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Maxus Strategic Systems, Inc. v. Aqumin, LLC

Representative Claim

  1. (‘115 Patent) A virtual reality generator to display abstract information as a multi-dimensional information terrain, the virtual reality generator comprising:

an input module receiving the abstract information from an information source, the information source generating the information as a function of a predetermined analysis of real-time and pre-stored data;

a user interface module including a first input selecting a categorical dimension for each of a first dimension of a multi-dimensional information terrain and a second dimension of the multi-dimensional information terrain and a second input for selecting a numerical dimension for a third dimension of the multi-dimensional information terrain, the user interface module selecting a portion of the abstract information as a function of the categorical dimensions and the numerical dimension; and

a virtual reality generator module coupled to the input module and the user interface module, the virtual reality generator generating, continuously modifying and displaying on a display device a multi-dimensional information terrain that enables a user to simulate movement through and interact with the abstract information, the information terrain representing selected portions of the information,

wherein when the user simulates movement through and interacts with the abstract information, the user viewing the display device has a sensation of traveling through and within the information terrain.

Posture:

Motion for summary judgment.

Abstract Idea: No

The Supreme Court has stressed the need to “tread carefully in construing this exclusionary principle lest it swallow all of patent law. At some level, all inventions embody, use, reflect, rest upon, or apply laws of nature, natural phenomena, or abstract ideas. Thus, an invention is not rendered ineligible for patent simply because it involves an abstract concept.” Alice Corp. Ply. Ltd. v. CLS Bank, Int’l, 134 S. Ct. 2347, 2354 (2014) (internal citations omitted).

The Court agreed with the Plaintiff’s statement that:

[T]he inventions as claimed in the patents-in-suit describe a system to manage, display, and analyze large volumes of complex data through the unique use of computers, the Internet, and virtual reality software as described in the patents-in-suit. Maxus contends that the use of the phrase “abstract information” throughout the patents-in-suit refers to the massive volume of financial data that Maxus inventions manage through the use of preexisting technologies in unique ways described by the patents-in-suit that have never been accomplished before the Maxus inventions.

The Court ended the order by quoting from DDR Holdings:

On a fundamental level, the creation of new compositions and products based on combining elements from different sources has long been a basis for patentable inventions. See, e.g., Parks v. Booth, 102 U.S. 96, 102 (“Modern inventions very often consist merely of a new combination of old elements or devices, where nothing is or can be claimed except the new combination.”); KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 418-19 (“[I]nventions in most, if not all, instances rely upon building blocks long since uncovered, and claimed discoveries almost of necessity will be combinations of what, in some sense, is already known.”). DDR Holdings, LLCv. Hotels.com, L.P., 773 F.3d 1245, 1258, n.5 (Fed. Cir. 2014).