Speed Track, Inc. v. Amazon.com, Inc. et al, 4-09-cv-04479 (CAND January 23, 2017, Order) (White, USDJ)
Wednesday, January 25, 2017
File Access Patent Not Ineligible Under 35 U.S.C. § 101
The court denied defendants' motion to dismiss on the ground that plaintiff’s computer file access patent encompassed unpatentable subject matter because the asserted claims were not directed toward an abstract idea. "[T]he claimed invention is not merely an abstract idea, but rather the [patent] claims an improved method for accessing files in a data storage system of a computer system. . . . [T]he claimed invention is directed at solving a challenge unresolved by the prior art in which a search in a hierarchical directory structure did not guarantee a result. The claimed invention addressed that concern with the mechanism of allowing the user to search only those terms that are actually contained in the file description, thereby eliminating the possibility that the user may mistype or misspell a search term. . . . The description of the invention and the claims created a technological solution to the problems that had existed with conventional file access methods. Because the Court finds that the patent claims are directed to a specific improvement to computer functionality, the claims are not directed to an ineligible abstract idea."