cv-01052 (CACD October 5, 2016, Order) (Selna, USDJ)
Friday, October 7, 2016
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."