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Easyweb Innovations v. Twitter

Representative Claim

1. A message publishing system (MPS) operative to process a message from a sender in a first format, comprising:

a central processor;
at least one sender account;
at least one storage area configured to store at least a first portion of the message; and
software executing in the central processor to configure the processor so as to:

identify the sender of the message as an authorized sender based on information associated with the message in comparison to data in the sender account, wherein the identification is dependent upon the first format;
convert at least a second portion of the message from the first format to a second format; and
publish the converted second portion of the message so as to be viewable in the second format only if the sender has been identified as an authorized sender.

Posture:

Appeal(s) from the US District Court for the Eastern District of New York (Case No. 2:11-cv-04550)

Abstract Idea: Yes

At the first step of the Alice/Mayo framework, the court found that claim 1 is directed to an abstract idea because “[it] merely recites the familiar concepts of receiving, authenticating, and publishing data.”  The court noted several prior cases where it previously explained that “claims involving data collection, analysis, and publication are directed to an abstract idea. Elec. Power Grp. v. Alstom S.A., 830 F.3d 1350, 1353 (Fed. Cir. 2016) . . . ; see also In re TLI Commc’ns LLC Patent Litig., 823 F.3d at 611; FairWarning IP, LLC v. Iatric Sys., Inc., 839 F.3d 1089, 1093-94 (Fed. Cir. 2016).”  The court went on to distinguish other cases involving claims found non-abstract by noting that “[c]laim 1 . . . uses generic computer technology to perform data collection, analysis, and publication and does not recite an improvement to a particular computer technology[.]”

Something More: No

The court’s brief analysis at step two of the Alice/Mayo framework declined to accept arguments from the appellant/patent owner that “an inventive concept arises from the ordered combination of steps in claim 1.”  Instead, the court found that “[c]laim 1 recites the most basic of steps in data collection, analysis, and publication and they are recited in the ordinary order.”