IOENGINE LLC v. Interactive Media Corp., 1-14-cv-01571 (DED January 4, 2017, Order) (Sleet, USDJ)
Friday, January 6, 2017
Tunneling Client Access Point Patent Not Invalid Under 35 U.S.C. § 101
The court denied defendants' motion for summary judgment of invalidity because defendant failed to show that plaintiff’s tunneling client access point patent was directed toward an abstract idea. "[Defendant] argues claim 1 of the [patent] is invalid under 35 U.S.C. § 101 because it is generally directed to the abstract idea of providing communication with computing devices. . . . The court disagrees with [defendant's] over-simplified characterization of the claims. . . . [T]he Independent Claims of the [patent] recite a specific arrangement of components and a very specific implementation and structure of the executable program code. Furthermore, the court disagrees with [defendant's] assertion that the [patent] has no 'particular concrete or tangible form'. . . . [T]he Independent Claims here define a tangible portable device with an unconventional hardware configuration that is able to run specific program code to provide the claimed functionality. More important, the court agrees, as [plaintiff] maintains, that the Independent Claims of the [patent] are directed to a 'specific asserted improvement in computer capabilities,' not to an abstract idea 'for which computers are invoked merely as a tool.'. . . As the specification delineates, the claims are directed to addressing a specific technological problem in then-existing computing environments: portable devices were 'bulky, provide[d] uncomfortably small user interfaces, and require[d] too much power to maintain their data.'"