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Chief Judge Stark denies motion for judgment on the pleadings

Chief Judge Leonard P. Stark recently denied a motion for judgment on the pleadings under section 101.  MAZ Encryption Technologies LLC v. Blackberry Corp., C.A. No. 13-304-LPS (D. Del. Sept. 29, 2016).  At issue were claims describing “a process that enables frictionless, ‘behind-the-scenes’ encryption – when a user closes or saves a file, the invention automatically obtains an appropriate encryption key, encrypts the file, and saves the encrypted file in EDMS.”  Id. at 10.  In so ruling, Chief Judge Stark rejected the defendant’s analogy between the claimed invention and “how an old hotel would store and keep track of the keys to its patrons’ rooms.”  Id. at 15.  The Court explained, “Defendant’s analogy is unpersuasive.  It fails to capture the key inventive aspect touted in the ‘681 patent:  handling encryption operations without requiring user input, that is, ‘transparently.'”  Id. at 16 (emphasis in original).  Chief Judge Stark added that the defendant’s analogy failed because each of the purportedly analogous steps performed in connection with how an old hotel would store and keep track of room keys were manually performed by a hotel clerk.  Id. at 16.  Overall, the Court found that the claims were not directed to an abstract idea under the Alice/Mayo analysis.  Instead, in the Rule 12(c) posture, the Court was required to accept as true the specification’s statements that the claimed invention was a technical solution to problems in the prior art.  Id. at 10-11.  The Court therefore denied the motion for judgment on the pleadings, but noted that several of the defendant’s arguments that could have been considered in a different procedural context–because they relied on extrinsic evidence–could not be considered in the context of the motion the defendant elected to bring.

MAZ Encryption Technologies LLC v. Blackberry Corp., C.A. No. 13-304-LPS (D. Del. Sept. 29, 2016)

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