Eyetalk365, LLC v. Zmodo Technology Corporation Limited, 2-17-cv-02714 (NVD February 14, 2018, Order) (Jones, USDJ)
Friday, February 16, 2018
Audio-Video Doorbell Patent Not Invalid Under 35 U.S.C. § 101
The court denied defendant's motion to dismiss on the ground that plaintiff’s audio-video doorbell patent encompassed unpatentable subject matter because the asserted claims were not directed toward an abstract idea. "[T]he Court has rejected arguments that a patent claim is abstract because its only concrete, physical component not relying on a computer’s generalized computing capabilities was well-known or long-practiced. . . . Detecting the presence of a person at a door, sending a video of the person to be viewed, and speaking with the person at the door are all concrete steps requiring more than the abstract thinking capabilities of a person or a computer. Regardless of anticipation or nonobviousness under §§ 102 and 103 -- neither of which is at issue in the present motion, and upon which the Court states no opinion -- Claim 1 is patent-eligible under § 101."