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Judge Stark grants Section 101 motion

Data Engine Technologies LLC v. Google Inc., C.A. No. 14-1115-LPS (D. Del. Sept. 29, 2016), Chief Judge Leonard P. Stark granted Defendant’s Rule 12(c) motion because the Court concluded that asserted claims of certain of the patents-in-suit were directed to patent-ineligible subject matter.

The patents-in-suit at issue relate to electronic spreadsheets. Id. at 1. The Court’s analysis divided the patents into two groups. First, as to the “Tab Patents,” the patent containing the claim the Court determined was representative “broadly cover[ed] methods for rendering electronic, three-dimensional spreadsheets, wherein individual spreadsheet pages may be labeled and selected via user input such that selected pages are shown while others are ‘obscure[ d].’” Id. at 10. The second group of claims within an additional patent related to tracking changes and versions within a spreadsheet. See id. at 14.

By the time of decision, the Court had already issued its opinion on claim construction, therefore the Court applied those constructions to its decision to the extent necessary. Id. at 1-2. Additionally, because the motion presented an issue of law, the Court “rejected consideration of all extrinsic evidence presented by the parties and relie[d] only on the pleadings and patents, which were attached as exhibits to the complaint, and ma[de] its ruling as a matter of law.” Id. at 16 n.4.

As to the Tab Patents, the Court first determined that the claims were directed to an abstract idea. It agreed with Defendant that the claims covered the abstract idea of “using notebook-type tabs to label and organize spreadsheets,” and that the claims were “directed to nothing more than the basic process of organizing, indexing, and displaying information, which can be (and has historically been) performed manually with an accountant’s columnar pad and a pencil.” Id. at 10-11 (internal quotation marks omitted). It further agreed that the idea was something “humans have commonly performed entirely in their minds, with the air of columnar pads and writing instruments,” which also supported the conclusion that the claims were directed to an abstract idea. Id. at 12. The Court then concluded that the additional limitations of the claims did not add an inventive concept. Specifically, “[t]he concepts of storing electronic spreadsheets in a single file or on a single disk are precisely the type of generic computer limitations that the Supreme Court said could not qualify as inventive concepts in Alice, 134 S. Ct. at 2357.” Id. at 12. Additionally, the claims failed the “machine-or-transformation test” because they were not “tied to a specific machine or implementation described in the respective specifications.” Id. Finally, the Court concluded that these claims would “disproportionately tie up use of the underlying abstract idea” because the claims “add little-to-nothing” to that idea that would meaningfully narrow them “to a specific way of implementing three-dimensional, tabbed spreadsheets.” Id. at 13. Accordingly, the Court concluded the Tab Patents were invalid under Section 101.

As to the additional patent, Defendant argued it was directed to the abstract idea of “collecting data, recognizing certain data within the collected data set, and storing that recognized data.” Id. at 15. The Court “agree[d] that the claims are directed to an abstract idea – but that abstract idea is more accurately, and narrowly, described as collecting spreadsheet data, recognizing changes to spreadsheet data, and storing information about the changes.” Id. at 15 (emphasis in original). Noting that the Federal Circuit has found that similar claims are directed to abstract idea, the Court concluded this patent was also directed to an abstract idea where the patent’s invention “would be straightforward for an accountant to implement in a non-computer context.” Id. Furthermore, there was no inventive concept in the representative claims that would render them eligible. “Limitation of the claims to an electronic spreadsheet technological environment is insufficient to confer patent eligibility,” and the claims also “fail[ed] the machine-or-transformation test. The claims are not tied to a specific machine or implementation described in the specification. The claims do not transform any article into a different state or thing.” Id. at 16. Because the claims also disproportionately tied up their underlying abstract idea, the Court concluded that these claims were also invalid under Section 101. Id.

The Court also denied Plaintiff’s request for leave to amend its Complaint as “amendment would be futile, given the Court’s decision is based entirely on the claims and specifications of the patents, which cannot be amended by repleading.” Id. at 16 n.4.

Data Engine Technologies LLC v. Google Inc., C.A. No. 14-1115-LPS (D. Del. Sept. 29, 2016)

 

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