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Judge Robinson grants motion for judgment on the pleadings under § 101.

Judge Sue L. Robinson recently granted a defendant’s motion for judgment on the pleadings under 35 U.S.C. § 101.  Cyberfone Sys., LLC v. Lexmark Int’l, Inc., Civ. No. 14-1489-SLR (D. Del. Oct. 8, 2015).  The patent at issue, titled “Data Transaction Assembly Server,” was directed to “a form driven operating system which permits dynamic reconfiguration of the host processor into a virtual machine which supports any of a number of operating system independent data transactions, and more particularly, to a data transaction assembly server which downloads data transactions representative of different applications.”  Id. at 1, 13.  Judge Robinson found that the purpose of the patent claims—“entering and processing data in response to questions on forms or templates”—was an abstract concept.  Id. at 16.  The Court further found that “although the problem addressed by the asserted claims is rooted in computer technology, the claimed solution is not disclosed with enough specificity to transform the abstract idea . . . into a patentable application of such, thus risking monopolization of the abstract idea itself.”  Id. at 18.

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