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Intellectual Ventures I LLC et al v. Capital One Financial Corporation et al.

Representative Claim

‘081 Patent:

  1. 21. An apparatus for manipulating XML documents, comprising:

a processor;

a component that organizes data components of one or more XML documents into data objects;

a component that identifies a plurality of primary record types for the XML documents;

a component that maps the data components of each data object to one of the plurality of primary record types;

a component that organizes the instances of the plurality of primary record types into a hierarchy to form a management record type;

a component that defines a dynamic document for display of an instance of a management record type through a user interface; and

a component that detects modification of the data in the dynamic document via the user interface, and in response thereto modifies a data component in an XML document.

002 Patent:

  1. A method for retrieving user specific resources and information stored either on a local device or a network server, the method comprising the steps of:

retrieving a mobile interface from the network server to the local device;

displaying the mobile interface on the local device, the mobile interface including a plurality of pointers corresponding to the user specific resources and information; and

retrieving the user specific resources and information using the plurality of pointers displayed on the mobile interface.

Posture:

Recommendation by Special Master re summary judgment on patent eligibility.

Abstract Idea: No

‘081 Patent:

“[T]he Special Master agrees with plaintiffs that the claimed invention is not an abstract idea. Capital One’s characterization of the claims as merely representing something as generic and broad as “data storage” and its analogy of the patent to activities performed by a “human translator” or something that can be achieved through use of a pen and paper, is excessively detached from the specificity and plain language of the claimed invention, and the overall intrinsic evidence pertaining to the patent.”

“The claims at issue in those cases heavily relied on by Capital One [Alice, Content Extraction, Digitech, Cyber Corp and Cyberfone] have a substantially different character than the disclosed and claimed invention of the ’081 Patent. The ’081 Patent, including its claims, is directed to an apparatus utilizing a specific method for dynamically retrieving, manipulating, updating, creating, and displaying data from different types of XML documents – documents that contain a very specialized, computer language and can differ significantly from business to business in terms of formats and syntax.”

002 Patent:

“[T]he Special Master agrees with the Plaintiffs that Capital One’s characterization of the idea embodied by the ’002 patent misconstrues the claims. In particular, it ignores the claims’ use of the “mobile interface” as a key and integral aspect of the claimed invention, as well as the other verbiage in the claims. See supra at 26-29. Also, the plain language of the claims features the mobile interface; it is an important and integral subject in Claims 1, 9, 11, 34 and 37, and is mentioned four times in Claim 1, two times in Claim 9, four times in Claim 11, three times in Claim 34, and once in Claim 37. Additionally, Claim 1, which is incorporated by reference in asserted claim 9, highlights a method whereby a mobile interface is retrieved to the local device from a network server and mediates the user selections and information retrieval process.”

Something More: Yes

‘081 Patent:

“Again, here, the Special Master is persuaded by Plaintiffs’ argument, as Capital One does not properly focus on all of the language of the claims and the actual invention described in the patent. We agree with the Federal Circuit that it is sometimes difficult to discern when the limitations add “significantly more” to the claims, DDR, 773 F.3d at 1255, as is evidenced by the plethora of decisions that have been rendered post-Alice. But this is not one of those circumstances.”

“Here, the claimed invention of the ’081 Patent clearly identifies and solves a unique problem in computer technology presented by the many different XML documents in use across many different businesses enabling a business user to transcend them.”

002 Patent:

“The Special Master further finds that the claimed invention of the ’002 Patent clearly identifies and solves problems unique to the computer networks field involving access to multiple types of information, documentation, programs and links from multiple locations and devices.”

“The patent itself explains the significant and specific concepts underlying the invention – and the mobile interface and the methods using that interface are central to the invention and are the “new and useful” (35 U.S.C. § 101) transformative aspects to any generic pointer system. Not only does the ruling squarely fit within the language of the Federal Circuit in DDR, 773 F.3d at 1257, i.e., that “the claimed solution is necessarily rooted in computer technology in order to overcome a problem specifically arising in the realm of computer networks,” it is consistent with the underlying purpose of our patent laws.”