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SimpleAir, Inc., v. Google Inc., et al.

Representative Claim

Claim 1 of the ’279 Patent recites:

  1. A system to transmit data from an information source to remote computing devices, the system comprising:

a central broadcast server configured to receive data from at least one information source and process the received data with at least one parser;

an information gateway communicatively coupled to the central broadcast server, the information gateway configured to build data blocks from the parsed data and assign addresses to the data blocks;

a transmission gateway communicatively coupled to one or both of the central broadcast server and the information gateway, the transmission gateway configured to prepare the addressed data blocks for transmission to receivers communicatively coupled to the remote computing devices and initiate transmission of the addressed data blocks to the receivers, wherein the transmission is made whether the remote computing devices are online or offline from a data channel associated with each remote computing device.

Claim 35 of the ’279 Patent recites:

  1. A system to transmit data from an information source to remote computing devices, the system comprising:

a central broadcast server configured to receive data from at least one information source and process the received data with at least one parser;

an information gateway communicatively coupled to the central broadcast server, the information gateway configured to build data blocks from the parsed data and assign addresses to the data blocks;

*2 a transmission gateway communicatively coupled to one or both of the central broadcast server and the information gateway, the transmission gateway configured to prepare the addressed data blocks for transmission to receivers communicatively coupled with the remote computing devices and cause the addressed data blocks to be transmitted to the receivers;

a plurality of remote computing devices configured to receive the addressed data blocks transmitted from the transmission gateway utilizing the receivers, wherein the remote computing devices are capable of being notified of the receipt of the transmitted data blocks by the receivers whether the remote computing devices are online or offline from a data channel associated with each remote computing device.

Claim 1 of the ’154 Patent recites:

  1. A method to transmit data from an information source via a central broadcast server to remote computing devices, the method comprising:

(a) generating data at the information source, wherein the information source is associated with an online service relating to the generated data;

(b) identifying one or more users that have subscribed to receive a notification relating to the generated data;

(c) transmitting the generated data to a central broadcast server configured to process the generated data using at least one parser and transmit the processed data to receivers communicatively coupled with remote computing devices associated with subscribed users, wherein the central broadcast server:

(i) comprises one or more servers associated with a parser to parse the generated data received from the information source;

(ii) is communicatively coupled to at least one information gateway, the information gateway configured to build data blocks from the parsed data and assign addresses to the data blocks; and

(iii) is communicatively coupled to at least one transmission gateway, the transmission gateway configured to prepare the addressed data blocks for transmission to the receivers and configured to cause the addressed data blocks to be transmitted to the receivers, and wherein the transmission is made whether the remote computing devices are online or offline from a data channel associated with the remote computing devices.

Posture:

Motion for Summary Judgment under 35 U.S.C. § 101.

Abstract Idea: No

[T]he Court finds that the Patents–in–Suit are not directed toward an abstract idea, because they are directed toward patent-eligible methods and systems of “using a central broadcast server” to package and transmit “data from an online information source to remote computing devices.” See (Resp. at 6.) Though Defendants argue that the Patents–in–Suit are directed to the abstract idea of “packaging and transmitting information,” Defendants do not explain how such a characterization, which ignores significant claim limitations, encompasses the invention claimed by the Patents–in–Suit. See (Mot. at 5–7.) Such conclusory argument, without more, is not enough for Defendants to meet their burden of establishing that the Patents–in–Suit are directed to an abstract idea.

Something More: N/A

Even assuming that the Court found that the patents are directed toward the abstract idea . . . the Court finds that the claim limitations are sufficient to ensure that the Patents–in–Suit amount to significantly more than a patent on that abstract idea. See Alice, 134 S.Ct. at 2355. . . . At the very least, the Patents–in–Suit disclose particular solutions for the problem of the “[l]ack of notification of information delivery when offline” 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. See Internet Patents Corp. v. Active Network, Inc., No.2014–1048, 2015 WL 3852975, at *6 (Fed. Cir. June 23, 2015); see (Resp. at 9.)