Local Intelligence, LLC v. HTC America, Inc. et al, 5-17-cv-06437 (CAND April 6, 2018, Order) (Davila, USDJ)
Tuesday, April 10, 2018
Patent for Displaying Location-Relevant Communications On a Phone Not Invalid Under 35 U.S.C. § 101
The court denied defendant's motion to dismiss on the ground that plaintiff’s patent for displaying location-relevant communications on a phone encompassed unpatentable subject matter because the asserted claims were not directed toward an abstract idea. "[T]he claims of the Asserted Patents are best characterized as directed to: refreshing location-relevant communication services on a phone’s display by obtaining a current location from a location server, selecting communication services using logic in a datastore, and refreshing the display. . . . [T]he claims at issue do more than simply state a result (i.e., display communication services according to current location); they also recite the way in which it is accomplished (i.e., using location retrieved from the location server and functions stored in the datastore). Accordingly, because the specific improvement to the technology of user interfaces claimed in [Core Wireless Licensing S.A.R.L. v. LG Elecs., Inc., 880 F.3d 1356 (Fed. Cir. 2018)] was not an abstract idea, the Court must conclude that the similarly specific improvement to user interfaces claimed here is also not an abstract idea."