Multimedia Messaging Patents Invalid Under 35 U.S.C. § 101​

The court granted defendants' motion to dismiss because the asserted claims of plaintiff’s multimedia messaging patents encompassed unpatentable subject matter and found that the asserted claims were directed toward an abstract idea. "Defendants argue that claim 17 covers an abstract idea because it addresses the problem of 'incompatability in communication.' In Defendants' view, such a problem 'has existed ever since human languages diverged' and claim [plaintiff's] solution 'is equally ancient' because it involves 'conversion to and from a common format.' The Court agrees. . . . [Plaintiff] counters that claim 17 is not directed to an abstract idea because it is 'limited to the transmission of multimedia messages in a multi-carrier environment.' But claims that 'limit [an] abstract idea to a particular environment' are 'no less abstract for the step 1 analysis.'"

Intellectual Ventures I LLC v. T-Mobile USA, Inc. et al, 1-13-cv-01632 (DED August 23, 2017, Order) (Stark, USDJ)