Patents for Generating Screen Displays for Interactive Applications Not Invalid Under 35 U.S.C. § 101

The court denied defendant's renewed motion for judgment on the pleadings on the ground that plaintiff’s patents for generating screen displays for interactive applications encompassed unpatentable subject matter because the asserted claims were not directed toward an abstract idea. "The claims of the [patents] are directed to a specific computer functionality improvement -- improving the capabilities of networks hosts and computer networks -- and are patent-eligible under step 1. . . . This method allows the computer to function more quickly by speeding the data storage process and reducing memory requirements, allowing the computer to serve more users. . . . [T]he claims of the [patents] are not directed to local data storage generally, but recite specific features for improving computer functionality by generating screen displays and partitions by breaking the data content of applications or advertisements into objects, storing them locally, and selectively retrieving them when needed. This method reduces the processing demand on the host system, allowing the host to function more efficiently."

International Business Machines Corporation v. Groupon, Inc., 1-16-cv-00122 (DED November 17, 2017, Order) (Stark, USDJ)