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Affinity Labs of Texas v. Amazon

Representative Claim

14. A media system, comprising:

a network based media managing system that maintains a library of content that a given user has a right to access and a customized user interface page for the given user;

a collection of instructions stored in a nontransitory storage medium and configured for execution by a processor of a handheld wireless device, the collection of instructions operable when executed: (1) to initiate presentation of a graphical user interface for the network based media managing system; (2) to facilitate a user selection of content included in the library; and (3) to send a request for a streaming delivery of the content; and

a network based delivery resource maintaining a list of network locations for at least a portion of the content, the network based delivery resource configured to respond to the request by retrieving the portion from an appropriate network location and streaming a representation of the portion to the handheld wireless device.

Posture:

Appeal from the United States District Court for the Western District of Texas in No. 6:15-cv-00029-WSS, Judge Walter S. Smith, Jr.

Abstract Idea: Yes

The Federal Circuit agreed with the district court’s Step One determination, stating:

“The term ‘customized user interface,’ as used in the ’085 patent, is not limited to any particular form of customization, but covers the general idea of customizing a user interface. Like the basic concept of tailoring content to a user, as in Intellectual Ventures I, the basic concept of customizing a user interface is an abstract idea.”

In justifying its conclusion, the opinion addresses the claims’ recitation of certain physical components by noting that, like TLI Communications and Ultramercial, “the [’085 patent’s] specification [makes] clear that the recited physical components merely provide a generic environment in which to carry out the abstract idea of classifying and storing digital images in an organized manner.”  The opinion also reasons that “[t]he purely functional nature of the claim confirms that it is directed to an abstract idea, not to a concrete embodiment of that idea.”

Something More: No

The Federal Circuit also agreed with the district court’s Step Two determination, stating:

“The only putatively narrowing limitation in that result-focused claim is the limitation requiring that the ‘network based media managing system’ have ‘a customized user interface page for the given user.’ But neither the claim nor the specification reveals any concrete way of employing a customized user interface. The specification simply states that a user interface can be customized ‘in a plurality of ways’ by allowing users to select and receive ‘on-demand customized audio information.’ Id., col. 16, ll. 21-22, 25-26. That disclosure and the accompanying ‘customized user interface’ limitation in the claim do not constitute a concrete application of the abstract idea of delivering content to a wireless device and thus do not embody an ‘inventive concept,’ as that term has been used in the Mayo/Alice line of cases.”