Prisua Engineering Corp. v. Samsung Electronics Co., Ltd. et al, 1-16-cv-21761 (FLSD March 9, 2017, Order) (Moore, USDJ)
Monday, March 13, 2017
Patent for Extracting and Embedding Digital Images Within a Video Not Invalid Under 35 U.S.C. § 101
The court denied defendant's motion to dismiss on the ground that plaintiff’s patent for extracting and embedding digital images within a video encompassed unpatentable subject matter because the asserted claims were not directed toward an abstract idea. "Users of the [accused] product are . . . able to select a portion of . . . captured images along with a portion of [an] original video data stream. The product’s digital processing unit then uses its memory and processing components to 'spatially match the second image (from the user input video data stream) to the first image (from the original video stream).' This process substitutes the first image with the second image—i.e., the 'user-selected "Best Face."' . . . [Plaintiff] alleges that the above violates [the patent-in-suit]. . . . [Defendant] seeks to oversimplify the [patent] in arguing that the 'Best Face' invention uses a generic computer function to perform an action that could be performed by a human by cutting-and-pasting. The Court declines to equate the 'Best Face' technology with 'arts and craft classes' or making collages. . . . [T]he [patent] describes more than just a 'generic computer performing a generic function.' To grant [defendant's] Motion to Dismiss on the basis of patent-ineligibility would run contrary to the warnings in [Alice Corp. v. CLS Bank Int’l, 134 S. Ct. 2347 (2014)] and [Mayo Collaborative Servs. v. Prometheus Laboratories, Inc., 132 S. Ct. 1289 (2012)] that courts not construe the categories of patent ineligible subject matter too broadly."