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A PTY LTD. v. eBay, Inc.

Representative Claim

  1. A method of conveying an email message including an address field containing a descriptor of an intended recipient of the email message, the descriptor being different from an email account name of the intended recipient, the method comprising:sending a database query to a database containing a plurality of identifying elements associated with the intended recipient and email addresses to search for the email address associated with the descriptor, wherein said descriptor comprises at least one of the identifying elements; and
    transmitting said email message to said email address found during said search of the email addresses if a unique email address is located.

Posture:

Rule 12(c) motion for Judgment on the Pleadings.

Abstract Idea: Yes

The Court is well aware that in many cases it is difficult to distinguish between an abstract idea and its application. However, in light of the agreed claim construction, the Court concludes that the claims of the ‘572 Patent are more similar to the ideas that have been found to be abstract in other cases before the Supreme Court and the Federal Circuit, such as Alice and Ultramercial, involving methods of organizing business activity. The Court thus finds that the ‘572 Patent is most accurately characterized as directed to the abstract idea of an address directory.

Something More: No

Plaintiffs contend that the ‘572 Patent is analogous to the patents at issue in DataTern and DDR Holdings because it overcomes a problem specifically arising in the realm of computer networks. The Court disagrees. The claims of the ‘572 Patent do not overcome a problem specifically arising in the realm of computer networks. Rather, those claims address a long-standing problem (i.e. finding the correct destination address in order to make a message or package deliverable) in a computer setting. The Supreme Court has made clear that simply implementing a long standing practice on a computer is not enough for patentability. See Alice, 134 S. Ct. at 2358 (“limiting the use of an abstract idea to a particular technological environment is not enough for patent eligibility.”). Accordingly, the Court finds that the claims of the ‘572 Patent do not have sufficient “additional features” beyond the abstract idea of an address directory to transform the claims into patent eligible subject matter. Ultramercial, 772 F.3d at 715 (quoting Mayo, 132 S. Ct. at 1298).