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Judge Stark denies 101 motion related to claims directed to determining expected time of arrival

Chief Judge Leonard P. Stark recently considered Defendants’ motion for judgment on the pleadings that the asserted claims of the patent-in-suit are invalid under 35 U.S.C. § 101.  Vehicle IP, LLC v. AT&T mobility LLC, et al., No. 09-1007-LPS (D. Del. Sept. 29, 2016).  The patent-in-suit, U.S. Patent No. 5,987,377, discloses methods and systems involving:

a dispatch for generating destination information for a vehicle; a communications link coupled to the dispatch; and a mobile unit coupled to the communications link for receiving the destination information generated by the dispatch, wherein the mobile unit can determine vehicle position and, based on that position, calculate the estimated time of arrival (“ETA”) at a destination identified by the vehicle.

Id. at 1.  Defendants argued that the asserted claims were unpatentable because they claim the abstract idea of “calculating, at a vehicle, its expected time of arrival at a location.”  Id. at 8.  Judge Stark disagreed, at least at this stage:

 While Defendants are correct that each of the claims is directed to a system or method of making a calculation, the details of the system or method steps dominate the claims.The asserted claims are not directed to an abstract idea but, rather, to a specific technological system designed to improve upon earlier technological solutions for calculating ETA. The asserted claims do not merely recite a formula for estimated time of arrival and add the words “apply it.” Instead, the claims recite the use of particular pieces of equipment and assign particular functions to each.  These features are then linked to create a system (or enable a methodology) that allows for the calculation of ET A.

Id. at 9 (internal citations omitted).  Judge Stark went on to note that this conclusion “is further bolstered by the fact that each of the claims appears to involve the use of specialized equipment.”  Id. at 10.  In other words, on the record before the Court, it appears the claims are not “merely directed toward the application of an abstract idea in a generic computer environment.”  Id. at 11 (emphasis in original).  Judge Stark noted that the limited record “at this stage does not make clear whether the hardware limitations recited in the asserted claims reflect the capabilities of a generic computer as of the 1995 priority date of the [patent in suit].”  Id. at 12.

Vehicle IP LLC v. AT&T Mobility LLC, No. 09-1007-LPS

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