GOTV STREAMING, LLC V. NETFLIX, INC.
Before Prost, Clevenger, and Taranto. Appeal from the United States District Court for the
Central District of California.
Summary: A winning claim construction isn’t always enough to overcome § 101.
GoTV Streaming, LLC sued Netflix, Inc. for infringement of three patents directed to methods and systems for delivering and tailoring server content for streaming on wireless devices. Netflix argued that each patent was directed to ineligible subject matter under § 101. The district court rejected Netflix’s § 101 challenge but held all asserted claims of one of GoTV’s patents indefinite. A jury found that Netflix infringed the two remaining patents. GoTV and Netflix filed cross appeals on indefiniteness and patent eligibility.
On appeal, the Federal Circuit first reversed the district court’s indefiniteness holding, instead adopting GoTV’s proposed construction of the claim term. The court then turned to the two-step Alice test and held that, under step one, the claims were directed to the abstract idea of a template set of specifications that can be tailored for final production of a specified product to fit a user’s constraints. The court likened the abstract idea in the claims to a “pattern specifying many but not all details for a dress or trousers” or a “kitchen-cabinet blueprint.” At Alice step two, the court held that the claims lacked an inventive concept because they merely recited ordinary computers and networks collecting information to prepare a tailored image description for display on a device screen. Therefore, the Federal Circuit reversed the district court’s judgment on patentability and ruled in favor of Netflix.
Editor: Sean Murray
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