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YYZ LLC v. Hewlett Packard Company

Representative Claim

  1. A computerized method for use in an asynchronous messaging environment, wherein said messaging environment comprises at least one original message comprised of original message data, comprising:

providing, through a monitoring message, at least part of said original message data to a central message repository;

populating a transaction record in said central message repository with said original message data provided by said monitoring message;

wherein said original message data comprises the status of an activity.

Posture:

Summary Judgment.

Abstract Idea: Yes

The Court found that representative claim 1 of the ’749 Patent is directed to the abstract idea of collecting and saving information relating to a business process.  Despite the patent owner’s attempt to characterize the claim as involving “solutions to problems that existed in very specific technological environments” (the DDR approach), the Court described the claimed subject matter as merely a method for collecting a copy of information related to a business process consisting of two steps: “(1) sending a copy of information relating to the status of a business activity to a central repository; and (2) storing the copied information in a record in the central repository.”  These steps can be performed without the use of a computer (i.e., organizing human activity), and therefore the Court concluded that the claim is directed to an abstract idea.

Something More: No

Patent owner’s attempt at narrowing the technological field to avoid total preemption of the abstract idea was insufficient to prevail on the second prong of the Alice analysis:

“In terms of reviewing the merits of the competing arguments, the court finds that “the asserted claims of the patents-in-suit operate in an asynchronous message-based communications environment and fix problems only existing in asynchronous environments.” Just narrowing an abstract idea “to a particular technological environment” is insufficient to pass muster under the § 101 paradigm.”

Patent owner also failed to persuade the court the claims were directed to a technological improvement innovative enough to override the routine and conventional use of a computer.  Importantly, the Court noted that the features argued by patent owner as providing the alleged technological improvement were not specifically recited in the claim, and further noted it is not sufficient to broadly recite overly broad language that applies the alleged technical improvement.

To broadly claim a method of accomplishing routine functions requires more than just an “apply it” directive, even in a specific technical environment such as the one at bar. A component that “can be configured” to perform the claimed function is neither sufficiently described nor sufficiently innovative to transform the inventive concept at bar into patent-eligible subject matter. See, e.g., Planet Bingo, LLC v. VKGS LLC, 576 F. App’x 1005, 1008-09 (Fed. Cir. 2014) (rejecting argument that unclaimed features and “complex computer code” are relevant for patent-eligibility purposes). Plaintiff has not raised triable issues of fact sufficient to withstand summary judgment.