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Content Guard Holdings, Inc. v. Google, Inc.

Representative Claim

  1. A computer-implemented method of distributing digital content to at least one recipient computing device to be rendered by the at least one recipient computing device in accordance with usage rights information, the method comprising: determining, by at least one sending computing device, if the at least one recipient computing device is trusted to receive the digital content from the at least one sending computing device; sending the digital content, by the at least one sending computing device, to the at least one recipient computing device only if the at least one recipient computing device has been determined to be trusted to receive the digital content from the at least one sending computing device; and sending usage rights information indicating how the digital content may be rendered by the at least one recipient computing device, the usage rights information being enforceable by the at least on recipient computing device.

Posture:

Motion for judgment on the pleadings.

Abstract Idea: No

“[T]he Court finds that the Patents-in-Suit are directed toward patent-eligible subject matter. In particular, the Patents-in-Suit are not directed toward an abstract idea, at least because they are directed toward patent eligible methods and systems of managing digital rights using specific and non-generic ‘trusted’ devices and systems. See, e.g., (Response at 13 (‘This is significant because it underscores that the subject matter of the Trusted Repository Patents is narrow, i.e., limited to devices that maintain physical, communications, and behavioral integrity, rather than all devices that are capable to receive content via the Internet.’))”

Something More: Yes/No

“Further, even arguendo, if the Court found that the patents are simply directed toward the ‘abstract idea . . . the claim limitations, individually and “as an ordered combination,” are sufficient to ensure that the Patents-in-Suit amount to ‘significantly more’ than a patent simply on that abstract idea. See Alice, 134 S. Ct. at 2355. For example, the claims require that the ‘repository’ be a ‘trusted system’ which the Court construed as ‘maintain[ing] physical, communications, and behavioral integrity in the support of usage rights,’ in order to manage digital rights. At the very least, the Patents-in-Suit disclose particular solutions for the problem of ‘enforcing usage rights and restrictions on digital content’ that ‘(1) [do] not foreclose other ways of solving the problem, and (2) recite[] a specific series of steps that result[] in a departure from the routine and conventional’ way of managing digital rights. Internet Patents Corp. v. Active Network, Inc., No. 2014-1048, 2015 WL 3852975, at *6 (Fed. Cir. June 23, 2015).”