Defendants Motorola Mobility, LLC, Amazon.com, Inc., Apple Inc., Huawei Technologies Co., Ltd., Huawei Device USA, Inc., HTC Corp., HTC America, Inc., Samsung Electronics Co., Ltd., Samsung Electronics America, Inc., and Samsung Telecommunications America, LLC (collectively, “Defendants”), filed a Joint Renewed Motion for Judgment on the Pleadings Declaring All Asserted Patent Claims Invalid Pursuant to 35 U.S.C. § 101. The Plaintiff ContentGuard Holdings, Inc. (“ContentGuard”) opposed the motion arguing that the claims were patentable.
The district court began by explain that: At a high level, the Stefik Patents are generally directed toward systems and methods for controlling the use and distribution of digital works in accordance with “usage rights” through the use of “trusted” systems. See claim 1 of the ‘007 Patent (“sending the digital content . . . to the at least one recipient computing device only if the at least one recipient device has been determined to be trusted”). The Court construed “trusted” to require that three types of “integrities”–physical, communication, and behavioral–be maintained. Similarly, the Nguyen Patents are generally directed toward systems and methods for controlling the use and distribution of digital works in accordance with “usage rights”–and more particularly, “meta-rights”–through the use of “trusted” systems.
The Defendants contended that the claims are directed to patent-ineligible subject matter and therefore are invalid under 35 U.S.C. § 101, arguing that the Stefik Patents address nothing more than the “abstract idea of enforcing usage rights and restrictions on digital content.” Defendants also argued that the Nguyen Patents address nothing more than the “abstract idea of enforcing sublicensing rights and restrictions (which the patents name ‘meta-rights’) on digital content.”
After reviewing a number of the §101defenses, the district court concluded that the patents-in-suit were not directed toward an abstract idea. The district court reached this conclusion “because they are directed toward patent-eligible methods and systems of managing digital rights using specific and non-generic ‘trusted’ devices and systems. See, e.g., (Response at 13 (‘This is significant because it underscores that the subject matter of the Trusted Repository Patents is narrow, i.e., limited to devices that maintain physical, communications, and behavioral integrity, rather than all devices that are capable to receive content via the Internet.’)).”
The district court also found that “even arguendo, if the Court found that the patents are simply directed toward the ‘abstract idea of enforcing usage rights and restrictions on digital content’ as Defendants propose, which it does not, the claim limitations, individually and ‘as an ordered combination,’ are sufficient to ensure that the Patents-in-Suit amount to ‘significantly more’ than a patent simply on that abstract idea. See Alice, 134 S. Ct. at 2355. For example, the claims require that the ‘repository’ be a ‘trusted system’ which the Court construed as ‘maintain[ing] physical, communications, and behavioral integrity in the support of usage rights,’ in order to manage digital rights. At the very least, the Patents-in-Suit disclose particular solutions for the problem of ‘enforcing usage rights and restrictions on digital content’ 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. Internet Patents Corp. v. Active Network, Inc., No. 2014-1048, 2015 WL 3852975, at *6 (Fed. Cir. June 23, 2015).
Accordingly, the district court denied the motion for judgment on the pleadings.
Continentalguard Holdings, Inc. v. Amazon.com, Inc., Case No. 2:13-CV-1112-JRG (E.D. Tex. Aug. 2015)
The authors of www.PatentLawyerBlog.com are patent trial lawyers at Jeffer Mangels Butler & Mitchell LLP. For more information about this case, contact Stan Gibson at 310.201.3548 or SGibson@jmbm.com.