Visual Interactive Phone Concepts, Inc. v. United States Cellular Corporation, 1-11-cv-05289 (ILND November 15, 2016, Order) (Hart, USDJ)
Thursday, November 17, 2016
Videophone Mailbox Patent Invalid Under 35 U.S.C. § 101
The court granted defendant's motion for judgment on the pleadings because the asserted claims of plaintiff’s videophone mailbox patent encompassed unpatentable subject matter and found that the claims were directed toward an abstract idea. "The [patent-in-suit] has two main components: a user station having a videophone and an electronically connected central data center. The videophone is an integrated device that includes a telephone, general purpose computer, a video screen, a memory chip, an interface chip, encoders, and means for inputting transaction information. . . . The broad general definition of a 'videophone' in the patent and the prior art indicates that the thrust of the patent is the interactive mailbox facility system, not the videophone itself. . . . Plaintiff argues that the inclusion of tangible components, alone, saves the patent from being abstract. The Federal Circuit has found, however, a number of claims involving tangible components to be abstract. . . . A comparison of the [patent] claims with prior art reveals that the claims focus on the functionality of conducting a transaction and disclose no more than the abstract idea of conducting transactions using conventional computer components, a telephone and centralized data storage."