In a recent memorandum opinion, Chief Judge Leonard P. Stark invalidated on summary judgment Walker Digital’s U.S. Patents No. 5,884,270 and 5,884,272 for lack of patentable subject matter under 35 U.S.C. § 101. Walker Digital, LLC v. Google, Inc., C.A. No. 11-318-LPS (D. Del. Sept. 3, 2014). The patents related to “controlling the release of confidential or sensitive information of at least one of the parties in establishing anonymous communications.” The Court agreed with a hypothetical proposed by Google, which showed that a human would infringe the independent claim of the ’270 patent during “routine headhunting,” and found that “[t]o allow the claim to survive would disproportionately risk preempting a building block of human interaction, retarding rather than promoting progress, contrary to the very purpose patents are granted.” With respect to the ’270 patent’s dependent claims, the Court explained that “[e]ven accepting that the use of a computer increases speed and efficiency of performing the steps of the claims, and improves the likelihood of preserving anonymity of the first and second parties, these characteristics do not save the claims. As the Supreme Court has stated, the mere recicitation of a generic computer cannot transform a patent-ineligible abstract idea into a patent-eligible invention.” (internal quotation marks and citation omitted). The analysis was largely the same with respect to the ’272 patent.