Personalized Media Communications, LLC v. Funai Electric Co., Ltd., 2-16-cv-00105 (TXED February 22, 2017, Order) (Payne, MJ)
Friday, February 24, 2017
PMC Signal Processing Patents Not Ineligible Under 35 U.S.C. § 101
The magistrate judge recommended denying defendant's motion to dismiss on the ground that plaintiff’s signal processing patents encompassed unpatentable subject matter because the asserted claims were not directed toward an abstract idea. "[Defendant] argues that the asserted claims of the [first] Patent are 'simply directed to a generic way of communicating information to determine which television program to display.' The Court disagrees. The [first patent's] claims are directed to overcoming problems specific to the distribution of streaming digital television programming and other digital content over computer networks. . . . [T]he claims of the [second] patent are directed at a receiver station that receives and processes signals. The particularized elements of those claims are similar to the claim elements in [Enfish, LLC v. Microsoft Corp., 822 F.3d 1327 (Fed. Cir. 2016)]. . . . [T]he [third patent's] claims address a specific technological problem rooted in signal transmission and processing. . . . Similarly, the [fourth patent's] claims are directed to a process of matching a 'signal processing scheme' to the variable format of a received digital signal to output television programming. Finally, the Court finds that the [fifth patent's] claims are directed to a method of handling information transmissions whose variable-length data must first be decoded before the data can be used to create video images. . . . The asserted claims recite patentable subject matter as defined by precedent interpreting § 101."