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Intellectual Ventures I LLC v. Symantec Corp.

Representative Claim

‘050

9. A method for identifying characteristics of data files, comprising:

receiving, on a processing system, file content identifiers for data files from a plurality of file content

identifier generator agents, each agent provided on a source system and creating file content IDs using a mathematical algorithm, via a network;

determining, on the processing system, whether each received content identifier matches a

characteristic of other identifiers; and

outputting, to at least one of the source systems responsive to a request from said source system, an

indication of the characteristic of the data file based on said step of determining.

 ‘142

1. A post office for receiving and redistributing email messages on a computer network, the post office comprising:

a receipt mechanism that receives an e-mail message from a sender, the e-mail message having at least

one specified recipient;

a database of business rules, each business rule specifying an action for controlling the delivery of an e-

mail message as a function of an attribute of the e-mail message;

a rule engine coupled to receive an e-mail message from the receipt mechanism and coupled to the

database to selectively apply the business rules to the e-mail message to determine from selected ones of the business rules a set of actions to be applied to the e-mail message; and

a distribution mechanism coupled to receive the set of actions from the rule engine and apply at least

one action thereof to the e-mail message to control delivery of the e-mail message and which in response to the rule engine applying an action of deferring delivery of the e-mail message, the distribution engine automatically combines the email message with a new distribution list specifying at least one destination post office for receiving the e-mail message for review by an administrator associated with the destination post office, and a rule history specifying the business rules that were determined to be applicable to the e-mail message by at least one rule engine, and automatically delivers the e-mail message to a first destination post office on the distribution list instead of a specified recipient of the e-mail message.

Posture:

Appeals from the United States District Court for the District of Delaware in Nos. 1:10-cv-01067-LPS, 1:12-cv-01581-LPS

Abstract Idea: Yes

The Federal Circuit compared the ‘050 patent with the long held practice of mail sorting.

“The Supreme Court has held that ‘fundamental . . . practice[s] long prevalent’ are abstract ideas. Alice, 134 S. Ct. at 2356. The Supreme Court and we have held that a wide variety of well-known and other activities constitute abstract ideas.

Here, it was long-prevalent practice for people receiving paper mail to look at an envelope and discard certain letters, without opening them, from sources from which they did not wish to receive mail based on characteristics of the mail . . . The patent merely applies a well-known idea using generic computers ‘to the particular technological environment of the Internet.’”

The Federal Circuit agreed with the district court that “the asserted claims of the ‘142 patent are directed to human-practicable concepts, which could be implemented in, for example, a brick-and-mortar post office.” The Court pointed out that IV’s own technology tutorial demonstrated that the concept is well-known and abstract by stating:

“In the typical environment, the post office resides on a mail server, where the company’s emails are received, processed, and routed to recipients. Conceptually, this post office is not much different than a United States Postal Service office that processes letters and packages, except that the process is all computer-implemented and done electronically in a matter of seconds.”

Something More: No

The asserted claims of the ‘050 patent were not patent-eligible because there was no specific or limiting recitation of improved computer technology, rather the asserted claims described only generic computer elements.

“The steps of the asserted claims of the ‘050 patent do not ‘improve the functioning of the computer itself,’ Alice, 134 S. Ct. at 2359, for example by disclosing an ‘improved, particularized method of digital data compression,’ DDR Holdings, 773 F.3d at 1259, or by improving ‘the way a computer stores and retrieves data in memory,’ Enfish, LLC v. Microsoft Corp., 822 F.3d 1327, 1339 (Fed. Cir. 2016). Rather, these claims use generic computers to perform generic computer functions.”

Likewise, the ‘142 specification

“thus confirms that the implementation of the abstract idea is routine and conventional. The ‘142 patent does not ‘improve the functioning of the computer itself.’ Alice, 134 S. Ct. at 2359 (citation omitted). Nor does it solve a “challenge particular to the Internet.” DDR Holdings, 773 F.3d at 1257.