US PATENT NO. 7,679,637 LLC v GOOGLE LLC
Before Moore, Hughes, and Stoll. Appeal from the United States District Court for the Western District of Washington.
Summary: Result-oriented claims were found ineligible under 35 U.S.C ? 101 because the claims did not describe how the claimed results were achieved or how they embodied any specific technological improvement.
US PATENT NO. 7,679,637 LLC sued Google LLC for infringement of the ’637 patent, which related to web conferencing systems including “time-shifting capabilities” enabling participants “to observe [a] session in real-time, delayed while the session is still in progress, or after the session has completed.” Google moved to dismiss the complaint under Rule 12(b)(6), arguing that the claims were ineligible under 35 U.S.C ? 101. The district court granted Google’s motion to dismiss and denied leave to amend the complaint based on futility. US PATENT NO. 7,679,637 LLC appealed.
The Federal Circuit affirmed the district court’s decision. Under Alice Step One, the Federal Circuit found that the claims were directed to the patent-ineligible abstract idea of “allowing asynchronous review of presentations.” This was because the claims did not describe “how the alleged goal of asynchronous review” was achieved. Further, the Federal Circuit noted that the written description did not disclose any improvement to the underlying components or explain how the claimed invention was a technical solution to a problem facing the inventor. Under Alice Step Two, the Federal Circuit found that the result-oriented claims provided no specific implementation illustrating how to achieve the claimed results. The specification made clear that the claimed applications were conventional, well-known components operating according to their ordinary functions, and therefore could not be an inventive concept.
Editor: Sean Murray
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