Personalized Media Communications, LLC v. v. Amazon.com, Inc., et al., C.A. No. 13-1608 - RGA, August 10, 2015
Andrews, J. Defendants’ motion for judgment on the pleadings is granted.
The disputed technology relates to the use of control and information signals embedded in electronic media content to generate output for display that is personalized and relevant to a user. The court finds that one representative claim is directed to the abstract idea of using personal information to create a customized presentation. This is the same abstract idea that the Federal Circuit held to be patent-ineligible in Intellectual Ventures I. Nor does the claim here provide an inventive concept. The fact that the method was a new means of transmitting information is not relevant to the § 101 analysis. Another claim which relates to updating operating instructions is likewise abstract and lacking in an inventive concept. A third claim recites the abstract idea of encryption. Double encryption has been in place since the Cold war and is not inventive. A fourth claim relating to generating incomplete instructions using information stored at the transmitter station is likewise patent ineligible. A fifth claim relates to cross-selling. User interaction is insufficient to render the claim patent eligible. An additional claim relating to receiving instructions for completing an order, adding personal information and sending the order is abstract and noninventive. Finally, a claim relating to providing recommendations based on general information is also unpatentable.