Youtoo Technologies LLC v. Twitter Inc., 3-16-cv-00764 (TXND November 10, 2016, Order) (Godbey, USDJ)
Tuesday, November 15, 2016
Video Content Distribution Patents Invalid Under 35 U.S.C. § 101
The court granted defendant's motion to dismiss because the asserted claims of plaintiff’s video content distribution patents encompassed unpatentable subject matter and found that the claims were directed toward an abstract idea. "[Plaintiff] argues that, like [Enfish, LLC v. Microsoft Corp., 822 F.3d 1327 (Fed. Cir. 2016)], the claims improve computer functionality. But that is not the case. Here, claim one of both the patents covers a method of receiving video data, limited to a certain length and frame rate, from a camera, operated by a user, transcoding the video data, and transferring the video data for distribution. In short the claims each cover the process of automatically transcoding user recorded video files to a predetermined format that is suitable for a television broadcast or publication on the internet. The Federal Circuit has repeatedly found similar claims directed toward gathering, processing, and outputting information are abstract. . . . [T]hese claims do not improve the functioning of the computer itself, they facilitate uploading video into a certain format, a process that was previously possible without the patents at issue. Thus the claims merely facilitate uploading video."