D&M Holdings, Inc., et al. v. Sonos, Inc., 1-16-cv-00141 (DED February 16, 2018, Order) (Andrews, USDJ)
Wednesday, February 21, 2018
Audio/Visual Playback Patent Invalid Under 35 USC § 101
The court granted defendant's motion for summary judgment because the asserted claims of plaintiffs’ audio/visual playback patent encompassed unpatentable subject matter and found that the claims were directed toward an abstract idea. "I agree with Defendant that this claim is, at most, directed to the automation of a process that can be (and has been) performed by humans. . . . Claim 1 includes the additional element of reproducing the recorded signal with either the previously stored or default preferences, but that element is similarly abstract, as it, too, is at most directed to the automation of a process that can be performed by humans. Claim 1 is thus directed to the abstract idea of choosing to play back media with or without playback preferences. It is not directed to an invention that improves this process."