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Cloud Satchel, LLC v. Amazon.com, Inc., et al

Representative Claim

  1. A distributed system for accessing and distributing electronic documents using electronic document references, the distributed system comprising:a) a database of electronic documents and electronic document references stored in a first memory having a first capacity, each electronic document having an associated document reference identifying a location of the electronic document in the first memory, each electronic document having a first memory requirement for storage greater than a second memory requirement for storage of the associated electronic document reference;b) a distributed document handling subsystem coupled to the database, the document handling subsystem including a transceiver for transmitting an electronic document reference without its associated electronic document at a first location and receiving the electronic document reference without its associated electronic document at a second location, the distributed document handling subsystem responding to receipt of the electronic document reference by producing a copy of the associated electronic document at a third location;c) a portable electronic document reference transport device for transporting the electronic document reference without its associated electronic document, the portable electronic document reference transport device being physically separate from the first memory and the distributed document handling subsystem, the portable electronic document reference transport device including a second memory for storing the electronic document reference without its associated electronic document, the second memory having a capacity significantly less than the capacity of the first memory, the portable electronic document reference transport device including a transceiver for receiving the electronic document reference without its associated electronic document at the first location and transmitting the electronic document reference without its associated electronic document at the second location.

Posture:

Motion for Summary Judgment.

Abstract Idea: Yes

Here, the parties agree that the claims facilitate the “identification and retrieval of documents from storage.” Representative claim 1 of the ′321 patent, at its core, describes the implementation of the abstract idea of cataloguing documents to facilitate their retrieval from storage in the field of remote computing. . . . Plaintiffs arguments that the claims recite inventive applications of the abstract concept of “storage and retrieval of electronic documents” and that the claims name specific devices are factors more appropriately considered in step two of the Alice framework.

Something More: No

Although the court understands plaintiff’s argument that the steps of “transmitting” and “receiving” may not have been conventional practices in the field of computing a the time of invention, these steps nonetheless do nothing more than recite functions that “can be achieved by any general purpose computer without special programming.” . . . The court also recognizes that the application of document cataloguing in the realm of portable computing usefully addressed the problem of limited memory space in portable computers. The fact that an abstract idea may be usefully applied, however, is not enough to “transform an unpatentable principle into a patentable process.” . . . Plaintiffs argument that the claims “improve the functioning of the computer” also falls short, as the patents do not claim an improvement to the computer, but rather describe how to apply the abstract idea of cataloguing to pre-existing, conventional computers.