Device Management LLC v. Amazon.com, Inc., C.A. No. 15-762 - SLR, May 17, 2016.
Robinson, J. Defendant’s motion to dismiss is granted.
The patent-in-suit is titled "Method and System for Operating Applications for Remote Terminal Devices." Defendant challenged the patentability of the patent-in-suit pursuant to section 101 and Alice. The court notes the Federal Circuit in DDR, § 101 jurisprudence has evolved from the complete rejection of patentability for computer programs, to the almost complete acceptance of such, to the still difficult-to-discern requirements of the Alice analysis. Furthermore, that the method at bar may be described as the abstract idea of division of labor does not provide the answer to step one of the Alice inquiry. The claimed method, then, generally provides for the installation of a generic client-side application on the terminal device and the installation of a corresponding remote application on the server (which handles most of the graphical processing). It appears that the '683 patent pre-empts virtually all possible ways of performing the claimed method because the very steps of the method comprise nothing more specific than the underlying idea itself.