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Prism Technologies v. T-Mobile USA, Inc.

Representative Claim

  1. (‘345 Patent) A method for controlling access, by at least one authentication server, to protected computer resources provided via an Internet Protocol network, the method comprising: receiving, at the at least one authentication server from at least one access server, identity data associated with at least one client computer device, the identity data forwarded to the at least one access server from the at least one client computer device with a request from the at least one client computer device for the protected computer resources; authenticating, by the at least one authentication server, the identity data received from the at least one access server, the identity data being stored in the at least one authentication server; authorizing, by the at least one authentication server, the at least one client computer device to receive at least a portion of the protected computer resources requested by the at least one client computer device, based on data associated with the requested protected computer resources stored in at least one database associated with the at least one authentication server; and permitting access, by the at least one authentication server, to the at least the portion of the protected computer resources upon successfully authenticating the identity data and upon successfully authorizing the at least one client computer device.
  1. (‘155 Patent) A system for controlling access to protected computer resources provided via a network utilizing at least one Internet Protocol, the system comprising: at least one authentication server having an associated database to store (i) identity data associated with at least one client computer device, and (ii) data associated with said protected computer resources; at least one access server adapted to receive said identity data from said at least one client computer device;  said at least one access server adapted to forward said identity data received from said at least one client computer device to said at least one authentication server; said at least one authentication server adapted to authenticate said identity data responsive to a request for said protected computer resources by said at least one client computer device; said at least one authentication server adapted to authorize said at least one client computer device to receive at least a portion of said protected computer resources, based on said stored data associated with said protected computer resources; and said at least one authentication server adapted to permit access to said at least a portion of said protected computer resources upon successfully authenticating said identity data and upon successfully authorizing said at least once client computer device.

Posture:

Cross-motions for Summary Judgment.

Abstract Idea: Yes

“The Court finds that the claims are directed toward an abstract idea. By examining the words of the claims, it is apparent that the claims are directed to a providing restricted access to resources. In Jericho Systems Corp. v. Axiomatics, Inc., the district court found that a claim involving a user entering a request for access was an abstract idea. 2015 WL 2165931 (N.D. Tex. May 7, 2015). The court stated, “The abstract idea being that people who meet certain requirements are allowed to do certain things.” Id. at *4. The underlying ideas behind Prism’s claims are similar to abstract idea discussed in Jericho.”

Something More: Yes

“[T]he Court finds that asserted claims do include inventive concepts to ensure that patents in practice are more than just patents on restricting access to resources. Prism’s patents involve the implementation of the Internet. However, the patents in application do more than “broadly and generically claim ‘use of the Internet’ to perform an abstract business practice.” DDR Holdings, 773 F.3d at 1258. The claims modify the way the Internet functions to provide secure access over a protected computer resource. The problems addressed by Prism’s claims are ones that “arose uniquely in the context of the Internet, and the solution proposed was a specific method of solving that problem.” Id. at 1257. ”